Taite Moneybags and his business colleague Aramis Lotsamoney are residents of the UK for

tax purposes. They have approached you, as their tax advisor, with some questions about

starting a business. They have an interesting business concept involving land development

activities.

The two plan to set up a parent company, borrow money through the company structure,

and loan the money at a commercial rate to a 100% owned subsidiary company. Their initial

thoughts are the undertaking will encompass a 2 year planning phase, 5 years of business

subsidiary will buy and develop land for subdivision and sale.

period

The business model involves the sale of the subsidiary company by shares to the least

sale price after 2 – 3 years, refinancing the company’s existing loan if necessary. This plan

requires significant initial borrowings with associated expenses including interest

The business model involves the sale of the subsidiary early in the relevant financial year

after five years of operation.

3.

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