Profit accruing in fiduciary or representative capacity

Profit accruing in fiduciary or representative...

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I have a client who has bought two blocks of flats (£1.6M) and is looking at investment from them after renovation. He will sell some flats and retain others.

The expected "investment advisor" has arrived and told him that under that he should take advantage of CTA 2009 c.4.

I am researching at present but would appreciate input from those whose knowledge is greater than mine as to the way this works and the inherent dangers as search engines are not very productive.

Thanks

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By Justin Bryant
22nd Aug 2014 16:56

I think

This may be a Baxendale-Walker type scheme and if so there's not much more to say.

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By Steve Kesby
22nd Aug 2014 20:53

No Justin...

... it's not a [***] film! :)

It's in CTA 2009, s.3 and s. 6. Profits accruing to a company in a fiduciary or representative capacity really aren't chargeable to Corporation Tax, for a reason; the reason being that they're chargeable on the beneficial owners of those profits!

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By Justin Bryant
26th Aug 2014 10:46

No Steve

You have rather missed the point. There is a BW type scheme that suggests that that is a loophole that can be used for Yoshik's client. You can probably find it on Google etc.

https://www.accountingweb.co.uk/anyanswers/question/profit-extraction-using-remuneration-trust-rt 

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