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06 December 2011 / Kevin Slevin
Issue: 4333 / Categories: Comment & Analysis , Capital Gains

KEVIN SLEVIN wonders whether HMRC’s views of trading activities relating to the substantial shareholdings exemption will also apply to entrepreneurs’ relief


  • Revenue & Customs Brief 29/11 prompts another look at the definition of a trading company and trading group.
  • Similar definitions in substantial shareholdings exemption and entrepreneurs’ relief.
  • HMRC’s change of view may facilitate entrepreneurs’ relief claims.
  • Minority shareholdings may no longer be a bar to relief.
  • Why should the trading activities have to be similar?

This is an article about capital gains tax entrepreneurs’ relief as it can apply to gains realised on the disposal of shares and centres around the meaning of ‘trading company’ and ‘trading group’.

In fact I would like to begin with a disclaimer and say that the particular point of view expressed here as regards the meaning of those phrases is not necessarily mine.

Indeed although I spend many hours of each...

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