The availability of entrepreneurs’ relief, and the timing of gains need to be reviewed whenever there is a share reorganisation or a sale of shares in exchange for shares or loan notes in the acquiring company. The reorganisation provisions can be disapplied where ER could otherwise be lost, but the cashflow implications must not be overlooked. There are complex transitional rules dealing with loan notes and EIS shares acquired before 6 April 2008 and redeemed or sold in part before 23 June 2010.
