This month’s update by Mark Watterson and Gary Barnett (Simmons & Simmons) covers FTT decisions on the tests for a transfer of a going concern and a ‘direct and immediate’ link.
TOGCs and property development
In Haymarket Media Group Ltd v HMRC [2022] UKFTT 168 the FTT has held that the sale of a property with the benefit of planning permission and subject to short term leases to persons connected with the buyer (in the commercial sense) did not amount to a transfer of a going concern (TOGC). The FTT rejected the taxpayer’s contention that the sale was of a property development or property letting business.
Haymarket had been the owner of a building in Teddington since 2004 which it both occupied as its own business premises and leased to tenants. In 2014 it sought planning permission for the redevelopment of the property with a view...
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This month’s update by Mark Watterson and Gary Barnett (Simmons & Simmons) covers FTT decisions on the tests for a transfer of a going concern and a ‘direct and immediate’ link.
TOGCs and property development
In Haymarket Media Group Ltd v HMRC [2022] UKFTT 168 the FTT has held that the sale of a property with the benefit of planning permission and subject to short term leases to persons connected with the buyer (in the commercial sense) did not amount to a transfer of a going concern (TOGC). The FTT rejected the taxpayer’s contention that the sale was of a property development or property letting business.
Haymarket had been the owner of a building in Teddington since 2004 which it both occupied as its own business premises and leased to tenants. In 2014 it sought planning permission for the redevelopment of the property with a view...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
