Holding company was not ‘trading’ for entrepreneurs’ relief purposes
In A Moffat and another v HMRC [2025] UKFTT 663 (TC) (5 June) the FTT held that the taxpayers’ claims for entrepreneurs’ relief (now business asset disposal relief) on the disposal of shares in a company did not succeed because the company was not the holding company of a trading group. The FTT however allowed their appeal against penalties imposed by HMRC in respect of the claims holding that the taxpayers had not behaved carelessly.
The taxpayers sold their shares in CM Ltd a company which had a subsidiary CYBC Ltd which operated a pier in Chelsea providing moorings together with services and maintenance for houseboats. Houseboat owners paid mooring fees and maintenance charges annually to CYBC Ltd. Maintenance charges were for connection to utilities a concierge service and nightwatchman patrol and...
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Holding company was not ‘trading’ for entrepreneurs’ relief purposes
In A Moffat and another v HMRC [2025] UKFTT 663 (TC) (5 June) the FTT held that the taxpayers’ claims for entrepreneurs’ relief (now business asset disposal relief) on the disposal of shares in a company did not succeed because the company was not the holding company of a trading group. The FTT however allowed their appeal against penalties imposed by HMRC in respect of the claims holding that the taxpayers had not behaved carelessly.
The taxpayers sold their shares in CM Ltd a company which had a subsidiary CYBC Ltd which operated a pier in Chelsea providing moorings together with services and maintenance for houseboats. Houseboat owners paid mooring fees and maintenance charges annually to CYBC Ltd. Maintenance charges were for connection to utilities a concierge service and nightwatchman patrol and...
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