The Upper Tax Tribunal has agreed that HM Revenue & Customs was right to deny entrepreneurs’ relief to a pair of company owners, despite acknowledging that the outcome was unfair and the relief had been devised precisely for entrepreneurs like them.
The decision, which overturned a First-Tier Tax Tribunal judgment last year, turned on whether Michael and Elizabeth McQuillan’s holding of redeemable shares with no right to a dividend counted as ordinary share capital (HMRC v Michael and Elizabeth McQuillan, 2017 UKUT 0344 TCC).
The tribunal decision may be found at – https://bit.ly/2wN1WEo
