In Reddleman Properties Ltd v HMRC (TC01250 – 13 July) a company (R) submitted a CT return claiming the benefit of the small companies’ rate.
HMRC issued an amendment charging tax at the full CT rate on the basis that R was a ‘close investment-holding company’.
R appealed contending that it existed ‘for the purpose of making investments in land’ within what is now CTA 2010 s 34(2)(b).
The First-tier Tribunal rejected this contention and dismissed the appeal finding that most of R’s income was rental income from an associated company so that even though R’s long-term intention may have been to derive most of its income from lettings to unconnected parties it remained a close investment-holding company during the year in question.
(The company applied for the decision to be anonymised. The...
