Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

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...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon