Finance Bill 2020 ― what’s new?

By Tolley
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The following Owner-Managed Businesses guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Finance Bill 2020 ― what’s new?
  • Legislative changes
  • Consultations

The Finance Bill 2020 was published on 19 March 2020, consisting of 105 clauses and 14 schedules, running to 176 pages. The Bill includes a number of measures for which legislation was published in draft on 11 July 2019 and at the Budget on 11 March 2020. Much of the content comes as no surprise to us all, although there were one or two small surprises and additional detail, all of which is mentioned below.

Current expectation is that the Bill will be given Royal Assent in July, but in this fast-changing environment, a delay to the Autumn cannot be ruled out.

Alongside the publication of the Finance Bill, a number of consultations were opened and several policy and other related documents were issued on Making Tax Digital (MTD), and these too are mentioned below.

Legislative changes
Entrepreneurs’ relief

Perhaps the only big surprise in the Bill itself is what has happened to entrepreneurs’ relief.

When the Government announced the reduction in the lifetime limit for entrepreneurs’ relief from £10m to £1m for all disposals on or after 11 March 2020, the draft legislation issued on Budget day also included anti-forestalling legislation where arrangements had already been put in place in anticipation of any changes to entrepreneurs’ relief. This included share for share reorganisations made on or after 6 April 2019, under TCGA 1992, s 135, where an election could be made to trigger a gain to attract entrepreneurs’ relief at the date of the share exchange in the hope of maintaining relief under the old rules. The anti-forestalling rules mean that the disposal of the original shares is treated as taking place at the date of the election a

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