The cases of Ramsay and Zetland can help provide an answer, says Peter Vaines
The term business is not defined for capital gains tax or inheritance tax legislation but we have two recent tribunal cases to help our understanding.
By an interesting coincidence two of the tribunal cases published last month dealt with the same point – the meaning of a business for tax purposes. In Elizabeth Moyne Ramsay v HMRC [2013] UKUT 0226 (TCC) the Upper Tribunal looked at whether the letting of residential accommodation was a business for the purposes of the capital gains tax relief in TCGA 1992 s 162 where a business is transferred to a company in exchange for shares. In Trustees of David Zetland Settlement v HMRC...
