Thomson v HMRC

In C Thomson v HMRC [2021] UKFTT 453 (TC) (6 December 2021) the First-tier Tribunal (FTT) decided that entrepreneurs’ relief (now business asset disposal relief) applied to the disposal by a partner in an accountancy firm of its business premises. Even though the disposal of a single asset would not normally qualify for entrepreneurs’ relief on the facts of this case the disposal of partnership premises was part of a wider disposal to enable the taxpayer to exit the business notwithstanding that the wider disposal had been going on for 22 years.

There was no dispute about the circumstances of the disposal. The taxpayer had been one of two partners in the firm since 1970. In 1996 he started to consider retirement and succession. He identified two accountants working in the practice (the ‘new partners’) as suitable successors and made an unwritten agreement with them. Under...

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