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Andrew Richardson v HMRC

In Andrew Richardson v HMRC [2015] UKFTT 179 (25 April 2015) the FTT found that taper relief did not apply to the disposal of a property occupied by subsidiaries of listed companies.

Mr Richardson together with a business associate had purchased a property comprising a shop and an office which had both been let to tenants. The property had later been sold with the tenants still in occupation and taper relief had been claimed on the disposal under TCGA 1992 Sch A1. HMRC had denied relief on the ground that the tenants were listed companies.

The FTT accepted that the tenants were trading companies; however they were ‘51% subsidiaries’ (ICTA 1988 s 838) of listed companies. The property was therefore not used by ‘qualifying companies’ and taper relief did not apply to its disposal.

Read the decision.

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