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The parties’ submissions
The parties’ submissions
In Allam, the UT upheld the decision of the FTT in that case to the effect that the company in question had carried on activities during the period relevant to the claim for entrepreneurs’ relief which were, to a substantial extent, not trading activities.
The Respondents submit that the facts in the present case are on all fours with the facts in Allam. In particular, they point out that, during the relevant period:
the only income derived by PSSL was rental income;
the quantum of that income was meaningful;
no actual re–development of the Property took place; and
the expenditure in relation to the re–development of the Property was relatively insignificant
- 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