by PJC1308 on Wed Nov 02, 2011 12:05 pm
I have a client company that has spent £50,000 on it’s website and is looking to sell this website to a SIPP for £200,000 (valuation may be an issue!)
The question I have is whether the ‘gain’ in the company is assessed as a trading receipt (under the intangibles regime) or as a capital gain (under the tangible rules).
I know that for UK GAAP purposes this is treated as a tangible asset under FRS 15.
I have been advised that the client has a choice in how this is treated for tax purposes – is this correct?
It is fairly key as the company has brought forward losses which could be utilised against an income profit – could HMRC argue this is a different trade?