The simple question is when did trade commence.
A fishing boat is acquired, improvements and modifications are made to the boat, tests completed, licences obtained and crew engaged.
The first commercial voyage is undetaken, they reach fishing waters, cast the nets, suffer mechanical problems and do not land a catch and return to shore. The skipper decides that the nets and rigging need to be replced which takes approximately four months.
We have treated the trade as having commenced on the day of the first commercial voyage however HMRC contend that trade commenced when the first fish were landed and offered for sale.
Any thoughts?
Thank you.
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