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Throwing more light on BADR
Key points
- Tenconi and Wardle are two recent appeals to the First-tier Tribunal concerning entrepreneurs’ relief now business assets disposals relief (BADR).
- Despite the failure by the taxpayer the Tenconi case highlights one issue which can be of importance and that tax practitioners should note.
- In Wardle the point in issue was whether the activities of a partnership met the definition in TCGA 1992 s 169S(1).
- The Wardle decision highlights one of the advantages of operating a business through a limited company when it comes to claiming BADR.
There have been two recent case reports of appeals to the First-tier Tribunal concerning claims to entrepreneurs’ relief. These are Tenconi (TC8088) and Wardle (TC8105). While it has to be said these cases reveal nothing new they do highlight interesting points for busy practitioners. This article focuses on two points of interest – matters which might...
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