For a number of years taxpayers or their agents have been able to approach HMRC for their views as to whether a company was a trading company for business taper relief purposes. Many advisers have used this facility to great effect to ensure the availability of the 75% reduction in the taxable gain.

HMRC have now withdrawn the facility to ask for a pre transaction view and will only give an opinion after the transaction has taken place.

Internet link:

Tax Bulletin 84