Entrepreneurs’ relief is meant to encourage the owners of successful companies. But owners who raise extra funds to grow their businesses can find that doing so means that they lose their entitlement to relief. The draft bill includes measure to alleviate this problem, but they only come into effect on 6 April next year so business owners need to take great care in the timing of any new fundraising.
Andrew Goldstone and Jeffrey Lee (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in McQuillan, X-Wind Power, Mabbutt and Shah.
Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.