Entrepreneurs’ relief denied where company had meaningful non-trading activities.
In T Eyre and others v HMRC[2025] UKFTT 566 (TC)(22 May) the First-tier Tribunal (FTT) held that the appellants were not entitled to entrepreneurs’ relief on disposals of shares in a property company. Although the company was preparing to carry on a trade its activities during the relevant period included to a substantial extent non-trading activities. As such it was not a ‘trading company’ for the purposes of the relief.
The case concerned disposals of shares in Phoenix Spencer Sandbanks Ltd (PSSL) a company which had acquired a mixed-use property in Poole and was actively seeking planning permission for its redevelopment. The appellants who were directors and shareholders claimed entrepreneurs’ relief under TCGA 1992 Part 5 Chapter 3 asserting that the disposals were ‘qualifying business disposals’.
The FTT found that...
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Entrepreneurs’ relief denied where company had meaningful non-trading activities.
In T Eyre and others v HMRC[2025] UKFTT 566 (TC)(22 May) the First-tier Tribunal (FTT) held that the appellants were not entitled to entrepreneurs’ relief on disposals of shares in a property company. Although the company was preparing to carry on a trade its activities during the relevant period included to a substantial extent non-trading activities. As such it was not a ‘trading company’ for the purposes of the relief.
The case concerned disposals of shares in Phoenix Spencer Sandbanks Ltd (PSSL) a company which had acquired a mixed-use property in Poole and was actively seeking planning permission for its redevelopment. The appellants who were directors and shareholders claimed entrepreneurs’ relief under TCGA 1992 Part 5 Chapter 3 asserting that the disposals were ‘qualifying business disposals’.
The FTT found that...
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