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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Entrepreneurs’ Relief: trading company and holding company of a trading group - surplus trading property

A company may own a property which is surplus to its immediate business requirements. You should not, for example, regard the following as necessarily indicating a non-trading activity:

  • letting part of the trading premises;
  • letting properties that are no longer required for the purpose of the trade in question, where the company’s, or group’s objective is to sell those properties;
  • sub-letting property where it would be impractical or uneconomic in terms of the trade to assign or surrender the lease. For example, the benefit derived from disposing of the lease may be outweighed by the reverse premium payable;
  • the acquisition of property (whether vacant or already let) where it can be shown that the intention is that it will be brought into use for trading activities.