In 2020, ten companies, all with a common director who was a chartered accountant (AD), had their claims for seed enterprise investment scheme (SEIS) relief denied by HMRC. The refusal was based on three main grounds for each company: failure to meet the risk-to-capital condition, the trading condition, and engagement in disqualifying arrangements. In the case of the eighth company, HMRC additionally argued that the ‘shares requirement’ was not satisfied. The First-tier Tribunal sided with HMRC, accepting the argument of artificial fragmentation motivated by a desire for increased SEIS relief. As a result, the taxpayer’s appeal was dismissed.