The government has confirmed that the entrepreneurs’ relief (ER) lifetime limit is reduced from £10 million to £1 million, with effect for qualifying disposals made on or after 11 March 2020 and certain disposals made before 11 March 2020.
Legislation, which will be included in the Finance Bill 2020, will:
In addition, where shares have been exchanged for those in another company on or after 6 April 2019 and before 11 March 2020 and an election is made under section 169Q of TCGA 1992 on or after 11 March 2020, the disposal will be treated as taking place at the time of the election for ER purposes (meaning that the new lifetime limit of £1 million will apply), if either of the following applies:
A stamp duty land tax (SDLT) surcharge of 2% will be introduced for non-UK resident buyers of English and Northern Irish residential property with effect on and from 1 April 2021.
A refund of the surcharge will be due to buyers who become UK resident after their purchase.
Transitional measures will be introduced for contracts that have been exchanged before 11 March 2020 but are completed or are substantially performed after 1 April 2021.
The measures will be included in the Finance Bill 2021. The government will also publish a summary of responses to its consultation on the measure in due course.
© 2020 GSC Solicitors LLP. All rights reserved. GSC grants permission for the browsing of this material and for the printing of one copy per person for personal reference. GSC’s written permission must be obtained for any other use of this material. This publication has been prepared only as a guide to provide readers with general information on recent legal developments. It is not formal legal advice and should not be relied on for any purpose. You should not act or refrain from acting based on the information contained in this document without obtaining specific formal advice from suitably qualified advisors.