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?
- Dispensing with accounting periods, with nested ledgers. 245 7
- cancellation of Engagement 230 4
- Foreign branch in SME 112 1
- How much did you pay for your website 1,250 22
- Fastest Software 675 11
- Self Employed Self Assessment: Capital Allowance and Car Lease/HP 137 1
- Where did it go? 299 2
- Seed Enterprise Investment Scheme Charges 96 1
- Feuding directors 299 8
- VAT Registration for Building Company 116 2
- FILING COMPANY ACCOUNTS 511 12
- Vat threshold issues 1,914 14
- Company Accounts - Limited company 615 5
- Use of Home for Sole Trader 256 4
- Vodaphone Share Scheme 115 1
- Benefit fraud 3,437 49
- SA Tax Returns 177 3
- Agent Change of Postal Address 172 2
- Consolidated accounts 144 2
- On line petition re HMRC grabbing money from taxpayer bank accounts 1,033 24
- CTA study material 653
- Anyone have clients that use Pay4Later to offer customers credit? 396
- Employment related securities question 249
- ATED Penalties 222
- AIM Stocks and IHT 204
- Tax Relief for overseas employees 174
- Trust for Employee 159
- Expat pension contributions? 152
- Staff accommodation without a rental value or RV 136
- Capital allowances 128