Commentary

D1.122 Investment holding companies and dealing companies

Corporate tax
Corporate tax | Commentary

D1.122 Investment holding companies and dealing companies

Corporate tax | Commentary

D1.122 Investment holding companies and dealing companies

The question sometimes arises as to whether there is any merit in establishing or maintaining the status of a property or investment company as either an investment holder (D7.301) or a dealer (D7.330)1.

There are a number of differences in the tax treatment of investment companies as compared with dealing companies in respect of their dealing investments; the principal differences are as follows:

  1.  

    (a)     profits realised by dealing companies on the sale of dealing assets are included in full in the profits chargeable to corporation tax, and were taken into account in determining the

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