Part 1 Reduction in Lifetime Limit

SCHEDULE 3 Entrepreneurs' Relief

Section 23

Part 1 Reduction in Lifetime Limit

Reduction in lifetime limit

1

In section 169N of TCGA 1992 (entrepreneurs' relief: amount of relief)—

(a)     in subsection (4), for “£10 million” substitute “£1 million”;

(b)     in subsection (4A), for “£10 million” substitute “£1 million”.

Commencement

2

The amendments made by paragraph 1 have effect in relation to disposals made on or after 11 March 2020.

Anti-forestalling: unconditional contracts

3

(1)     This paragraph applies where an asset is conveyed or transferred on or after 11 March 2020 under a contract made before that date that is not conditional.

(2)     Despite section 28(1) of TCGA 1992 (disposal under unconditional contract made at time of contract and not at time of later conveyance or transfer), the disposal is to be treated for the purposes of paragraph 2 as taking place at the time the asset is conveyed or transferred, and not at the time the contract is made, unless the condition in sub-paragraph (3) or (4) is met.

(3)     The condition in this sub-paragraph is that—

(a)     the parties to the contract are not connected persons,

(b)     no purpose of entering

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