Home / Tax / Companies and corporation tax / Capital gains

Legal News

Entrepreneurs’ relief claim failed where trade not yet started (Wardle v HMRC)

Copyright © 2025 LexisNexis
Published on: 18 May 2021
Published by a LexisNexis Tax expert

Table of contents

  • Why it matters
  • Case details

Article summary

Tax analysis: In Wardle v HMRC, the First-tier Tax Tribunal (FTT) decided that entrepreneurs’ relief (now called business asset disposal relief) was not available to a partner in a partnership which had not yet commenced trading at the time of the disposal.

Powered by Lexis+®
Jurisdiction(s):
United Kingdom

Related documents:

3 Checklists
View More
4 News
View More
1 Practice notes
4 Q&As
View More
Powered by Lexis+®

Related documents:

3 Checklists
View More
4 News
View More
1 Practice notes
4 Q&As
View More

Popular documents

Taxation of derivatives—chargeable gains basis rules

Taxation of derivatives—chargeable gains basis rulesThe general rule, as explained in Practice Note: Taxation of derivatives—the main rules, is that the profits and losses arising to a company from its derivative contracts are (like the profits and losses from its loan relationships) brought into

When would preference shares fall under the shares as debt rules and hence the dividend payments would

When would preference shares fall under the shares as debt rules and hence the dividend payments would fall to be taxed as debt as opposed to qualifying for the corporation tax exemption for dividend payments?The ‘shares as debt’ rules applied to shares held by companies up until 21 April 2009 (for

Is there any guidance as to the appropriateness of defining ‘Control’ as either (a) in accordance with

Is there any guidance as to the appropriateness of defining ‘Control’ as either (a) in accordance with section 1124 of the Corporation Tax Act 2010, or as (b) the beneficial ownership of more than 50% of the issued share capital of a company or the legal power to direct or cause the direction of the

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of corporation tax on chargeable gains.Each company is a separate legal person for tax purposes meaning that, in the absence of a special rule, an