Incorporation relief under s. 162 TCGA - definition of 'business'
Do readers have experience of the definition of a business for incorporation relief purposes.
We have a partnership owning a large portfolio of residential and commercial property. They work full time collecting rents, and organising repairs. In some instances they are very hands on with repairs themselves. They have an office and it is a full time job.
Is this a business for s.162 purposes?
Does it make a difference if partnership rental income was shown as rental income in individual partners tax returns rather than a partnership trade? ie no NIC's have been paid therefore it does not look like a business to me.
- Goodwill Valuation Prior to April 2002, with the intention of selling on due to personal changes 494 14
- Dividend Vouchers 358 5
- Gift to employee 400 14
- Profit accruing in fiduciary or representative capacity 156 3
- MS Surface Pro 3 128 2
- practice planning 74 1
- HMRC Penalties - are they enforceable? 1,105 37
- Child and Working Tax Credits and sudden increase in investment income - does this trigger a claw back? 175 3
- Anybody have that old ACCA Student Training Record (STR1) 153 1
- Question re Career choice... 1,652 10
- Which address 1,071 12
- Does anybody still use a Filofax? 601 20
- Financial statements in Word, with formulas 1,510 17
- Your fondest calculator memories 1,218 44
- R&D tax claim 259 7
- You think HMRC are inefficient? 546 9
- Company Pension Contributions 2013/14 210 7
- Tax Allowance on University Course 197 1
- Transfer of a business 131 1
- I hate HMRC's voice recognition system - The Inept Interrogator 1,170 22
- DTR : TIOPA 2010 Section 42 487
- CTA study material 459
- Sect 102 TMA 1970 337
- Pre incorp expenses 321
- Relief on French Tax Deposit? 271
- Anyone have clients that use Pay4Later to offer customers credit? 262
- What is the tax position if I am working overseas but via a UK agency? 212
- Gift Aid after 5 April, before 31 Jan - Tax Credits 167
- Taxation of partners in an LLP following new rules 140
- Employment related securities question 128