The appellants’ activities constituted a business but did not amount to a trade for entrepreneurs’ relief purposes.  

One appellant (SR) was a self-employed freelance MOT tester and vehicle mechanic; the other appellant (LRS) was a hairdresser. LRS was also employed in SR’s business dealing with administration and accounts. In 1993, the appellants acquired Unit 2 of a commercial premises, and in 1998 acquired Unit 1. 

The premises were unoccupied from June 2011 until 1 February 2012, when a business was set up offering secure storage in Unit 2 and the opportunity for third parties to hire workshop facilities in Unit 1. 

SR was subsequently approached by a classic car dealer, which stored cars at the premises from 1 November 2012 until 31 March 2013. SR continued as a freelance MOT tester, working at customer