Taper relief and corporate partners

Taper relief and corporate partners

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I am interested in people's views on the taper relief status of the shares in a company that is a partner in a trading partnership.

If we ignore any other income except that arising from the partnership what are people's opinions about whether the shares are business or non business assets? Also what do they think are the salient points in deciding on the status for these types of company.
Simon Denton

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By User deleted
14th Aug 2006 14:52

Can you ignore the other aspects of the company?
Prima facie, whether a company trades itself or in partnership with others, where the partnership itself is trading, the shares qualify for BATR.
ICTA s118ZA(1) extends this to a trade carried on by an LLP. ICTA s114 covers a general partnership

TCGA 1992 Sch A1 , para.'s 23 and 24 extend this to where the partnership is via a JV comapny or a joint enterprise company, as defined.

The remaining issue is whether - looking at the company as a whole - it satisfies TCGA Sch A1 para 22A or does it otherwise conduct activities which are substantially other than trading?

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