188体育

Young, Austen & Young Ltd (YAY) beneficially owned all the shares in Jones Refrigeration Ltd (Jones). It wanted to sell these shares but Jones owed 拢200,000 to YAY and other group companies which it could not repay. YAY subscribed for a further 200,000 拢1 ordinary shares in Jones which Jones used to repay the loans. YAY sold the shares in Jones. As discussed in CG51748 the subscription for the new shares was treated as a share reorganisation. YAY claimed a deduction for the 拢200,000 it had paid for the shares even though it was agreed the transaction was a bargain made otherwise than at arm鈥檚 length.