CGT instalments and ER
Taxpayer has a £3m gain on sale of shares, qualifying for Entrepreneurs relief.
£2m paid immediately , £1m over two instalments at + 12 months and + 24 months.
Consideration is ascertainable.
Q - is there any Entrepreneurs relief restriction if an election under TCGA S280 to pay by instalments is made.
My colleague thought there was, but my research today can't find anything confirming this.
My colleague may be thinking of a Marren v Ingles unascertainable situation though, where loss of ER on the deferred earn out right is a known issue.
My conclusion is that for a straightforward payment by instalment arrangement, ER isn't compromised by TCGA S280 claim to pay by instalments.
Any quick thoughts from the floor?
- Rogue Accountant 2,822 46
- Getting fees, getting harder? 3,535 71
- P60 from HMRC Basic Paye Tools 5,283 19
- HMRC Scam 243 2
- Departments in Sage 50 86 1
- Where has Portia gone? 682 25
- Is it worth being a limited company if already a higher rate taxpayer? 214 2
- HMRC, YouTube, ITTOIA... 319 4
- Capital Gains? 257 2
- Associated disposals - Entrepreneur's relief 103 1
- Partial Exemption relating to a multi academy trust 73 1
- Is it possible to have an excel link to a different dated excel file 448 9
- Taxation of serviced offices 127 2
- AIA - new period 220 1
- Self assessment question 1,160 48
- Major Works Invoice to Rental Property 376 9
- What is the base cost of this asset for CGT? 265 3
- New Client wants an Income Certificate for a Mortgage 856 20
- Dividend Tax Rate 442 8
- Ex Wives Club 547 13
- Services via intermediaries and new HMRC reporting requirements 773
- RTI - duplicate employee record 509
- Pensions Regulator 438
- How hard is it to reduce a code? 394
- Sanzar 296
- Sage Vat return box 2 296
- Digital marketing focus group 277
- How do you do it 264
- Report old income 227
- Kashflow balance sheet difference 226