We should be grateful for readers' views on our chances of success in persuading HMRC that substantial pension contributions in the following circumstances are wholly and exclusively for the purpose of the business.
A limited company has traded as a garden centre for sufficient years to give the husband and wife shareholders 75% taper relief.
The assets of the company — freeholds goodwill stock and equipment were sold in May 2007 and the capital gains on the sales of freeholds and goodwill after indexation amount to £500 000. It is not wished to reinvest in any business assets.
Both husband and wife have been very active in the business but minimal if any salaries have been taken over the years as the shareholders have been in receipt of other forms of income; similarly there have been minimal dividends.
...Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.