Nick Wright explores the critical 'business' requirement for tax-efficient property portfolio incorporation, examining when rental activities qualify as genuine business rather than passive investment.
The ability to transfer a property portfolio to a company in a tax-efficient manner hinges on whether the activities constitute a 'business' rather than mere investment activity.
This is important for capital gains tax (CGT) purposes as incorporation relief requires the transfer of a ‘business’. A business is also a fundamental principle in establishing a partnership for the purpose of partnership law. Provided a partnership,
