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Entrepreneurs' relief
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Entrepreneurs' relief
ENTREPRENEURS-RELIEF
Eyre and others v HMRC
Entrepreneurs’ relief denied where company had meaningful non-trading activities.
Private client review for July 2024
Kazia Gagg
Edward Reed
Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for
private clients under the new Labour government and comment on a number
of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.
J Wardle v HMRC
Entrepreneurs’ relief claim allowed.
Private client review for May 2024
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases
concerning entrepreneurs’ relief, PPR and SDLT.
J Cooke v HMRC
ER claim succeeded despite shareholding of less than 5%.
Are trusts an appropriate vehicle to hold shares in a family business?
Hayden Bailey
Hayden Bailey (Boodle Hatfield) considers the use of trusts as part of an ownership strategy for family businesses to enable succession planning.
M Stolkin and others v HMRC
Company was not trading so entrepreneurs’ relief not available.
Private client review for February 2024
Clare Wilson
Edward Reed
Tensions between transparency and privacy and some recent tribunal
decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
Private client review for July 2022
Sophie Aitmehdi
Edward Reed
Edward Reed and Sophie Aitmehdi (Macfarlanes) report on several of the most interesting recent tribunal decisions in the private client sphere.
Kavanagh v HMRC
Entrepreneurs relief: the 5% test
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6
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress