A very unusual one has come across my desk.
Mrs Cook & Mr Washerup wanted to open a restaurant, they took a property and were rate payers from Feb 2020, there was a fair amount of work getting it ready and therefore they would have opened the doors April/May 2020, but we all know what happened next. In April 2020 the local authority paid them them a 25k grant.
After this they continued to attempt to get the business up and running but for various reasons were unable to. They were even given a further grant from the local authority later in the year.
Has the trade commenced? I would say no, because they have never been in a position to open the doors and offer a service.
If we accept that, is the Local Authority grant therefore not taxable? The grants far exceed the expenses.