Corporation tax – Whether the appellantʼs activity in relation to the development of an office property was a trading activity or an investment – Penalties for alleged negligent return – Appeal allowed.
The appellant had claimed that a London-based property was bought with the intention of using it as an investment rather than as trading stock to sell on at a profit. The First-tier Tribunal (FTT) found on the weight of the evidence that the intention of the appellant was to buy the property as an investment for rental yield and so upheld the appeal.
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