Mutual club and corporation/capital gains tax

[Oldgrumpy]

A club that is treated by HRMC as a members club which generates a surplus not a profit and thus pays no tax on income.

Fallen on hard times, large debts, club buildings becoming unsafe due to lack of repairs & money.

Sells part of the club, stewards quarters, cellars and store room to developers and also has to demolish approx 1/4 of the club plus toilets to allow developers to build on the land.

Money received approx 600k, paying debts, rebuilding toilets and cellars ect and repairs to building approx 500k.

We believed that corporation/capital gains tax due on the surplus, 100k, but tax man wants it on the 600k (less taxable allowances)

Who is right? Is there a way to reduce tax bill? as if we don't Club will most probably fail.


Thanks.

[bd6759]

HMRC are correct. What you spend the proceeds on rarely affects the amount of the gain.