VCM25210 - EIS: income tax relief: associates: 'interested in'

For the purpose of VCM25200, the words ’interested in' have a wide meaning. For example, where shares are held by trustees, the trustees, the beneficiaries and the remainderman (if any) of the trust are all interested in the shares. Where shares are held by trustees under a will for persons in succession, the life tenant and the remainderman, as well as the trustees, are interested in the shares. (See, in this connection, CIR v Park Investments Ltd, 43TC200, particularly the judgment of Danckwerts L J at page 225, CIR v Tring Investments Ltd, 22TC679, and Alexander Drew and Sons Ltd v CIR, 17TC140.)

The executors or administrators are interested in the assets of a deceased person's estate during the period of administration, (Willingale v Islington Green Investment Co, 48TC547). The beneficiaries should be regarded as interested in any assets of the estate from which they may benefit.