Property Companies--I

Carmichael, K.S.
March 1969
Accountancy;Mar1969, Vol. 80 Issue 907, p200
Trade Publication
This article looks at several taxation provisions and its role in determining the tax position of a property company in Great Britain. A property company is defined as a company the principal activity of which is ownership of land either for the purposes of re-sale or to earn an income. Companies owning woodlands will not be considered. For reasons which will become clearer as the series progresses, a vital factor in determining the tax position of a property company is whether the company is an investment company or whether it is a trading or dealing company. In other cases, the facts may not determine at a glance the category or the shareholders may be anxious to show that the company is in a particular category. In the case of all property companies, therefore, before giving any tax advice, an accountant should consider several factors. If it sought to show the company is an investment company, the Memorandum should in its objects state the object of the company is to purchase or build houses. For the purposes of investment only, it should not contain any clause allowing the company to be builders or contractors. Obviously there may be cases where temporary finance is arranged which is subsequently repaid with the aid of a long-term mortgage.


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