In PEMS Butler Ltd v HMRC (TC01769 – 7 February) a trading company (P) had purchased a farm in 1990 and used it as its premises until 2000. It then sold the farm for £600 000 and purchased a replacement property for £354 900. P’s directors moved into the new property and P claimed rollover relief in respect of part of its gain on the sale of the farm. Following an enquiry HMRC issued a closure notice on the basis that 95% of the new property was used for non-trading purposes so that only 5% of the purchase price (ie £17 745) could be treated as qualifying for rollover relief. P appealed. The First-tier Tribunal reviewed the evidence and allowed the appeal in part finding that most of the property was occupied by P’s directors and that P was...
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In PEMS Butler Ltd v HMRC (TC01769 – 7 February) a trading company (P) had purchased a farm in 1990 and used it as its premises until 2000. It then sold the farm for £600 000 and purchased a replacement property for £354 900. P’s directors moved into the new property and P claimed rollover relief in respect of part of its gain on the sale of the farm. Following an enquiry HMRC issued a closure notice on the basis that 95% of the new property was used for non-trading purposes so that only 5% of the purchase price (ie £17 745) could be treated as qualifying for rollover relief. P appealed. The First-tier Tribunal reviewed the evidence and allowed the appeal in part finding that most of the property was occupied by P’s directors and that P was...
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