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Another year
KEY POINTS
- From 6 April 2019 the period throughout which the qualifying conditions for entrepreneurs’ relief must be satisfied is increased to two years.
- The importance of understanding when a business started.
- A new provision will enable a pre-incorporation period to be taken into account when considering share ownership.
- The new rules do not formally encompass share reorganisations so advisers and their clients must rely on HMRC’s interpretation.
- A two-year period of uncertianty after incorporation.
- An election may be made under TCGA 1992 s 169Q to disapply s 127 thereby triggering a taxable disposal for capital gains tax purposes.
From a policy standpoint I can...
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