Charles Hellier

Decision released 3 July 2006

Date trade commenced – trade set up and commenced – section 218 FA 94 – whether trade had commenced at a time when heads of terms for a purchase had been agreed


A special commissioner decided that a taxpayer had not set up and commenced his trade until after 6 April 1994 for the purposes of the Finance Act 1994, s. 218 where, before that date, he had nothing with which to trade and had merely incurred expenditure in preparation for trading rather than carried on operational activities.


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