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MARK McLAUGHLIN explains why a company's 'trading company' status may depend on the HMRC official considering its Code of Practice 10 application.
IT IS UNFORTUNATE that there is very often a necessity for tax advisers to include phrases like 'it all depends …' and 'subject to …' in their advice to clients. I can imagine that many clients interpret such phrases as 'ifs' and 'buts' and ask themselves 'does he really know what he's talking about?'! I have to confess that when it comes to predicting how HMRC will react in certain situations the answer is 'probably not'!
MARK McLAUGHLIN explains why a company's 'trading company' status may depend on the HMRC official considering its Code of Practice 10 application.
IT IS UNFORTUNATE that there is very often a necessity for tax advisers to include phrases like 'it all depends …' and 'subject to …' in their advice to clients. I can imagine that many clients interpret such phrases as 'ifs' and 'buts' and ask themselves 'does he really know what he's talking about?'! I have to confess that when it comes to predicting how HMRC will react in certain situations the answer is 'probably not'!
Russian roulette
In my article 'National Lottery?' (Taxation 14 July 2005) I extolled the virtues of applications to HMRC for Code of Practice 10 (COP10) rulings on 'trading company' status for capital gains tax taper relief purposes (well it seemed like a good idea at the time). However...
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