An entrepreneurs’ relief claim on the disposal of goodwill upon the incorporation of a business was unsuccessful, as the taxpayer was unable to prove that the disposal took place before the introduction of rules restricting relief on goodwill disposals from 3 December 2014. 

Summary 

An entrepreneurs’ relief (ER) claim on the disposal of goodwill on the incorporation of a business was unsuccessful, as the taxpayer was unable to prove that the disposal took place before the introduction of rules restricting relief on goodwill disposals from 3 December 2014. 

Background 

The appellant established her first nursery school in 1996, which operated from premises at a church under a personal licence. In 2001, the appellant opened a second school, which also operated from premises at a church under a personal licence. In the period to 2011, the business gained reputation and