In Thompson (HMIT) v Hart 2000 STC 381 the taxpayer received shares in return for properties transferred to a company as part of a BES scheme. He claimed BES relief in relation to a subscription for these shares. Relief was denied as he had transferred property in return for the shares and had not subscribed cash. The Judge ruled that “money” could not be extended to include money’s worth and accordingly did not extend to include property.
In National Westminister Bank plc v IRC 1994 STC 580 it was held shares were not issued until they had been finally registered, following application and allotment.