I have a client who has, over four or five years, refurbished a listed building and turned it into appartments. The project is now over and he now wishes to close down the company through an MVL and claim ER on the proceeds.
He does have three rental properties, held personally, which he has held for three, six and ten years respectively. He intends to keep these, although, should a tenant leave, he might consider selling a property, instead of re-letting. He may buy another in its place or add to his portfolio.
Does anyone disagree that this is a different type of trade to the one run by the company ? Imho, he is not caught by the TAAR but this is relatively new legislation and there's not much of a track record at the moment.