Quote Originally Posted by Interested_Party View Post
Thanks unhuman (and the other two). I don't think I've left out any relevant facts. But if you think there is something that could change this position please ask me and I'll endeavour to answer. As you can probably see I've been giving this a lot of thought. But I'm not a tax person and I don't know what I don't know. Thanks in advance.
No I don't think so. The issue is determining the intent on purchase of the shares (bearing in mind that I believe the onus of proof would be on yourselves if the IRD challenged the sales).

The evidence of intent seems to be very clear based on what you have outlined.