.png)
.png)
MARK McLAUGHLIN CTA (Fellow), ATT, TEP, considers a problem with Code of Practice 10 taper relief rulings on trading company status, and offers a possible solution.
IT ALWAYS WORRIES me when HM Revenue & Customs (HMRC) announce a clarification of legislation. Past experience causes apprehension that the 'clarification' is going to leave me even more uncertain than before! A recent example of this is HMRC's guidance on the definition of 'trading company' for capital gains tax taper relief purposes and the measures to be applied when determining trading company status.
MARK McLAUGHLIN CTA (Fellow) ATT TEP considers a problem with Code of Practice 10 taper relief rulings on trading company status and offers a possible solution.
IT ALWAYS WORRIES me when HM Revenue & Customs (HMRC) announce a clarification of legislation. Past experience causes apprehension that the 'clarification' is going to leave me even more uncertain than before! A recent example of this is HMRC's guidance on the definition of 'trading company' for capital gains tax taper relief purposes and the measures to be applied when determining trading company status.
Practical difficulties in establishing trading company status in the context of 'substantial' non-trading activities were described in 'A Substantial Qualification' by Paul Lodge and Matt Reid (see Taxation 20 January 2005). Tax Bulletin 53 states that tax districts '… should respond positively' if a company wishes to establish its status as a trading company (or...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
