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This relief (TCGA92/S169H to S169V) was introduced by FA08/SCH3 to complement the flat rate for capital gains tax that applies to disposals taking place on or after 6 April 2008. From that date, disposals no longer attract indexation or taper relief.

Entrepreneursâ€� relief has the effect of charging certain gains at a lower rate of tax than the flat rate. »Ê¹ÚÌåÓýapp main conditions reflect similarities with those for retirement relief although with significant simplifications.

Gains arising on or associated with the disposal of the whole or part of a business may qualify, as may certain disposals of shares or securities, but not those held in Funds at Lloyd’s. »Ê¹ÚÌåÓýappse are not ‘relevant business assetsâ€� under TCGA92/S169L, being excluded assets under subsection (4). Detailed guidance is at CG64005.

Until 22 June 2010, gains that qualify for relief were reduced by 4/9ths. For disposals on or after 23 June 2010, the gain is charged to capital gains tax at a rate of 10 per cent.

»Ê¹ÚÌåÓýapp amount of gains that may qualify for the relief is subject to a lifetime limit which is £10,000,000 for disposals made on or after 1 April 2011.

Reducing a member’s syndicate capacity, including where this is done by reducing the number of syndicate participations within a member’s spread, is not likely to amount to the disposal of part of the underwriting business. It is instead more likely to be a disposal of an asset.