Trade losses not recoverable:Losses made in a trade carried on by a sole trader can be set against his or her other income. However relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v HMRC [2025] UKFTT 495 (TC) (1 May) which involves losses incurred in a shooting business on a country estate emphasises that the two limbs of the test are independent. The FTT accepted that the trade was being carried on a commercial basis. However it found that the second part of the test was not satisfied. Its conclusion was clear: ‘Profit clearly means the excess of income over expenditure. The Shoot hardly made a profit in over 15 years of operation. Having considered all of the information in the documents before us we did not get the impression that...
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Trade losses not recoverable:Losses made in a trade carried on by a sole trader can be set against his or her other income. However relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v HMRC [2025] UKFTT 495 (TC) (1 May) which involves losses incurred in a shooting business on a country estate emphasises that the two limbs of the test are independent. The FTT accepted that the trade was being carried on a commercial basis. However it found that the second part of the test was not satisfied. Its conclusion was clear: ‘Profit clearly means the excess of income over expenditure. The Shoot hardly made a profit in over 15 years of operation. Having considered all of the information in the documents before us we did not get the impression that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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