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My client is a trading company which occupies premises on which it has spent extensive amounts. Originally the building was bought by the holding company of the trading company but shortly afterwards was sold by the holding company to a self-invested personal pension (SIPP) fund for the benefit of the directors of the trading company. Since the disposal of the property to the pension fund about £100 000 has been spent by the tenant on integral features.
In the case of a future sale of the building by say the pension fund to a property investor is it necessary for a fixed value claim under CAA 2001 s 198 to be made at that point? I am bearing in mind that the existing tenant which incurred the expenditure will continue to occupy the building?
Taxation readers’ thoughts would be much appreciated.
Query 19 671...
