Entrepreneurs’ relief meaning

In this issue: Taxes management and litigation VAT Real estate taxes Oil and gas taxation Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Taxes management and litigation FTT upholds penalties for invalid BADR claims (Cox and another v HMRC) As outlined below, in Cox and another v HMRC [2024] UKFTT 510 (TC), the First-tier Tax Tribunal (FTT) rejected the taxpayers’ appeals against penalties arising from defective entrepreneurs’ relief claims, now termed business asset disposal relief (BADR). The FTT decided the claimants failed to exercise reasonable care when making the claims, and that HMRC’s choice not to suspend the penalties was not erroneous. See News Analysis: FTT upholds penalties for invalid BADR claims (Cox and another v HMRC). VAT FTT confirms dip pot formed part of single supply of takeaway food subject to VAT (Queenscourt Limited v HMRC) As previously noted in a Tax...

In this issue: Residential property Transferring property Easements, rights and covenants Property taxes Additional property updates this week Daily and weekly news alerts Trackers New Q&As Residential property Failure to serve claim notice did not invalidate transfer of right to manage The Supreme Court unanimously rejected the appeal in A1 Properties (Sunderland) Ltd v Tudor Studios RTM Company Ltd [2024] UKSC 27, confirming that Tudor Studios RTM Company Ltd (Tudor Studios RTM Company)’s omission to serve a claim notice on A1 Properties (Sunderland) Ltd (A1 Properties) did not undo the transfer of the right to manage. The issue for decision was the consequence of non-compliance with section 79(6)(a) of the Commonhold and Leasehold Reform Act 2002 (CLRA 2002), and whether such a failure necessarily invalidates the process. Court of Appeal authority indicates that not every failure to serve a claim notice defeats an RTM company’s acquisition of the right to manage the premises: Elim Court...

In this issue: Spring Statement 2025 Probate UK taxes for Private Client HMRC Manuals updates Tax avoidance, evasion and non-compliance Regulatory compliance for Private Client Contentious trusts and estates Art and heritage property, landed estates and farming families International Question of the week Daily and weekly news alerts LexTalk® Private Client: a Lexis+® community New and updated content Dates for your diary Trackers Latest Q&As Useful information Spring Statement 2025 Spring Statement 2025—key points On Wednesday 26 March 2025, the Chancellor of the Exchequer, Rachel Reeves, presented the government’s Spring Budget. There were no fresh measures for Private Client tax advisers—disappointing for those with clients likely to be affected by the planned reforms to business property relief and agricultural property relief from April 2026. Nor was there any sign of a rethink on the proposal to levy an IHT charge on pensions on death. By contrast,...

Successive UK governments have aimed to cement the UK as one of the world’s most appealing settings for innovation and enterprise. To that end, a wide-ranging suite of tax incentives has been rolled out to encourage innovative companies, supporting both investors and trading entities, and assisting businesses at every phase of a business’s life cycle. These incentives include: R&D tax reliefs patent box business asset disposal relief (previously entrepreneurs’ relief) capital allowances for purchases of: knowhow patents, and plant and machinery venture capital trusts the enterprise investment scheme, and the seed enterprise investment scheme This Practice Note outlines the UK position on key tax considerations when determining how to structure an innovative business with international or global aspirations. The observations are general in nature and work on the basis of a clean slate; revisiting an existing IP ownership arrangement will inevitably demand a bespoke solution (notably...

Before disposing of a business or trade When planning a disposal, a corporate seller must choose the most suitable deal structure. Commercial drivers should lead, yet securing a tax-efficient outcome will inevitably be a key concern. The initial choice is whether to transfer: the business and its underlying assets (a business sale), or the shares in a subsidiary that holds the business and assets (a share sale) Broadly, sellers tend to prefer a share sale: it offers a straightforward exit and, where the substantial shareholdings exemption (SSE) applies, any gain is exempt from tax. An asset deal is more likely to crystallise tax charges and leaves any pre-completion tax liabilities with the seller. This Practice Note does not address individual sellers or business asset disposal relief (BADR). For more on BADR, see Practice Note: CGT—business asset disposal relief (formerly entrepreneurs' relief)...

CGT reliefs most relevant to Private Client Multiple reliefs exist to lessen or defer capital gains tax (CGT) arising on the disposals of both business and personal interests...

On the life tenant’s death, an inheritance tax (IHT) liability would arise pursuant to section 49 of the Inheritance Tax Act 1984 (IHTA 1984), subject to any property that was eligible for relief at that time...