29/09/2026
A taxpayer win!
The tax appeal decision is a welcome one because it helpfully recognises the commercial reality of property development.
But the case shows why business owners and advisers should keep clear evidence of any development work, directors’ involvement, spending and how any lettings fit into the wider plans.
It’s not merely enough to intend to develop a property - you’ll need to back this up with actions and clear records.
https://www.churchilltaxation.co.uk/former-company-directors-win-entrepreneurs-relief-case-against-hmrc/