TC09530 - [2025] UKFTT 00566 (TC)

We agree with the Respondents that the company was not actually carrying on a trade during the relevant period, for the reasons given in paragraphs 25 above. Indeed, we did not understand the Appellants to disagree with that proposition.

However, that does not mean that the activities of the company during the relevant period were not for the purposes of a trade that it was preparing to carry on or with a view to its starting to carry on a trade.