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S Reneaux and another v HMRC

In S Reneaux and another v HMRC [2019] UKFTT 666 (5 November) the FTT found that the disposal of commercial premises did not qualify for entrepreneurs’ relief in circumstances where they were no longer used for the purpose of the appellant’s trade at the time of disposal (TCGA 1992 s 169 et seq.).

Mr Reneaux worked as a self-employed freelance MOT tester and vehicle mechanic. Mrs Reneaux-Smith worked as a hairdresser and was also employed in Mr Reneaux’s business dealing with the administration and accounts. They had each acquired 50% of two units within a commercial development. 

Mr Reneaux had first traded at the premises and then sold his business to an individual who had leased the premises from him for a time. Mr Reneaux had continued to work as a freelance MOT tester working at customer locations. 

After the initial release the premises had...

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