Susanna Breslin writes for Lexis on the Upper Tribunal's decision in Osmond and Allen v HMRC [2025] UKUT 183 (TCC)

Susanna Breslin writes for Lexis on the Upper Tribunal’s decision in Osmond and Allen v HMRC [2025] UKUT 183 (TCC)

Susanna Breslin writes for Lexis on the Upper Tribunal’s decision in Osmond and Allen v HMRC [2025] UKUT 183 (TCC). The Upper Tribunal allowed the taxpayers’ appeal, holding that they did not necessarily have a main purpose of obtaining “an income tax advantage” under the Transactions in Securities regime simply by virtue of having main purpose of obtaining the benefit of Enterprise Investment Scheme disposal relief.