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HMRC internal manual

Capital Gains Manual

Entrepreneurs’ Relief: date of cessation of a business

The date of the cessation of a business, or the date upon which a company ceases to be a trading company or holding company of a trading group, is a question of fact. Determining the date will usually be straightforward where trade has ceased entirely. But for less clear cut cases when there is a wide difference between possible dates and this is material to a claim for Entrepreneurs’ Relief there is guidance in the Business Income Manual to assist you. See BIM80565+.

It may be more difficult to establish an exact date when a company ceased to qualify based on its having substantial non-trading activities if the change in activities is incremental and in those circumstances the date of change may be taken as the end of the relevant company accounting period.