Legal updates: £462k tax relief refused as company sale breaches conditions

26 Oct 2026

Sophie Brooks and Debbie Shaw assess the tax tribunal decision on business asset disposal relief (BADR) in Poznic, transfer of intellectual property in Garden House Software, retirement exit letters in Evans, and FCA warning on exaggerated disclosures

Tax relief denied where shareholder could not prove 5% voting rights

The First Tier Tribunal (FTT) decision in Katarina Poznic v HMRC [2026] UKFTT 1298 (TC) is a reminder that eligibility for business asset disposal relief (BADR) depends on satisfying the statutory conditions and being able to prove that those conditions were met. The tribunal dismissed the taxpayer’s appeal after concluding that the shares she sold did not carry the voting rights required for BADR.

BADR conditions