Early trade losses relief

pierce-uk

Free Member
Mar 4, 2019
5
0
Hi there,

I was employed full-time until September 2018 when I left to set up my own business as a minibus operator. I am now getting close to actually launching something. One of my first moves will be to make a significant capital investment in vehicles (around £200k) and I'm trying to figure out the most beneficial way to do that from a tax perspective. Here's my understanding so far:

- I believe I should be able to claim the annual investment allowance on the vehicles (to clarify, they are vans that I'll convert to minibuses, rather than cars, so I think they are included) which means I can deduct the full amount of the investment against profits in my first year

- This will result in my business making a signficant loss in Year 1 for tax purposes (since the vehicles will last many years). If I register as a sole trader, I believe I can offset this loss against my previous income when I was employed under "early trade losses relief". Most of my previous income for the past few years was at the 40% tax rate so as I understand it I would effectively get back 40% of whatever I was able to offset against previous income

My questions are:

1) Does the above seem correct? I will get formal advice from an accountant before committing to anything but just want to sense check for now

2) I understand that there is a £50,000 cap on loss relief in any one year. However, I am not clear whether the cap applies to (A) the year in which you make the loss or (B) the year you are offsetting against. This makes a difference for early trade losses relief where you can offset losses against three previous years. To be more concrete, I'm asking which of the following scenarios is correct:

Scenario A: I make a £200k loss in the 2018/19 tax year. I offset this against previous income using early trade losses relief, starting with the 2015/16 tax year (three years prior). My taxable income in that year was £120k but I am capped at offsetting £50k of the loss. This reduces my taxable income in the 2015/16 year to £70k and I get a refund of 40% on the £50k reduction (i.e. £20k). The cap applies to the amount of loss I can offset from my 2018/19 profits so I can't do any further offsetting and the remaining £150k of the loss is kept in the business (where it could be used to offset against future profits).

Scenario B: As before, I make a £200k loss in the 2018/19 tax year which I offset using early trade losses relief. I start with the 2015/16 tax year and offset the maximum of £50k against my £120k income, giving me a £20k rebate. The cap applies to the amount of this loss I can offset against income in the 2015/16 year but I can then continue to offset a further £50k against my income in 2016/17 tax year (say another £20k rebate) and a further £50k against my income in 2017/18 tax year (another £20k rebate). The final £50k of the loss is kept in the business (where it could be used to offset against future profits). Overall, I have offset £150k against previous income for a £60k rebate.

3) As I understand it, I can only get this early trade losses relief if I am registered as a sole trader. Given the scale of the benefit, it seems worth starting as a sole trader rather than a limited company for this reason. However, ultimately I would prefer to end up as a limited company (for various reasons, including issuing shares in future). Could I change from a sole trader to a limited company after having claimed loss relief or would HMRC have a problem with that? For instance, would it fall foul of their rule that the business must have been intending to make a profit, given that the sole trader would only ever have made a loss, or would they recognise that the limited company was just a change in the legal structure and the business had continued?

I apologise for this post being fairly long and technical but would appreciate any advice. Please let me know if you need any clarification.

Thanks,

Pierce
 
Sep 18, 2013
6,699
3
1,553
Colchester
I have just done the above for a sole trader who left his job to set up a camper hire business - bought 3 camper vans to start (on finance) and I did the carry back loss claims & capital allowance computations.

You also need to consider whether to register for VAT so that you claim the VAT back you are likely to pay on the vans & conversion costs.
 
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MJ Holohan

Free Member
Dec 27, 2018
53
10
London
Are you using your own money to invest in the business? Would it not be better to incorporate a limited company. You may be able to avail of the Enterprise Investment Scheme which can be carried back 2 years and then keep your capital allowances and deduct over time.
 
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pierce-uk

Free Member
Mar 4, 2019
5
0
Yes, I am planning on using my own money in the first instance but once the business is up and running I’d hope to raise further capital from external investors to fund growth.

My thinking about starting as a sole trader, then going limited is:

- As a sole trader, I’ll be able to get a lot of tax relief using Early Trade Losses Relief. This would not be available to a limited company

- If I immediately registered as a limited company, I would not be able to get EIS on my own investment in the company because I am connected to the company (as an employee and director)

- If I start as a sole trader, then switch to a limited company EIS (and SEIS) would still be available at a later stage when I was looking to raise finance externally
 
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pierce-uk

Free Member
Mar 4, 2019
5
0
Of course. However, I said that I was happy to pay them so that wasn’t the issue.

Instead, the person who was dealing with me was clearly not particularly qualified and rather than doing something like offering to set up a (paid) appointment with someone more qualified, they just told me that I should register as a limited company based on my expected revenue with no consideration of the more detail questions.

The other accountancy firm I reached out to never got back to me. Again, I had made it clear that I was happy to pay for the advice.

I’m not saying all accountancy firms will be similar and no doubt I just need to look harder to find someone I can trust.

I’m just countering any notion that I’m not willing to pay for quality advice and have just asked the question here to save money.
 
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MJ Holohan

Free Member
Dec 27, 2018
53
10
London
Yes, I am planning on using my own money in the first instance but once the business is up and running I’d hope to raise further capital from external investors to fund growth.

My thinking about starting as a sole trader, then going limited is:

- As a sole trader, I’ll be able to get a lot of tax relief using Early Trade Losses Relief. This would not be available to a limited company

- If I immediately registered as a limited company, I would not be able to get EIS on my own investment in the company because I am connected to the company (as an employee and director)

- If I start as a sole trader, then switch to a limited company EIS (and SEIS) would still be available at a later stage when I was looking to raise finance externally

This is quite complicated and I would need to look at in more detail but I still think you might be better to incorporate sooner. You would likely be able to avail of EIS now as an unpaid director if you invest cash in the business.

This in addition to the investment allowance you would receive through the business would result in greater savings.

Please get in touch through my website below if you would like to discuss further.
 
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