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Entrepreneurs’ relief: Hammond’s disappearing trick

Ceinwen Rees and Alex Ereira (Macfarlanes) explain why practitioners will need to review advice given to clients who are expecting to benefit from entrepreneurs’ relief.
 

The 2006 cult classic film The Prestige opens with a voiceover from Michael Caine in his iconic cockney accent setting out the three-part anatomy of a magic trick. It seems that Philip Hammond has taken that lesson to heart with his recent changes to entrepreneurs’ relief that like the escalating theatrics of the film may have worrying implications for his audience.

The pledge

‘The first part is called “The Pledge”. The magician shows you something ordinary: a deck of cards a bird or a man.’

Entrepreneurs’ relief has long offered UK taxpayers the opportunity to reduce their capital gains tax liability on qualifying disposals of shares. Provided the conditions for the relief are satisfied entrepreneurs pay capital...

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