Business investment relief Flashcards
What is business investment relief
BIR permits non UK domiciled individuals to remit funds to the UK for qualifying investment purposes without creating a taxable remittance
What are qualifying investments
An acquisition of shares or securities in a non listed target company. Can either be a subscription of purchase of existing shares
A loan to a target company
The target company must be a trading company or a company which makes investment in trading companies
The company qualifies if it either:
Carry’s on a commercial trade (at least 80% of its activities are trading activities
Will trade within 5 years
Two misc points
Trading includes businesses which generate income from land for example companies who hold investment property for commercial renal purposes
Does not matter if related purposes is connect to the company.
What is the time limit for the investment
The money must be invested within 45 days from the date it is remitted into the UK. I the funds are removed within the 45 day period then no remittance is deemed to take place.
What is one of the key restrictions
Business investement relief is not available of the investor has obtained an abnormal benefit as a result of making the investement
