The disposal of assets by a partnership that had not commenced trading did not represent disposals of a business eligible for entrepreneurs’ relief, and pre-trading activities were not a ‘business’ for relief purposes. 

Summary 

The disposal of assets by a partnership that had not commenced trading did not represent disposals of a business eligible for entrepreneurs’ relief (ER), and pre-trading activities were not a ‘business’ for relief purposes. 

Background 

The appellant was one of three partners who, in January 2014, established a general partnership under English law whose business was to develop, construct and operate renewable power plants at three locations in the UK. The partnership commenced pre-trading activities on 1 May 2014. When the projects