According to a recent tribunal decision, the qualifying beneficiary test entrepreneurs' relief need only be met at the time of a disposal of settlement business assets. Sam Brodsky (Gray's Inn Tax Chambers) reports.
The case of Quentin Skinner 2005 Settlement L and others v HMRC [2019] UKFTT 516 (TC) the First-tier tribunal decided that beneficiaries under settlements were entitled to entrepreneurs’ relief (ER) on the disposal of shares by the settlements even though the settlements had held the shares for less than a year.
In that case there were three settlements and three beneficiaries. In July 2015 each beneficiary was given an interest in possession in one of the settlements. The beneficiaries already held shares in a company and their holding was sufficient to make that company a ‘personal company’ in respect of each of them. The holding...
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According to a recent tribunal decision, the qualifying beneficiary test entrepreneurs' relief need only be met at the time of a disposal of settlement business assets. Sam Brodsky (Gray's Inn Tax Chambers) reports.
The case of Quentin Skinner 2005 Settlement L and others v HMRC [2019] UKFTT 516 (TC) the First-tier tribunal decided that beneficiaries under settlements were entitled to entrepreneurs’ relief (ER) on the disposal of shares by the settlements even though the settlements had held the shares for less than a year.
In that case there were three settlements and three beneficiaries. In July 2015 each beneficiary was given an interest in possession in one of the settlements. The beneficiaries already held shares in a company and their holding was sufficient to make that company a ‘personal company’ in respect of each of them. The holding...
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:
