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Known unknowns

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Shareholdings in joint ventures and their new entrepreneurs’ relief rules

KEY POINTS

  • FA 2015 removed some fixed rules that determined the treatment of a joint venture owned by a trading company or group for entrepreneurs’ relief purposes.
  • A summary of the old rules and conditions.
  • An example of the rules that apply from 18 March 2015 and how they might apply in practice.
  • The factors that might indicate the trading status of a company or group.
  • The importance of considering the commercial and other reasons behind the acquisition of an interest in a joint venture.

In the beginning the capital gains tax entrepreneurs’ relief legislation caused uncertainty for some shareholders. Now we have only to cope with specific known unknowns.

Arguably as explained below FA 2015 s 43(1) and s 43(2) have not made...

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