Hi Karen,
Just to clarify if the profitable expenditure (which was the subject of the valuation allowance) was incurred 20 years ago when the developer partnership was formed S14M(2) (d) states that the allowance is no longer applicable.
If the profitable expenditure was incurred less than 15 year ago and the issue is whether the current “owner” can be interpreted as the same “owner” when the profitable expenditure was incurred I agree with Robert. The current owner obviously has an interest now but also had an interest when the profitable expenditure was incurred – so s14M(2)(a) and s14M(2)(e) cannot prevent the allowance from being applicable.
Mick
