Company has investment property that has halved in value. An impairment provision will have no effect on the tax position. But what if the company were to decide to develop the property, and so appopriate it to trading stock under a s161 election? Effect would be to transfer asset into stock at cost, but if a provision were then made against stock value would this provision be allowable as a trade deduction? I'm aware of the knock-on consequences on eventual sale, but client is concerned only about the immediate position.
26th Apr 2012 21:27