In the Upper Tribunal, Rebecca Sheldon alongside Harriet Brown, acted on behalf of the Appellant, Coconut Animated Island Limited (CAIL). This appeal concerned a decision of the First-tier Tribunal, regarding whether arrangements for issuing shares were “disqualifying arrangements”. The FTT previously ruled that because Condition A in s257CF(3) of the Income Tax Act 2007 was met, the arrangements for issuing the shares were “disqualifying arrangements”. This appeal explored scope of “arrangements” in s257HJ, as well as the meaning of a “relevant person” and “party to the arrangements” in s257CF(6) of the Income Tax Act 2007, in establishing whether the arrangements for issuing shares were “disqualifying arrangements”. For more information on this case, please view the judgment.