Autumn Statement 2015: Further changes to entrepreneurs’ relief

A number of changes were made to entrepreneurs’ relief (ER) in Finance Act 2015, principally to prevent ER from being claimed on incorporation; to amend the joint venture provisions; and to clarify the material disposal rules in connection with associated disposals.

Although there is no detail at present, it seems likely that HMRC have accepted that the changes made in Finance Act 2015 catch commercial situations as well as the contrived structures that they sought to combat. The amendments will ensure that the relief continues to be available on genuine commercial transactions.

Changes to the legislation will be considered by the government, presumably for inclusion in Finance Act 2016.