Effect of reduction in the entrepreneurs’ relief lifetime limit

The whirlwind of speculation surrounding the abolition of capital gains tax entrepreneurs’ relief finally came to an end when Chancellor of the Exchequer Rishi Sunak announced he was reducing the lifetime limit on qualifying gains from £10m to £1m.

Many entrepreneurs who plan to sell in the short term will be annoyed by this change but it will not be a surprise to the well advised.

The change was immediate and applies to disposals on or after 11 March 2020. There were no changes to the definitions of qualifying gains. Three anti-forestalling measures have been introduced to counteract attempts to bank the £10m lifetime limit before the change.

The Finance Bill 2020 was published on 18 March and it contained a surprise rebranding – entrepreneurs’ relief will now be called business asset disposal relief. For the purposes of this...