Summary 
 
A company that did not issue any invoices between March 2009 and its liquidation in 2015/16 was nevertheless a trading company for entrepreneurs’ relief purposes, as it was preparing to carry on its old trade at least up to November 2012.   
 
Background 
 
The appellants (Mr and Mrs P) were the director shareholders of a company (G), which until 2009 was involved in the London Metal Exchange (LME). G’s business was to trade in the LME and to broker credit deals to provide the finance to enable clients to engage in high value trading at the LME. The deals were complex and could take months to negotiate. G’s clients were hedge funds, banks, and other institutions who wanted to buy and sell metals. 
 
G was a successful business and had built up reserves of over £1 million when the