A company was held not to be a property developer for the purposes of annual tax on enveloped dwellings (ATED). Property developers enjoy relief from the tax under Finance Act 2013 s138(1).
A company acquired a residential property which it eventually improved and offered for sale.
On the facts of the case, the company was not running a property development trade. It was simply selling an investment property.
The case considered the badges of trade.
The case report can be downloaded from here.
Hopscotch Ltd  TC 7127 [19.05]