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How has entrepreneurs’ relief been eroded and what opportunities remain?

Entrepreneurs’ relief remains an attainable and valuable relief, as long as shareholders get the basics right. Andrew Marr and Michelle Hogan (Forbes Dawson) present a review of the relief in the context of recent legislative changes and the latest case law. 
 
It would be no exaggeration to say that entrepreneurs’ relief (ER) has been the most valuable tax relief in recent times. When it was first introduced in 2008 it allowed a special rate of 10% on the first £1m of qualifying gains. This was increased in various stages to a lifetime allowance of £10m effective from 6 April 2011. Given that it is relatively easy for married couples to effectively share qualifying gains they can often enjoy £20m of gains at the low 10% rate. This capital gains tax generosity has taken place against a backdrop of generally rising income tax rates and (until...

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