Although the reduction in the entrepreneurs’ relief lifetime limit from £10m to £1m was a straightforward change, detailed anti-forestalling rules in the Finance Bill mean that planning undertaken in anticipation of this will need to be carefully considered. Individuals who undertook sales to crystallise gains, or share exchanges to enable elections under s 169Q to be made, may be affected by these rules.
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Although the reduction in the entrepreneurs’ relief lifetime limit from £10m to £1m was a straightforward change, detailed anti-forestalling rules in the Finance Bill mean that planning undertaken in anticipation of this will need to be carefully considered. Individuals who undertook sales to crystallise gains, or share exchanges to enable elections under s 169Q to be made, may be affected by these rules.
If you are not a subscriber, subscribe now to read this content.