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Over the fences

15 October 2013
Issue: 4424 / Categories: Forum & Feedback , Capital Gains

A client purchased new business premises and claimed rollover relief. HMRC contend that the claim fails because the business activities contain an element of horse racing

Our client bought new business premises prepared them and then sold his old ones. HMRC say that the claim to capital gains tax rollover relief fails because his activities breeding foals that become racehorses contain an element of horse racing.

Our client keeps one old male horse at a time as a “role model” companion and calming influence for the young foals which we understand is normal practice.

Once a year this mature horse is entered into a licensed race so our client gains access to owners and trainers and can discuss the foals he has to sell.

The race itself is not the point of the exercise. On one or two other occasions a year the mature horse has raced in local amateur races again to keep customers aware of our client’s business.

HMRC say that because there is an element...

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