![TC09530 - [2025] UKFTT 00566 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
Not carrying out trading activities
Not carrying out trading activities
Activities not in the course of a trade
The Respondents’ submissions
In support of their first proposition, the Respondents submit that the sole activity of the company during the relevant period was one of property investment. They point to the fact that:
the Appellants have provided no evidence that the company bought or sold any other property during the relevant period;
the Property was initially acquired by PSSL as the consideration for the discharge of a loan which had been held by the company as an investment and it too was therefore acquired as an investment;
the Property was described in the accounts of the company for each of the 2017 AP and the 2018 AP as “investment property” and note 1 to the accounts of the company for the 2016 AP alluded to the fact that the Property was held as an investment; and
the only income of the company during the relevant period was the rental income which it derived from the Property.
- Heading
- Introduction
- the facts
- The relevant law
- with a view to its … starting to carry on a trade, …” The issue in dispute
- Not carrying out trading activities
- Our conclusion
- Activities not for the purposes of a trade which the company was preparing to carry on or with a view to its starting to carry on a trade
- Our conclusion
- Post–script
- Substantial non–trading activities
- The parties’ submissions
- and that no re–development of the Property has ever taken place
- Conclusions