While every attempt will be made to ensure that information provided is accurate at the time of publication, it should be treated as guidance only and does not constitute legal or professional advice. Tax law and guidance changes frequently and readers are advised to consult the current relevant publication for the most up-to-date information on this topic.

Capital gains tax entrepreneurs' relief has been with us since 2008 and practitioners will, by now, be aware of its main features, most of which will need to be satisfied in a 12-month run-up to a disposal.

Gains of £10m in an individual's lifetime can qualify for the 10% rate of capital gains tax rather than the normal 28%, so the stakes are high with up to £1.8m of tax (£10m gains at the differential of 18%) at stake if the adviser and his client do not arrange matters carefully and plan in advance.

The eight pages of legislation (TCGA 1992, s 169H to s 169S) have changed little and indeed there have been relatively few tribunal or other cases.

This article sets out 10 problem areas and how the adviser may resolve them with his client ... in good time before a disposal.

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