In John Tenconi v HMRC [2021] TC08088, the First Tier Tribunal (FTT) found that the transfer of a beneficial interest in guarantee rights was a chargeable disposal subject to Capital Gains Tax (CGT) and the rights could not be considered shares for the purposes of Entrepreneurs’ Relief.

On Review, HMRC upheld their position. Mr Tenconi Appealed to the FTT.

The FTT found in favour of HMRC:

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Business Asset Disposal Relief (Entrepreneurs' Relief): Disposal of shares or securities in a company
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VtaxP Toolbox: Business Asset Disposal Relief (Entrepreneurs' Relief): share disposals
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External link

John Tenconi v HMRC [2021] TC08088

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