A subsidiary company carried on activities which included to a substantial extent activities other than trading activities, such that the company was not a trading company for entrepreneurs’ relief purposes, and by definition the holding company was not the holding company of a trading group. 

Summary 

A subsidiary company carried on activities which included to a substantial extent activities other than trading activities, such that the company was not a trading company for entrepreneurs’ relief (ER) purposes, and by definition its holding company was not the holding company of a trading group. 

Background 

The appellants held shares in a company (CYBC) and had been directors since 1 February 2016. CYBC was located at Cheyne Pier, Chelsea. Its principal activities were the provision of moorings together with services and maintenance, as well as additional optional