In the recent case of Hopscotch Ltd v HM Revenue [2020], the redevelopment of residential property was not considered to be part of a property development trade for ATED purposes. The Upper Tribunal has dismissed the taxpayers appeal. The First Tier Tribunal looked at the evidence to support the commencement of property trading activity for a property previously held as an investment and concluded there was insufficient evidence to support the argument that the redevelopment of residential property was part of a property development trade for ATED purposes.
Justine Howard
Associate Director, Tax
KPMG Crown Dependencies
+44 1624 681000 Justine
Howard
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