A company preparing to carry on or start a trade was nevertheless not a trading company for entrepreneurs’ relief purposes because non-trading activities were a substantial part of the company’s overall activities. 

Summary 

A company preparing to carry on or start a trade was nevertheless not a trading company for entrepreneurs’ relief (ER) purposes because non-trading activities were a substantial part of the company’s overall activities. 

Background 

The appellants (TE, ZM and CP) were directors of a company (PSSL) from incorporation in 2011. In 2016, PSSL acquired a property. Previously, PSSL had made a loan to an unrelated third party (the original property owner) to enable the original property owner to acquire the property. PSSL acquired the property after the original property owner was unable to service the loan and interest. 

PSSL