Entrepreneurs relief anomoly?
I have read that there were no changes to the entrepreneurs relief in the emergency budget. Great what a relief as there is a deal on the table for a Client which is now unchanged.
However, since I have then read that where loan notes are taken for part or all of the consideration then the cashing in of these would not be eligible to the ER and would be charged at 18/28%.
So if my client sold the shares now for say £1.1m and received 1/3 now with the rest as loans payable in 2 further instalments would this be caught?
I was of the understanding that we would calculate the full gain and capital gains tax due on the first instalment and the loans for the further 2 would just be repaying the loans given. They would not be negotiable instruments just almost Directors loan accounts I guess.......