Pension contribution by property company

Pension contribution by property company

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A company owns a commercial property that it rents out to an associated company. For Corporation Tax it has been treated as an investment company.

It intends to sell the property which will give rise to a large Corporation Tax bill.

If, prior to the sale, the company pays a large contribution to a pension scheme for the benefit of the directors & claims loss relief set-off against the gain, would HMRC object on the 'wholly & exclusively' basis?

There was alot of talk about pension payments & allowability earlier in the year, but haven't heard much lately.

Any offers anyone?

Brian

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