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Entrepreneurs� relief

An individual may qualify for entrepreneurs� relief (TCGA92/S169H) when their business becomes a partnership. A partner may also qualify for entrepreneurs� relief when there is a disposal of part or all of the partnership business.

A partner may qualify for entrepreneurs� relief (subject to the normal conditions) when he disposes of all or part of a fractional share in shares which are held as partnership assets.

Guidance on entrepreneurs� relief in relation to partnerships is at CG64040.

“Roll-over� relief

Roll-over� relief (TCGA92/S152) may be available to a partner where there is a disposal of a partnership asset and the proceeds are re-invested in another asset which is also used for trade purposes.

Guidance on “roll-over� relief in relation to partnerships is at CG61150.

“Roll-over� relief on transfer of a business

“Roll-over� relief on transfer of a business (commonly called “incorporation� relief) is available to a partner where the whole of the partnership business is transferred to a company as a going concern, in exchange for shares (TCGA92/S162).

Guidance on “incorporation� relief is at CG65700.

Gift “holdover� relief

“Holdover� relief for gifts of business assets (TCGA92/S165) is available to a partner, in a partnership that is transparent for tax purposes (CG27000), when the partner disposes of a share in a partnership assets (subject to the normal conditions for this relief).

Guidance on gift “holdover� relief is at CG66880.

Partnership Manual

There is more information on the capital gains reliefs available to partners in PM272300.