Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/entrepreneurs-relief/ Views and developments from the Tax Department at Weil Fri, 24 Apr 2026 11:53:35 +0000 hourly 1 Entrepreneurs’ Relief – FA 2019 Changes https://tax.weil.com/uk-tax/straight-to-the-point/entrepreneurs-relief-fa-2019-changes/ Tue, 21 May 2019 13:51:55 +0000 Oliver Walker http://tax.weil.com/?p=510 Speed read This year’s Finance Act consolidated various changes to the Entrepreneurs’ Relief (“ER”) regime. There are two key changes that may be of particular relevance to corporate acquisitions: new (additional) economic ownership tests that must be satisfied in orderfor an individual holding shares in a company to benefit from ER; and a new option

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]]> Speed read This year’s Finance Act consolidated various changes to the Entrepreneurs’ Relief (“ER”) regime. There are two key changes that may be of particular relevance to corporate acquisitions: new (additional) economic ownership tests that must be satisfied in orderfor an individual holding shares in a company to benefit from ER; and a new option

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]]> Autumn Budget 2018 https://tax.weil.com/uk-tax/straight-to-the-point/autumn-budget-2018/ Mon, 29 Oct 2018 22:10:19 +0000 Oliver Walker http://tax.weil.com/?p=506 The Chancellor delivered the 2018 Autumn Budget this afternoon. Here is a summary of the key announcements.

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]]> The Chancellor delivered the 2018 Autumn Budget this afternoon. Here is a summary of the key announcements.

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]]> Ordinary share capital: HMRC shares its views https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-hmrc-shares-its-views/ Mon, 24 Sep 2018 15:14:49 +0000 Stuart Pibworth http://tax.weil.com/?p=503 For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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]]> For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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]]> Summer in the City: Draft UK Tax Legislation Published on 6 July 2018 https://tax.weil.com/uk-tax/corporation-tax/summer-in-the-city-draft-uk-tax-legislation-published-on-6-july-2018/ Fri, 13 Jul 2018 14:03:06 +0000 Stuart Pibworth http://tax.weil.com/?p=499 On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

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]]> On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

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]]> Ordinary Share Capital: Clarity in Relation to Dividend Rights https://tax.weil.com/uk-tax/uk-focus-latest-thinking/ordinary-share-capital-clarity-in-relation-to-dividend-rights/ Sun, 01 Oct 2017 17:10:06 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=483 The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

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]]> The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

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]]> Ordinary Share Capital: Can a Negative Prove a Positive? https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-can-a-negative-prove-a-positive/ Wed, 17 Aug 2016 12:50:08 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=465 The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

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]]> The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

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