FTT denies entrepreneurs’ relief where company’s activities included substantial investment elements despite redevelopment intentions (Eyre and others v HMRC)
Tax analysis: In Eyre and others v HMRC, the First-tier Tax Tribunal (FTT) held that the appellants were not entitled to entrepreneurs’ relief on disposals of shares in a property company. Although the company was preparing to carry on a trade, its activities during the relevant period included, to a substantial extent, non-trading activities. As such, it was not a ‘trading company’ for the purposes of the relief.