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CGT: No tax relief on disposal of distribution rights

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The FTT found that distribution rights held in a company limited by both share capital and guarantee rights were not ordinary share capital, so entrepreneurs’ relief (ER) could not apply to the gain on disposal.

13th Aug 2021
Tax Writer
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The company 

Monarch Assurance Holdings Ltd (MAH) was incorporated in 1979 before company law required companies to be limited by share capital or by guarantee rights, so it was limited by both.

Under MAH’s articles of association, there were two classes of member: shareholder members and investor members.

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