Although the reduction in the entrepreneurs’ relief lifetime limit from £10m to £1m was a straightforward change, detailed anti-forestalling rules in the Finance Bill mean that planning undertaken in anticipation of this will need to be carefully considered. Individuals who undertook sales to crystallise gains, or share exchanges to enable elections under s 169Q to be made, may be affected by these rules.
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Although the reduction in the entrepreneurs’ relief lifetime limit from £10m to £1m was a straightforward change, detailed anti-forestalling rules in the Finance Bill mean that planning undertaken in anticipation of this will need to be carefully considered. Individuals who undertook sales to crystallise gains, or share exchanges to enable elections under s 169Q to be made, may be affected by these rules.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: