An individual shareholder’s claim for entrepreneurs’ relief was unsuccessful as the company was not the shareholder’s ‘personal company’ due to failing the 5% test for voting rights.
Summary
An individual shareholder’s claim for entrepreneurs’ relief was unsuccessful as the company was not the shareholder’s ‘personal company’ (within TCGA 1992, s 169S(3)) due to failing the 5% test for voting rights.
Background
The appellant held 37 shares in a company (THHGL), which were re-designated as 37 ‘B’ ordinary shares by special resolution in August 2007.â¯Prior to the 2007 resolution and a re-designation of shares into ‘A’ and ‘B’ shares, there was a single