entrepreneurs relief - one year rule
My client has traded as an electrician for a number of years. He incorporated the business in November 2009 (he owned 100%) and then sold 25% of the shares in May 2010 to a third party. Can he claim entrepreneur's relief? I am concerned about the one year rule. Can you amalgamate the ownership as a sole trader and as a shareholder. I know that he could claim the relief at the point that he incorporated as opposed to claiming incorporation relief but he doesn't want to do this. I have looked at the HMRC guidance but can't see that it addresses the point specifically. Any help gratefully received.


Elect to disapply or take the hit!