My clients (UK resident and domiciled) set up an offshore FURB (Jersey) in May 2000. Shares (value £200,000) owned by their UK trading company were transferred to it and PAYE and NIC was paid. The shares were sold in 2002 for £400,000. The FURB trustees created an offshore limited company owned by the firm and lent it £250,000, which was used to buy a UK residential property. The company plans to demolish it and construct a small block of flats (using borrowed money) to be sold with the intention of making a profit. My questions relate to the UK tax treatment on these proposals.
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