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Another practical Knowledge Shop Webinar | 1

Applying the New 1 July Small Business

CGT Rollover Rules Webinar

June 2016


Contents Slides ............................................................................................................................................................... 4

Notes ............................................................................................................................................................. 13

Background............................................................................................................................................ 13

Basic conditions ..................................................................................................................................... 13

Tax implications ..................................................................................................................................... 19

The information contained herein is provided on the understanding that it neither represents nor is intended to be advice or that the authors or distributor is engaged in rendering legal or professional advice. Whilst every care has been taken in its preparation no person should act specifically on the basis of the material contained herein. If assistance is required, professional advice should be obtained. The material contained in the Applying the New 1 July Small Business CGT Rollover Rules Webinar should be used as a guide in conjunction with professional expertise and judgement. All responsibility for applications of the Applying the New 1 July Small Business CGT Rollover Rules Webinar and for the direct or indirect consequences of decisions based on Applying the New 1 July Small Business CGT Rollover Rules Webinar rests with the user. Knowledge Shop Pty Ltd, directors and authors or any other person involved in the preparation and distribution of these slides and notes, expressly disclaim all and any contractual, tortious or other form of liability to any person in respect of these notes and any consequences arising from its use by any person in reliance upon the whole or any part of the contents of these notes. Copyright © Knowledge Shop Pty Ltd June 2016. All rights reserved. No part of these slides or notes should be reproduced or utilised in any form or by any means, electronic or mechanical, including photocopying, recording or by information storage or retrieval system, other than specified without written permission from Knowledge Shop Pty Ltd. Please direct any questions regarding the Applying the New 1 July Small Business CGT Rollover Rules Webinar to: Knowledge Shop Pty Ltd Level 2, 115 Pitt St, Sydney 2000 Tel: 1800 800 232


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Slides

Michael Carruthers

Tax Director, Knowledge Shop

Applying the New Small Business CGT Rollover Rules Webinar

What we will cover

• Conditions that need to be met

• ATO guidance

• Practical issues

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Basic conditions

Transfer of asset to one or more other entities

Genuine restructure of

ongoing business

No change to underlying ownership

SBE test for all entities involved

Active asset

Residency testChoice by all

entities involved

Not tax exempt entities or super

funds

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Not a

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Call Julie on 1800 800 232 and see what’s on offer

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Genuine restructure

Basic test

Safe harbour

rule

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Ongoing business

• Transaction is expected to deliver benefits to the business in future

• Improve the operation of the business

• Not aimed at situations where transaction is connected with

– Winding down the business

– Selling the business

– Inappropriate tax planning

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LCG 2016/D3

Good restructures

• Asset protection

• Retain key employees

• Raise new capital

• Simplifying matters

Bad restructures

• Disposal of business

• Succession planning

• Extracting wealth from the business

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Safe harbour rule

• No change in underlying ownership of significant assets

• Assets continue to be active

• No material private use

Need to pass all of the

following for 3 years

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Don’t stop at the safe harbour rule

• What are the expected benefits to the business in terms of growth, innovation, reducing administrative burdens or costs?

• Is the client moving to a structure they should have been in from the start?

• Are the business operations basically the same?

Consider and

document

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Poll 1

• Green Pty Ltd operates a business and owns its business premises

• Shares in the company are held 50/50 by the Yellow discretionary trust and Blue discretionary trust

• The company is transferring the business premises to a unit trust, with units held 50/50 by the same discretionary trusts

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Poll 1

Assuming the other basic conditions are passed, would this transaction satisfy the ultimate economic ownership condition?

a) Yes

b) No

c) Yes, but only if the Yellow and Blue trusts have made family trust elections

d) I have absolutely no idea

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Ultimate economic ownership

• Trace through to individuals

• ATO comments on discretionary trusts:

“Non-fixed trusts may be able to meet the requirements for ultimate economic ownership, for example, where there is no practical change in which individuals economically benefit from the assets before and after the transfer.”

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Family trust elections

• Deemed continuity of ultimate ownership if:

– Family trust held asset just before or just after the transaction

– Every individual who had ultimate economic ownership of the asset just before and just after the transaction was a member of the family group

• How strictly should the rules be interpreted?

– Examples in LCG 2016/D2 and LCG 2016/D3

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SBE condition

• SBE in their own right

• Connected with a SBE

• An affiliate of a SBE

• Partner in a partnership that is a SBE

All parties to the

transaction need to be

at least one of the following

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Active asset

• Tested at the time the transfer takes effect

• If asset owner does not carry on a business then check whether it is used in a business carried on by

– Connected entity that is a SBE

– Affiliate that is a SBE

– Partnership that is a SBE (where the asset owner is a partner)

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Poll 2

• ABC Pty Ltd operates a business and is a SBE

• The shares are held 50/50 by mum and dad

• The shares are active assets under the small business CGT concessions (ie, meet the 80% test)

• Mum and dad want to transfer their shares to a discretionary trust which they control

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Poll 2

Can the SBE restructure rollover rules apply to the transfer of the shares?

a) No

b) Yes

c) Yes, but only if the trust makes a FTE with mum or dad as test individual

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Transfer of shares

• Active asset requirement

• Genuine restructure of ongoing business

• Ultimate economic ownership condition

Issues

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Tax implications

• Deemed consideration to ensure no gain or loss to the transferor

– CGT assets

– Trading stock and other revenue assets

– Depreciating assets

• Same amount used to determine cost for the transferee

• ‘Switch off’ provisions such as Division 7A

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CGT issues

Pre-CGT assets

CGT discount

15 year exemption

Small business rollover relief

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Depreciating assets

• New owner takes over WDV, effective life and method

• Tax relief for pooled assets

– Seems like all pooled assets would need to be transferred for concessions to apply

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Cost base of shares or units issued

Divide the result by

number of shares or

units

Subtract liabilities

assumed by the

transferee

Start with cost and WDV

of assets transferred

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Loss denial rule

Prevents capital losses being triggered on disposal of

shares or units where that entity has been involved in a

roll-over transaction

Exception where you can demonstrate that

the loss was not attributable to the

rollover transaction

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Consideration for the transfer

• Division 7A issues if loan created

• Trust deed and trustee obligations

• Companies and directors

• Bankruptcy laws

• Mismatch of profits and franking credits

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Areas of uncertainty

• Ultimate economic ownership condition

• FTE concessions

• Turnover threshold if SBE rules change from 1 July 2016

• Significant individual requirement under 15 year exemption

• Significant assets of the business

• ‘Material’

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Don’t forget

1. •GST

2. •FBT

3. •Stamp duty

4. •Part IVA

5. •Commercial and legal issues

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Questions?

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Notes

Background

In the May 2015 Federal Budget the Government announced a series of changes specifically aimed at small

business taxpayers. One of the final changes to actually become law is the introduction of a new form of

roll-over relief for small businesses from 1 July 2016. The rules are designed to enable small businesses to

restructure their business operations without triggering adverse implications under the income tax system.

However, there are a number of strict conditions that must be met to ensure that tax relief can actually

apply.

The broad policy objective behind the small business roll-over relief is to enable small businesses to

restructure their operations in a tax efficient manner. The Government recognises that many small

businesses owners set up their business without necessarily seeking professional advice on the best

structure to use. Also, sometimes the business structure that was most suitable when the business

commenced is no longer appropriate.

While the CGT provisions already contain a number of roll-overs that can be utilised for business

restructures, they generally only provide CGT relief when assets are transferred to a company. This new

form of roll-over relief will provide a greater level of flexibility by providing tax relief when assets are

transferred to a sole trader, partnership or trust if certain conditions can be met.

The changes are contained in the Tax Laws Amendment (Small Business Restructure Roll-over) Bill 2016

which passed through Parliament on 29 February 2016 and received Royal Assent on 8 March 2016. The

rules can therefore apply to the following:

Transfers of depreciating assets where the balancing adjustment event occurs on or after 1 July 2016;

Transfers of CGT assets where the CGT event occurs on or after 1 July 2016; and

Transfers of trading stock or revenue assets where this occurs on or after 1 July 2016.

Basic conditions

In order to obtain roll-over relief under the new rules there are a number of conditions in Subdivision 328-

G of the Income Tax Assessment Act 1997 (ITAA 1997) that need to be satisfied. These are summarised

below:

An entity transfers an asset to one or more other entities;

The transaction is, or is part of, a genuine restructure of an ongoing business;

Each of the parties to the transaction falls within one of the following categories:

o It is a small business entity (SBE) for the year in which the transfer occurred;

o It is connected with an entity that is a SBE for the year in which the transfer occurred;

o It has an affiliate that is a SBE for the year in which the transfer occurred; or

o It is a partner in a partnership that is a SBE for the year in which the transfer occurred;


The transaction does not have the effect of materially changing the individuals who have the ultimate

economic ownership of the asset transferred and their respective share of that ultimate economic

ownership;

At the time of the transfer the asset is an active asset of the vendor (or is an active asset of the relevant

connected entity, affiliate or partnership that is a SBE if the vendor is not an SBE in its own right);

The transferor and each transferee choose to apply roll-over relief;

The entities involved in the transaction pass a residency test; and

None of the entities involved in the transaction are complying superannuation funds or exempt entities.

Genuine restructure of an ongoing business

As noted above, the roll-over relief is only available to transactions that are part of a genuine restructure of

an ongoing business. Whether this condition will be met in relation to a particular transaction will depend

on the facts.

The inclusion of this condition suggests that the roll-over relief is not intended to apply in situations where

the business owner triggers the transaction in connection with the winding down or sale of the business.

That is, the roll-over is only aimed at situations where the transaction could be expected to deliver benefits

to the business in the future and where this is expected to improve the operation of the business.

As it may be difficult in some cases to conclude whether this condition will be met, section 328-435

provides a safe harbour rule. This section states that the transaction will be treated as being part of a

genuine restructure of an ongoing business if all the following conditions are met in the 3 year period after

the transaction takes place:

There is no significant change in ultimate economic ownership of any of the significant assets of the

business (other than trading stock) that were transferred under the transaction;

Those significant assets continue to be active assets; and

There is no significant or material use of those significant assets for private purposes.

If these conditions cannot be met then this does not automatically mean that the roll-over relief is not

available. It would simply mean that the client would need to be able to demonstrate to the ATO that the

transaction was actually a genuine restructure of an ongoing business. The factors that might be relevant

in making this determination are likely to include:

Whether it can be established that the restructure is being undertaken to facilitate growth, innovation

and diversification of the business, to enable it to adapt to changed conditions and/or to reduce

administrative burdens, compliance costs or cash flow impediments;

Whether the client is genuinely restricting the way the business will be operated as opposed to this

being a preliminary step in the course of disposing of assets;

Whether economic ownership of the business and its assets will be maintained;

Whether the same business operations will simply be conducted through a different legal structure (eg,

using the same premises, equipment, employees, suppliers etc);

Whether the transaction results in the client operating their business through a structure that might

reasonably have been utilised if they had obtained professional advice before starting the business.


The ATO has released a draft Law Companion Guideline LCG 2016/D3 which provides guidance on the

genuine restructure of an ongoing business requirement. The document provides a number of examples

which suggest that the following might be acceptable reasons for utilising the roll-over relief:

Providing relevant parties with additional asset protection

Improving the ability of the business to retain key employees

Raise new capital to finance business expansion plans; and

Simplify the taxpayer’s affairs (eg, eliminate unnecessary entities from the group).

The document also provides some examples of situations where the parties are not undertaking a genuine

restructure of an ongoing business such as:

Where the restructure is done as a preliminary step to the disposal of the business;

Where the restructure is undertaking by a taxpayer in the course of retiring from the business and

facilitating the transfer of wealth and assets to other family members (eg, succession planning); and

Where the restructure is primarily aimed at extracting wealth from the existing structure.

While it is appropriate for small business owners to consider the tax implications of the business structures

that they are using, it is expected that the Commissioner would not look favourably on a transaction if it

appeared to be unduly driven by tax considerations. When advising clients on this new roll-over it will be

important to ensure that the commercial reasons for the restructure are clearly documented to minimise

the risk that the Commissioner will seek to deny the roll-over relief on the basis that the transaction is not

part of a genuine restructure of an ongoing business or on the basis that the general anti-avoidance

provisions in Part IVA apply to the arrangement.

Ultimate economic ownership

The roll-over relief is only available if there is no material change to the underlying economic ownership of

the assets being transferred. This is a reference to individuals who have beneficial ownership of the asset,

either directly or indirectly.

If the asset is held by a company, partnership or trust it will be necessary to trace through to the individuals

who hold the interests in those entities and ultimately benefit from the asset in an economic sense.

If there is more than one individual who is an ultimate economic owner of an asset it is necessary to ensure

that their share of the ultimate economic ownership is materially unchanged. That is, their proportionate

interest in the asset must remain largely unchanged.

Note that the legislation uses the word “materially”. This suggests that there may be scope for minor

changes to take place, although it is not entirely clear how much flexibility this will encompass.


Examples from the EM

Example 1.1

Penny runs a small furniture manufacturing business as a sole trader. She wishes to run the business

through a unit trust.

Penny sets up the Just Me Unit Trust for this purpose, with herself as sole unit holder, and transfers the

active assets of the business to the trust. This would not result in a change in ultimate economic ownership

of those assets.

Example 1.2

Amy, Anna and Adrian run a delivery business as equal partners and want to transfer their interests in the

assets of the partnership to a company. Anna and Adrian are a couple.

Amy, Anna and Adrian establish a company, whereby 300 identical shares are issued. 100 shares are issued

to Amy, 150 shares are issued to Anna, and 50 shares are issued to Adrian. This is because Adrian has other

income and Anna and Adrian, as a couple, want to lower their overall income tax bill.

While this doesn’t change the individuals who have the ultimate economic ownership of the asset, there is

a change in the proportionate share of that ultimate economic ownership. Accordingly, Amy, Anna and

Adrian cannot use the small business restructure roll-over.

However, if the shares were distributed equally between the partners, the ultimate economic ownership of

the assets would be unchanged, and Amy, Anna and Adrian could use the roll-over, subject to satisfying the

other conditions.

While in many cases it should be relatively straight forward to identify the ultimate economic owners of an

asset, this will not always be the case. For example, when discretionary trusts are involved in the

transaction it could be very difficult to satisfy this requirement. As a starting point, the ATO provides some

brief comments in its guide to the new rules, these are extracted below:

“Non-fixed (discretionary) trusts may be able to meet the requirements for ultimate economic

ownership, for example, where there is no practical change in which individuals economically

benefit from the assets before and after the transfer.”

However, there is still a great deal of uncertainty around the application of the rules in practice when

discretionary trusts are involved.


As a result of this uncertainty, section 328-440 provides concessional treatment for situations where assets

are transferred to or from a discretionary trust. In this case, the transaction is treated as not having the

effect of changing the ultimate economic ownership of the asset (or an individual’s share of that

ownership) if:

The trust has made a family trust election (FTE);

Every individual who had an ultimate economic ownership interest in the asset just before the transfer

of the asset was a member of the family group of the test individual in the FTE; and

Every individual who had an ultimate economic ownership interest in the asset just after the transfer of

the asset was a member of that family group.

Example from the EM

Example 1.3

Chris and Victoria are husband and wife and are the only shareholders in Puppy Co, with each owning one

share with a cost base of $2 per share.

Puppy Co has successfully carried on a puppy training school and has acquired significant assets including

puppy boarding facilities, a vehicle, and goodwill.

Victoria and Chris wish to transfer the puppy boarding premises from Puppy Co to a recently settled

discretionary trust, the Fluffy Trust, which will lease the premises to Puppy Co. The family trust election is

made nominating Victoria as the primary individual controlling the trust. Victoria and Chris are members of

Victoria’s family group.

For the purpose of the roll-over, there will not be a change in the ultimate economic ownership of the

premises as a result of the transfer of the asset from Puppy Co to the Fluffy Trust. Therefore, assuming that

the other requirements are also met, the roll-over would be available in respect of the transfer.

Note that this concession is only available if the asset is held by a family trust just before or just after the

transfer takes place. Unfortunately, the concession does not assist situations where entities involved in the

transaction have shares or units held by a discretionary trust. While it might still be possible to pass the

basic requirement in these cases (eg, if an asset is transferred from a company to a unit trust where the

same discretionary trust owns all the shares in the company and units in the unit trust), there is some

uncertainty around this issue. We have raised this issue with both Treasury and the ATO and hope that the

ATO will provide some practical guidance on this shortly.

It is also unclear how narrowly the legislation should be interpreted when it comes to applying the

concession for family trusts. For instance, in the example above it is not clear whether Victoria and Chris

must be the only potential beneficiaries of the trust in order for the concession to be available. Some of the

examples provided by the ATO in LCG 2016/D2 and LCG 2016/D3 suggest that this may not necessarily be

the case.


Active asset

Unlike the existing small business CGT concessions, there is no requirement to test the asset being

transferred over a period of time. Under these rules, the condition is satisfied if the asset being transferred

is an active asset at the time the transfer takes effect.

If the entity transferring the asset is not classified as a SBE in its own right (eg, because it does not carry on

a business activity), the condition can still be met if the asset is used in a business carried on by a

connected entity or affiliate that is classified as a SBE.

If the entity transferring the asset is a partner in a partnership then the condition can also be met if the

asset is an asset of the partnership and the partnership is a SBE.

The EM to the Bill notes that this condition will not be met in relation to assets such as shareholder loans or

unpaid trust distributions. For example, if a company carries on a business and wants to transfer all its

assets to a related party, any loans receivable from shareholders that fall within the scope of Division 7A

would not qualify for the roll-over relief.

The way the rules are drafted means that it would be very difficult for the rules to apply to the transfer of

shares in a company or units in a trust. While these assets can potentially be classified as active assets (eg,

if an 80% test is satisfied), if the shareholder is not a SBE in their own right then the rules require the shares

or units to be used in a business carried on by the relevant connected entity or affiliate. It is difficult to see

how this condition could be satisfied unless the shares were held on revenue account as part of a business

of share trading.

Example from the EM

Example 1.5

Mr and Mrs Smith are directors and shareholders of private company ABC Pty Ltd. They each own 50

shares in ABC Pty Ltd, which operates the family business of a milk bar.

Due to the administrative burden of operating a private company, Mr and Mrs Smith decide to restructure

their business affairs. They use the small business restructure roll-over and transfer all plant and

equipment of the milk bar to a newly formed partnership.

A complying Division 7A loan for $50,000 to Mr Smith also exists in the balance sheet of ABC Pty Ltd. The

Division 7A loan cannot be transferred to the partnership as it not an active asset, and the normal

operation of Division 7A continues to apply in respect of the loan.


Residency

The residency rules depend on the type of entity involved in the transaction. The conditions are

summarised below:

If the entity is a company or individual it must be an Australian resident;

If the entity is a trust, it must be a resident trust for CGT purposes;

If the entity is a partnership (other than a corporate limited partnership), at least one of the partners

must be an Australian resident; or

If the entity is a corporate limited partnership, it must be a resident for income tax purposes under

section 94T ITAA 1936 (ie, it was formed in Australia or it carries on business in Australia and has central

management and control in Australia).

Tax implications

If these conditions are satisfied then the rules are designed to ensure that any income tax consequences

that would otherwise be triggered by the transaction will be disregarded.

As a starting point, this is achieved by treating the parties as having transferred the assets for an amount

that ensures that no gain or loss arises to the transferor. The recipient of the asset is treated as having paid

the same amount for the acquisition of the asset. For example, if a CGT asset has been transferred, the

recipient is treated as having provided consideration equal to the cost base of the asset at the time of the

event. Not only is this treatment applied to CGT assets, but is also extended to depreciating assets, trading

stock and other assets held on revenue account.

In addition, the rules ensure that any other provisions under the income tax law that could be triggered are

treated as if they had been “switched off”. For example, when a private company transfers assets to a

related party for less than market value consideration this can trigger a deemed dividend under Division

7A. However, section 328-450 ensures that this will not be treated as a dividend or deemed dividend in the

hands of the related party if the transaction qualifies for roll-over relief and the parties choose to apply roll-

over relief.

It is important to realise that while the roll-over impacts on the income tax treatment of the transaction,

the parties will still need to consider other potential implications such as GST, FBT and stamp duty. The EM

also stresses the point that the general anti-avoidance rules in Part IVA can still apply in appropriate

situations.

Indirect tax implications would also need to be considered. For example, while Division 7A might be

“switched off” at the time of the event, there could still be Division 7A issues if loans were created as a

result of a transaction that qualifies for roll-over relief but these loans are not repaid within the relevant

time frame or they are subsequently forgiven.


Specific CGT issues

Firstly, any pre-CGT assets of the transferor that are transferred under this roll-over will retain their pre-

CGT status in the hands of the transferee.

However, when it comes to applying the CGT discount on subsequent sale of the asset by the transferee,

they will be treated as having acquired the asset at the time of acquisition from the transferor. That is, the

12 month holding period under the CGT discount rules will be reset when the roll-over is utilised.

The situation is different when looking at the 15 year exemption under the small business CGT concessions.

If the transferee is able to access the small business CGT concessions on subsequent disposal of the asset

they will be treated as having acquired the asset when the previous owner acquired the asset for the

purpose of determining whether the 15 year ownership period condition has been satisfied under the 15

year exemption.

The other main modification under the CGT rules is relevant where the transferor has previously applied

the small business roll-over relief under the existing small business CGT concessions. If that entity acquired

a replacement active asset under those rules but has since transferred the asset to another entity under

the small business restructure roll-over provisions, the transferee is treated as if it was the entity that made

the choice to apply the small business roll-over under Division 152 when it comes to monitoring CGT events

J2, J5 or J6 (ie, could trigger a capital gain for the transferee if that asset ceases to be an active asset etc).

Depreciating assets

The rules around depreciating assets are dealt with separately to the rules dealing with CGT assets, trading

stock and other assets on revenue account. However, roll-over relief can still be obtained when the basic

conditions are satisfied. If the roll-over applies then the new owner would take over the written down

value of the assets and would deduct the decline in value of the assets using the same method (ie,

diminishing value or prime cost) and remaining effective life as the transferor was using.

The roll-over relief can also apply to assets that are subject to the pooling rules for small business entities.

While there is a lack of clear guidance around how the roll-over will apply in this case, it seems that relief

would only be available if all assets in the pool are transferred to the transferee.

Shares or units issued as consideration

Under the draft version of the rules the transferee was not allowed to provide consideration for the assets.

Fortunately this condition has been removed and does not form part of the final rules. As a result, the

transferee is able to provide consideration for the acquisition of the assets and this could include issuing

shares or units. If this occurs then there are some special rules to determine the cost base of those shares

or units. The cost base of the shares or units is worked out as follows:

Start with the sum of the cost and written down values of the assets that have been transferred;

Subtract any liabilities that the transferee has undertaken to discharge in respect of those assets;

Divide the remaining amount by the number of shares or units that were issued.


Example from the EM

Example 1.7

Edamame Pty Ltd transfers three assets that it owns to the Soy Trust in circumstances that qualify for

rollover:

• a CGT asset having a cost base of $100,000;

• a second CGT asset having a cost base of $1 million; and

• a depreciating asset having an adjustable value of $400,000.

The Soy Trust issues 10 units to Edamame Pty Ltd in exchange for the transfer. The cost base and reduced

cost base of each unit is $150,000 [($100,000 + $1 million + $ 400,000)/10].


Loss denial rule

The provisions also contain a special rule which is designed to ensure that losses are not recognised on sale

of shares in a company or units in a trust where that entity has disposed of or received assets as part of a

transaction to which the roll-over relief applies. The exception to this is where the taxpayer can

demonstrate that the loss is reasonably attributable to something other than the roll-over transaction.

For example, if a company transfers an asset to a new trust for less than market value consideration under

the small business roll-over relief, the shares in that company would presumably drop in value. If the

shareholder subsequently sold their shares in the company and made a capital loss they would need to

demonstrate that the capital loss was not attributable to the transfer of the assets to the trust for less than

market value consideration to be able to recognise that capital loss for CGT purposes.

This rule is not relevant to sole traders or discretionary trusts that have disposed of assets.

Example from the EM

Example 1.8

The Dance Partnership transfers an asset having an acquisition cost of $400,000 and market value of

$500,000 to Studio Pty Ltd, and the small business restructure roll-over applies to the transfer. Immediately

prior to the transfer, Studio Pty Ltd had existing assets of $700,000 and 18 ordinary shares on issue.

Studio Pty Ltd issues one share each to Riley and Michelle, the partners in the Dance Partnership, as

consideration for the transfer.

For both Riley and Michelle, the cost base and reduced cost base for their new share will be $200,000, and

the post issue market value of that share will be $60,000 (section 328-465).

To claim a capital loss on subsequent disposal, Riley and Michelle would need to establish that the loss is

attributable to something other than the roll-over transaction which includes, relevantly, the issue of the

shares and allocation of a $200,000 reduced cost base for those shares.

As the difference of $140,000 between the market value and the cost base of each share is attributable to

the roll-over transaction, Riley and Michelle will be unable to claim a loss to that extent on any subsequent

disposal of the shares.

Applying the New 1 July Small Business CGT Rollover Rules ...€¦ · growth, innovation, reducing...

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