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In Christopher Thomson v HMRC [2021] TC08337A, the First Tier Tribunal (FTT) allowed an Entrepreneurs’ Relief claim on the disposal of a partnership asset as the property disposal was part of the wider disposal of the partnership business even though that process had lasted over 20 years.

The FTT found that the disposal of the property represented the sale of part of a business as:

Useful guides on this topic

Business Asset Disposal Relief (Entrepreneurs’ Relief): Disposal of a business
Entrepreneurs' Relief (ER) was renamed Business Asset Disposal Relief (BADR) by Finance Act 2020. When does BADR apply? What is the rate of BADR? How do you claim BADR? What BADR case law is there?  

Business Asset Disposal Relief (Entrepreneurs’ Relief): At a glance
This is a freeview 'At a glance' guide to CGT Business Asset Disposal Relief (BADR), the relief formerly known as Entrepreneurs' Relief.

How to appeal an HMRC decision
Disagree with a HMRC decision? How to appeal, what type of decision can you appeal, what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

External links

Christopher Thomson v HMRC [2021] TC08337A


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