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M Stolkin v HMRC

In M Stolkin v HMRC (TC01667 – 10 January) an individual (S) disposed of several properties some of which had been used for business purposes some of which had been used partly for business purposes and some of which had not been used for business purposes. He claimed EIS deferral relief under TCGA 1992 Sch 5B and taper relief under TCGA 1992 s 2A(5) and claimed that the EIS relief should be set firstly against the gains on the non-business properties and secondly against the non-business parts of the ‘mixed use’ properties. HMRC accepted that the relief could be set firstly against the gains on the properties that had never been used for business purposes but issued a ruling that where a property had been used for both business and non-business purposes the EIS relief had to be treated as...

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