CG17953g - Taper relief: trading company and holding company of a trading group - periods before 17 April 2002 - meaning of "capable of having no substantial effect"


In the case of trading companies the question is whether non-trading purposes are 'capable' of having no substantial effect. This requires an objective assessment at any point in time as to whether it can be shown that this is the case rather than that it is theoretically possible. The meaning of substantial is discussed at CG17953p