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Meeting points

10 January 2007 / Mark McLaughlin CTA (Fellow)
Issue: 4090 / Categories: Events , HMRC powers
Longmark Tax Conferences Ltd conference: The first North West Property Tax Planning Conference, 30 November 2006. Reported by MARK McLAUGHLIN CTA.

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...

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