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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
Edward Reed
Kazia Gagg
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
Edward Reed
Klara Kronbergs
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
Edward Reed
Clare Wilson
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
Edward Reed
Sophie Aitmehdi
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
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
When Ramsay does not rescue HMRC
Tax and the City for July 2026
BlueCrest: the impact for asset managers
HMRC v BlueCrest Capital Management (UK) LLP