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21 April 2020
The effect of losses and gains on the entrepreneurs’ relief lifetime limit.
In 2011-12 our client incurred a capital loss of £250 000 on the disposal of a quoted shareholding which was a non-business asset. In 2015-16 the client had a capital gain of £500 000 which qualified for entrepreneurs’ relief. In 2017-18 there was a further gain which also qualified for entrepreneurs’ relief of £500 000.
Following the March Budget we are wondering how much of the entrepreneurs’ relief lifetime limit is now remaining. In our mind the possibilities are:
- nil – being the £1m limit less the two £500 000 gains;
- £250 000 – the £1m limit less net gains of £250 000 for 2015-16 and £500 000 for 2017-18; or
- £272 300 – as above plus the annual exemptions for 2015-16 and 2017-18.
The legislation at TCGA 1992 s 169N(4)(b)(i) talks about gains being ‘charged at the rate’...
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