Meeting points

The speakers quoted are all barristers from Gray's Inn Tax Chambers: Felicity Cullen Michael Thomas Conrad McDonnell Patrick Soares Barrie Akin   Patrick Way.

Companies exploiting land

Salaried Persons Postal Loans Ltd v HMRC [2006] STC 1315 gives rise to the possibility of a company owning property and deriving a rental return from it without carrying on a trade or investment business said Felicity Cullen. HMRC did not appeal this case so the authority stands. However the circumstances in which a company letting property is found not to be carrying on a business are likely to be exceptional. The case is understood to be causing concern for property-owning companies about the deduction of management expenses under TA 1988 s 75 for companies with investment business. In addition following the decision HMRC are apparently arguing more strongly that certain property...