This week's opinion

Articles on entrepreneurs’ relief are always popular with our readers. This is hardly surprising. Most firms will have clients who could qualify. The relief can deliver life-changing tax savings but as we all know it contains many elephant traps that can result in relief being denied in cases that seem on the surface to meet the conditions. Remember the McQuillan case (discussed by Robert King in ‘Much ado about nothing’  Taxation 8 November 2017) in which the conversion of a loan into shares resulted in entitlement to relief being lost. It is positive that the government recognises that the existing rules can create unfair results and I welcome the publication of the consultative document on the impact that dilution has on entrepreneurs’ relief.

The proposals will allow individuals to ‘lock in’ their entrepreneurs’ relief at the point of dilution so that it is not lost with the...