Hopefully this will be a quick answer. When we have an individual holding a property and they incorporate it into a company with the intention that the company will develop it and sell it one, could the gain arising on the initial transfer into the company be subject to income tax under the new rules? I assume not but cannot find an example on the subject....
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What does "and they incorporate it {a piece of land] into a company" mean? Land cannot become a company.
This is yet another question where the staring point is the trading/investment intention of the vendor, not the new rules (which are not much different to the old rules). If you read the relevant case law, the holding of land without rental income for future gain only can be capital and IMHO the new rules should not cause that to be income (but the explanation is detailed).
Seems to me their intention is likely trading as certainly is the company's, any background on the history of the individuals and the property to consider?