Entrepreneurs Relief

Entrepreneurs Relief

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My clients is a limited company.  The sole shareholders and directors are husband and wife, the shareholdings being held 50/50

The factory from which the company trades is owned by the husband and wife and they are now in the process of selling the factory, although the business will be ongoing.

Without any action, it seems that ER will not apply so CGT will be at 18/28%.  However I think I am right that the disposal associated with relevant material disposal rules are satisfied where the disposal of a business asset used by a company is associated with a disposal of business shares.

Therefore if husband and wife could each say sell or gift 1% of their shareholdings, at the time the factory is sold, am I right in thinking that ER could apply.  The remaining shares, say 49 each would continue to be held by husband and wife.

The company's balance sheet is overdrawn by around £250K and the business is not currently profitable so I can't imagine there would be any value to the shares therefore no additional capital gains from that disposal.

Does this all seem reasonable.

Many thanks for any thoughts

Replies (46)

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Nichola Ross Martin
By Nichola Ross Martin
24th Nov 2014 16:08

Condition B s169k?

but sounds like a greater planning exercise given the state of the balance sheet. Happy to help but no time to give freebies today.

 

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Portia profile image
By Portia Nina Levin
25th Nov 2014 11:02

Yes

HMRC accept that a sale of any shares is a (partial) withdrawal from participation in the business such that condition B in section 169K is satisfied.

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By HeavyMetalMike
25th Nov 2014 11:45

am I missing something? how can there be an assoc disposal without a material disposal of shares? 1% disposed will surely not qualify as a material disposal?

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Nichola Ross Martin
By Nichola Ross Martin
25th Nov 2014 11:47

Hmm

well the legislation says "as part of the withdrawal of the individual from participation in the business..." which to my understanding is not the same as saying "part of the partial withdrawal from participation". I would have thought that the draftsman would have said "partial" or something like it if that was the intention. 

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Portia profile image
By Portia Nina Levin
25th Nov 2014 11:57

Material disposal

All the legislation requires that there is a disposal of shares in a company that throughout the period of one year preceding the disposal:

was the individual's personal company and was a trading company (or holding company of a trading group), andthe individual was an officer or employee of the company.

A personal company is then one in which the individual holds at least 5%.

So individual has 50 shares (being 50%) for the one year period and disposes of 1 share at the end of it, you have a material disposal as defined in the legislation (assuming it is trading, and individual is an offcer/employee, etc.).

See CG63975 and CG63995:http://www.hmrc.gov.uk/manuals/cgmanual/CG63975.htm and http://www.hmrc.gov.uk/manuals/cgmanual/CG63995.htm

All you need to do is make sure that the sale of the factory is made as part of the withdrawal from the business (by the sale of shares). That is where it gets tricky

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Portia profile image
By Portia Nina Levin
25th Nov 2014 12:01

@ Nichola

Having less of an interest than I did yesterday, means that I have withdrawn from participation to the extent of the reduction.

If the parliamentary draftsmen had meant that the individual should withdraw from participation completely, or to a significant or substantial extent, then he would have said so.

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By michaelblake
25th Nov 2014 12:25

The disposal of one share is enough as Portia notes

As Portia notes the disposal of one share is sufficient and this was confirmed by HMRC in January 2012 - see the ICAEW Taxguide 1/12 at 

http://www.ion.icaew.com/TaxFaculty/23872

 

 

 

 

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Nichola Ross Martin
By Nichola Ross Martin
25th Nov 2014 14:47

@ Portia

but I am looking at s169K(3) - Condition B and I think from your comments that you are just looking at either Condition A in isolation or maybe the rule in s169I.

Please confirm?

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Portia profile image
By Portia Nina Levin
25th Nov 2014 15:14

I am referring to condition B

The point is that the sale of any shares is a withdrawal from participation.

If I have £100 in the bank and take £1 out, then that is a withdrawal.

As I have said (11:57), the important thing though is whether the sale of the factory is made as part of that withdrawal. See CG63995 (2nd para after the heading withdrawal from business) which makes it clear there needs only be a reduction in a person's interest.

http://www.hmrc.gov.uk/manuals/cgmanual/CG63995.htm

See also this from Taxation, where "Simples" (not me!) elaborates on some of the points from CG63995.

http://www.taxation.co.uk/taxation/Articles/2013/06/12/308891/three-way-...

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By michaelblake
25th Nov 2014 15:43

See Example C1 and paragraphs 95 to 98 of Taxguide 1/12

Nicola 

HMRC's take on these issues is addressed in Example C1 at paragraphs 95 to 98 of the ICAEW Taxguide and as Portia notes in the HMRC guidance at CG63995 and is guided by the principles discussed in the retirement relief case of Clarke v Mayo.

In practical terms if the share transfer forming the material disposal and the asset disposal forming the disposal associated with the material disposal take place on the same day (which I would have thought was always possible) there should be no difficulty.  

 

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Replying to DJKL:
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By HeavyMetalMike
25th Nov 2014 16:04

In practical terms the assoc disposal must be after, or not before, the share disposal. If you insist that 1% is a material disposal.

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Nichola Ross Martin
By Nichola Ross Martin
25th Nov 2014 16:43

That still doesn't sound like the requirement is met

I apprecate your arguments Portia and Michael but I beg to differ here - my approach is answered in para 102 of the ICAEW guide there needs to be a withdrawal from participation. Sure you can sell just one share, sure you can work the same hours - but you have in my mind, and  clearly HMRC's * to have something more than those to make a withdrawal from the business of the company. A loss of a 2% interest in a company that you already control by virtue of your wife's shareholding does not seem to provide the withdrawl and the OP gives no other clues on this point.

There are various articles on this here's another one http://www.taxation.co.uk/taxation/Articles/2012/02/29/286441/stress-relief

in Clarke v Mayo at least there was a retirement.

* assuming no change of view on HMRC's part since the comments in the ICAEW/CIOT guides.

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Portia profile image
By Portia Nina Levin
25th Nov 2014 17:09

Er

The article referred to says (under the required level of reduction heading, which discusses condition B):

"Is there a de minimis level in relation to a part-disposal of shares below which HMRC will seek to argue that the shareholding disposed of is not sufficient to satisfy the associated disposal provision?

The answer is that, in the absence of a provision in the legislation specifying a minimum percentage of shares which must be disposed of, HMRC will accept any level of reduction in the holding of shares or securities."

The point is that section 169K refers to the withdrawal from participation (rather than a withdrawal), as if we already know what withdrawal from participation it is talking about, having only previously referred to a material disposal.

So it must be that "the material disposal" and "the withdrawal from participation" were one and the same thing in the mind of the parliamentary draftsman.

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Nichola Ross Martin
By Nichola Ross Martin
25th Nov 2014 17:30

ER ...

lets just beg to differ. We have conflicting views, we have no relevant case law on this particular set of facts and I can see that Kevin Slevin and Mark Morton both are likewise critical of HMRC's guidance.

 

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By User deleted
25th Nov 2014 18:44

Does anyone else find s169K circular?

(By virtue of ss 5)

Anyway, here's my take on it. A material disposal is defined, and can include the disposal of a  single share. No problem there, then.

The problem stems from the lack of a definition of "withdrawal ... from participation". In my opinion, PNL is confusing "participation in the business" with "participation in the company".

Condition B is quite clear that the individual must withdraw from participation in the business carried on by the company. My interpretation of that (which may differ from others' interpretation) is that such a withdrawal is not the same as a withdrawal from participation in the company. In other words, a shareholder may sell 100% of his shares but if remains a full-time director then arguably he has not withdrawn from particpation in the business carried on by the company. (He may be said to have also withdrawn from particpation in the profits generated by the business, but that is not the same either.)

But my view differs from that of HMRC's, so if the circumstances suit I'd be more than happy to rely on their guidance.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 10:22

Participation in the business

Is a different thing to participation in the management of the business, which is apparently my confusion!

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By User deleted
26th Nov 2014 11:02

Agreed, Portia

But do you agree that the wording of the legislation is far from perfect? (And therefore too open to interpretation.)

"participation in the business carried on by the company" (which implies something more than a mere shareholding) is not the same as "participation in the company" (which implies nothing more than an equity or other stake in the company). Do I participate in the various businesses carried on by the companies in my portfolio? Not in the ordinary meaning of the phrase, I don't.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 11:21

A sleeping partner or a limited partner

Participates in the partnership business, by having an entitlement to a share of the profits. I do not see how it differs for a shareholder in a company.

I think if you want to know what participation means in relation to a company CTA 2010, section 454 is a good place to start.

I do not see any particular fault. The legislation first talks about a material disposal and then talks about the withdrawal from participation in almost the very next breath, giving clear implication that they are one and the same thing.

This is further supported by the fact that we are talking about a disposal associated with a material disposal, and condition B is the one that tells us what it means by association.

Here's a little quote from Justice Evans-Lombe in the High Court decision of Clarke v Mayo, as well:

"It was submitted on behalf of the Revenue that s 70(7) was to be construed so as to require that for the disposal of an asset to constitute an "associated disposal" it must take place as part of a withdrawal of the taxpayer from participation in the relevant business. That withdrawal must comprise the material disposal of business assets and accordingly "the associated disposal" must be associated with that "material disposal". I accept that submission."

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By User deleted
26th Nov 2014 11:54

We'll leave it at that, then

If a material disposal and the withdrawal from participation are, as you suggest, one and the same thing then there would be no need for separate conditions A and B.

s454 is helpful in as much as it sets out what is meant by participation in a company for the purposes of close company taxation. I can't find anything that refers separately to participation in the business of a company for the purposes of capital gains tax. (Where is the cross-reference in s169K to s454?) If s454 were relevant, there would be no need for the words "in the business of". Why did the draftsman feel the need to include those particular words?

As I say, we'll need to agree to differ - I can understand what the legislation is perhaps aiming to achieve but consider that, as it is written, it doesn't achieve that. The very fact that there needs to be case law to clarify what the legislation is supposed to mean supports my view.

 

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Portia profile image
By Portia Nina Levin
26th Nov 2014 12:08

Conditions A and B

To my mind, condition A serves two purposes.

For the first purpose it does serve condition B, insofar as it says:

A) There must be a material disposal, and

B) The disposal  (that we want to treat as associated, subsection 5) must be made as a part of the withdrawal from the business (that that material disposal represents).

Condition A's second purpose is, of course, to make it clear that the disposal by a soletrader of assets used in the business will never be an associated disposal, and so must satisfy the test of being a material disposal.

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By User deleted
26th Nov 2014 12:09

Condition B

I’m not too sure if a taxpayer should be relying too much on HMRC’s staff manual CG63995. In fact HMRC’s answer to a specific query on this (para 59 here) refers us to two of their staff manuals.Reading example 2 in CG64000 (which is basically about retirement) gives me the impression that HMRC are playing safe despite what they say in CG63995.

Relying on published HMRC guidance can be risky - Hanover company services v HMRC. Also recently Noor v HMRC has concluded that the FTT has no jurisdiction to adjudicate on ‘legitimate expectation’ cases (obviously HMRC published guidance included). In other words, following CG63995 doesn't provide any insurance at all, and the OP cannot have a legitimate expectation that his interpretation of the law based on the manual, and therefore his actions as a consequence thereof, was indeed correct, unless of course the UT were to agree with him.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 12:21

HMRC's interpretation

Is what they argued, and the court accepted, in Clarke v Mayo. It was the taxpayer that argued that withdrawal from the business meant withdrawal from the management of the business.

Mayo won not because he had retired from the business, but because the transfer of his shares to his children was a material disposal.

So there is no need to rely on HMRC's manuals, we can rely on the judge in Clarke v Mayo.

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By User deleted
26th Nov 2014 12:31

I still want to know ...

... why the draftsman thought it necessary to include the cumbersome words "in the business of".

But I just don't follow PNL's logic.

A) There must be a material disposal (which PNL contends is synonomous with withdrawal from participation)

Therefore, if Condition A is met then, by definition, Condition B is automatically met and so B would be superfluous. B must therefore refer to something more than just the material disposal referred to at A.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 12:38

Logic

A) There must be a material disposal (of one of two particular classes), and

B) The purported associated disposal must be associated with the material disposal aforementioned!

And then we have a High Court judge saying yes, that is exactly what it means.

I cannot understand the difficulty.

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By User deleted
26th Nov 2014 13:29

That's not what Condition B says

"Your" condition B above is the opening line, which is then dependent on 3 apparently independent conditions (unless you're saying that Condition B is dependent on Condition B).

The purported associated disposal must be associated with the material disposal. Agreed. There is no ambiguity there.

Condition A will be met if there is a material disposal (= withdrawal from participation according to PNL)

Condition B will be met if there is withdrawal from participation (= material disposal according to PNL).

So, if Condition A is met, Condition B is automatically met. So no need for Condition B. QED.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 13:40

Condition B

Is not met simply by there being a withdrawal from participation (= material disposal).

How frigging hard is this, really?

Condition B is met IF THE (ASSOCIATED) DISPOSAL IS MADE AS PART OF the withdrawal that the material disposal represents!

If the disposal is made as part of the withdawal!

Say it with me, If the disposal is made as part of the withdrawal. That is the condition! That is what makes it an associated disposal!

That is the test of the disposal being associated with the material disposal. It is made as part of the withdrawal (that is a material disposal).

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Portia profile image
By Portia Nina Levin
26th Nov 2014 13:58

Oh

And why did the parliamentary draftsmen feel the need to include the words "in the business of" after the words participation?

Because participators participate in something. It is just a qualification of the word participation.

We are only concerned with the manner of participation, which is the object matter of the material disposal.

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By User deleted
26th Nov 2014 14:16

Simplifying matters

By using what you consider to be interchangeable expressions:

Condition A is that an individual makes a material withdrawal from participation which consists of ... (b) a withdrawal from participation.

Condition B is that the individual makes the (associated) disposal as part of the withdrawal of the individual from participation.

Ah, I've got it now - a  disposal will be associated with a withdrawal from participation if it is made as part of a withdrawal from participation. It's all clear to me now.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 14:25

Exactly

ER is available for a disposal (disposal 2) associated with a material disposal (disposal 1).

For disposal 2 to be an disposal associated with a material disposal, there are three prerequisites:

1) Disposal 1 must be a material disposal (of a required type),

2) Disposal 2 must be associated with disposal 1, and

3) The asset that was the subject matter of disposal 2 must have been used the business in which the subject matter of the disposal 1 was a participating business interest at the requisite time.

It is simple, when you are not hell bent on making it unnecessarily complicated. :)

Actually rather than call them prerequisites, and number them 1, 2 and 3, why do we not just call them conditions A, B and C.

Would you rather I wrote the legislation?

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By User deleted
26th Nov 2014 14:40

Your version is much clearer, thanks

What you are saying (again) is that in order that disposal 2  be associated with material disposal 1, disposal 2 must be associated with material disposal 1. I agree  - very simple indeed.

Just as simple - "if disposal 2 is not associated with disposal 1 then disposal 2 is not associated with disposal 1."

Such fun.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 15:54

You have got it

That is the very test!

If the withdrawal from the business (with which disposal 2 is associated) and the material disposal (disposal 1) are not one and the same thing, then disposal 2 is not a disposal associated with disposal 1 (the material disposal).

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By User deleted
26th Nov 2014 16:26

That is the conclusion

That one must reach based on your interpretation.

But - would you not consider a retirement from the business and sale of assets used in the business (with or without a disposal of shares) also to be part of a withdrawal from participation in the business? I would. So even if A and B were not in fact one and the same thing, I would argue that (a) there has been a material disposal of shares and (b) a withdrawal from the business of the company. So, while it may help to argue that A and B are one and the same thing, I don't see it as a prerequisite.

But if they are one and the same thing, and if that was the intended interpretation, Condition B really ought to have been worded along the lines of "Condition B is that the disposal is associated with the disposal in Condition A." In other words, why the need to refer to the verbose "withdrawal from participation ..." if any disposal of shares is a de facto withdrawal from participation in the business?

My interpretation runs along the lines of "If John is the brother of Peter and Peter is the brother of James then James is the brother of John". Yours seems to be "If John is the brother of Peter then John is the brother of Peter." Which proves absolutely nothing, other than that Peter is the brother of John.

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Nichola Ross Martin
By Nichola Ross Martin
26th Nov 2014 16:24

But…let's put it another way

I posted this at the same time as the post above, but I can see we are making the same point.

 

HMRC's examples indicate that you can stay on a managing director/full-time worker in your company/partnership, so reducing your involvement in management of the business but only provided that you make a sizeable disposal of shares/partnership interests as fulfils the requirement from HMRC's angle that you are also making your withdrawal from participation (in the profits). The OP proposes just the one share and this where I have the difficulty.

 

Nowhere do we have an example of just disposing of one share, and whilst the disposal of a single share will attract ER, it is the fact that we have the conditions set out in the way that we do in s169K that makes the difficulty. 

 

 

 

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Portia profile image
By Portia Nina Levin
26th Nov 2014 16:30

The language

Has to cover both a reduced interest in a company and a reduced interest in a partnership. A withdrawal from participation in the business of either.

If you examine condition B more carefully, you will see that it does not refer to a withdrawal from participation, it refers to the withdrawal from participation.

In order to refer to the withdrawal from participation, it must have already told us what withdrawal in participation it is talking about; in condition A or earlier.

Now look back; it does in different language; a material disposal that consists of...

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By User deleted
26th Nov 2014 16:46

Language

Partnership or company, a simple referral to either of the disposals at A would have been enough.

You and I interpret the use of a and  the differently. In my view use of the merely indicates that an individual may withdraw from participation in the business only once. He may do so in stages (or 'parts', if you like). When I come to retire from practice, I may do so in stages, gradually reducing my input. It would be slightly odd to say that I had retired several times.

Therefore, the does not refer to any defined withdrawal, but is simply the correct grammar when talking about a single event, albeit an event undertaken in stages. I suspect that it was your example of withdrawing funds (of which withdrawals there may be several) from the bank that has confused you.

Alternatively, why does B not simply refer to "the withdrawals mentioned in A above"? It seems clear to me that "withdrawal from participation in the business" has a different, and much wider, meaning than the individual disposals referred to in a quite separate condition.

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By blok
26th Nov 2014 16:43

.

if there was enough tax at stake, I wouldn't want to take the chance that 1% is enough of a reduction.  As it stands - the legislation is open to interpretation and I'd want to put the point beyond doubt.  Again, totally depending on the tax at stake, but could they make a disposal of say 25% of the shares to children or a trust ?  I'm getting the impression the shares are pretty worthless anyhow...

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Nichola Ross Martin
By Nichola Ross Martin
26th Nov 2014 16:50

Worked it out

drrrrrr should have read the question.

Condition A applies to shares (plural) so the OP's plan fails by virtual of disposing of a single share...

 

 

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Portia profile image
By Portia Nina Levin
26th Nov 2014 16:55

@ BKD

On the point regarding a versus the, your latest view conflicts with your earlier view that the individual can withdraw from the business in one of two ways; reducing their interest or reducing their involvement in management.

If the grammar is correct, then the logic must be faulty.

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By User deleted
26th Nov 2014 17:11

Ah but, Nichola...

IA 1978 s6(c)  :)

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Portia profile image
By Portia Nina Levin
26th Nov 2014 16:58

@ Nichola

Somebody has cleary never read the 1978 Interpretation Act. Section 6(c) refers: http://www.legislation.gov.uk/ukpga/1978/30/section/6?view=plain

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By User deleted
26th Nov 2014 17:10

That's not what I said, Portia

In the general sense, an individual can withdraw from participation in the business (in other words, retire) only once.

That withdrawal may happen in stages, for example part one being the sale of [a significant part of] his shares, part  two being retirement from the business, part three being sale of business assets. That is not the same as saying that an individual can withdraw from business in different ways, each different part simply being part of a single process - if my words suggested otherwise, then I apologise for the confusion caused.

 

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Nichola Ross Martin
By Nichola Ross Martin
26th Nov 2014 17:59

Searching for the purpose

Yes I fully agree with IA on plurals and singles. I was being flippant. I've said all I can. Nothing I have read here or externally brings me round, so lets just agree to differ.

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Portia profile image
By Portia Nina Levin
26th Nov 2014 18:15

No, no, no

You said (16:26) "But - would you not consider a retirement from the business and sale of assets used in the business (with or without a disposal of shares) also to be part of a withdrawal from participation in the business?"

So withdrawal from a business, in your view, can be done either by reducing your interest or retiring or both?

But the legislation is looking for the withdrawal, which you say means one withdrawal (whether or not done in stages).

On the 1%, Clarke v Mayo is clear that the material disposal is the withdrawal from participation, and 1% is a material disposal.

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By User deleted
26th Nov 2014 18:47

No, no, no, no

I'll change the emphasis.

"But - would you not consider a retirement from the business and sale of assets used in the business (with or without a disposal of shares) also to be part of a withdrawal from participation in the business?"

However, I'll concede that my grammar was poor - what I should have said was "...of the withdrawal ..."

The withdrawal from the business ultimately involves all of the above components - I did not say that there is more than one way to withdraw from a business. The withdrawal may involve different things being done (either together or at different times), but that is not the same.

 

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Portia profile image
By Portia Nina Levin
27th Nov 2014 10:24

Yes, but

The judge in Clarke v Mayo disagreed with you, and I am going with the view of the judge! :)

The relevant part of the judgement is:

"I turn now to the second point taken before me by the Revenue but which was not taken before the Commissioners. This point requires construction of the words "withdrawal of the individual concerned from participation in the business carried on by … the company …" as they appear in s 70(7)(a). It is the Revenue's contention that the disposal in question to qualify for relief must be associated with a withdrawal from participation in the business by the taxpayer and that participation in this context must mean holding an interest in the business concerned. In the present case the property was disposed of on 31 January 1989 whereas the material disposal of the interest in the business, which was the transfer of the taxpayer's holding of 49.99 per cent. of the shares in the company did not take place until 28 February 1990. Accordingly, there was no sufficient association.

It was contended by the taxpayer that "participation in the business" in the context of this case meant management of the business. Such management ceased on 28 February 1989 when the company ceased trading. That was a date sufficiently proximate to the disposal of the property so as to justify a finding that it took place as part of a withdrawal of the taxpayer from the business being carried on by the company. I have already accepted the Revenue's submission that the withdrawal from the business spoken of in subs (7)(a) must comprise the material disposal of business assets, in this case the disposal of the 49.99 per cent. interest in the company's shares by the taxpayer, and the associated disposal must be associated therefore with that material disposal. The question whether such association exists must be one of fact and, therefore, not for this Court.

In para 9 of the Case the Commissioners find "… that the disposal of the property was an 'associated disposal' in that it took place as part of the withdrawal by the taxpayer from participation in the business of Middletons". On its face, that appears to be the necessary finding of fact. However, the point was not argued before the Commissioners, and it is not clear from this passage whether the Commissioners were treating the "material disposal" on 28 February 1990 as a necessary part of the withdrawal from the business of the company as I have found it must be. Indeed it was, in the course of argument, conceded on behalf of the taxpayer that there was no relevant finding of fact by the Commissioners that the disposal of the property was associated with the "material disposal" of the shares which comprised the withdrawal from the business of the company.

In the result, the matter should be remitted to the Commissioners for them to deal with the essential issue of fact on this point, namely whether the disposal of the property and the consequent disposal of the taxpayer's one-quarter share in it which took place on 17 December 1988 was part of a withdrawal of the taxpayer from the business of the company, such withdrawal comprising the transfer by the taxpayer of a 49.99 per cent. shareholding in the company for the benefit of his children on 28 February 1990."

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By User deleted
27th Nov 2014 10:42

Judges have been known to get things wrong

Granted, as it stands, you (and indeed I) would probably want to rely on to that decision, rather than the counter-argument in this interminable discussion. I simply disagree with his analysis . End of.

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