Thanks, much appreciated. That’s the conclusion we reached here, and confirmed to a health board online newsletter on same question only came across now.
Sure, but a client selling half his/her clients (and surviving off the remaining half) might argue that the half sold constituted (or could constitute) a business in its own right. CGT is a tax on disposal. It can't be wrong to look at what is disposed of (and not just what is acquired). And I think the farming cases in CG64020 do just that.
(I'm not sure we are disagreeing; just seeing the same thing from different angles. I get that with Jon a lot in here too. Seems I am the common factor... the one with odd perspectives.)
I'm not sure the farming cases help as there seems to have been a reduction in the scale of the business plus a change in that business for each. If the IFA was giving up say small business owners and focusing on private clients, would that work?!
"The relevance of Retirement Relief case law....."
This sums up my concern. Yes, current legislation heavily drawn from RR. Mr Gilbert did sell one of his clients (< 10 from memory) and the only near relevant ER case I could find.
My answers
Each property in company < £500k value for ATED, any thoughts on CIHC question?
Why bother posting if you are not offering help, is that not the point of this forum?! Nice dog picture though!
Thanks, much appreciated. That’s the conclusion we reached here, and confirmed to a health board online newsletter on same question only came across now.
Anyone able to help with this?
Broadly yes; seems to be an investment company, no 'trade' and so an entry in Box 155 'trading profits' and not Box 190 just doesn't look right.
DJKL that is most useful and reassures my understanding. Each holding will have to be looked through to determine whether NTLR rules apply or not.
Any one any answers to the specific questions raised?
I'm not sure the farming cases help as there seems to have been a reduction in the scale of the business plus a change in that business for each. If the IFA was giving up say small business owners and focusing on private clients, would that work?!
"The relevance of Retirement Relief case law....."
This sums up my concern. Yes, current legislation heavily drawn from RR. Mr Gilbert did sell one of his clients (< 10 from memory) and the only near relevant ER case I could find.
Eh pointless comment, that’s rich, reread the entire thread, and do have a great day!