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Tax Aware

Issue 20: December 2023

Tax Aware

Editor's Note

Moustapha Hammoud, Associate, Mishcon Private

This Issue covers several areas within tax. First, we cover the UK tax implications of making a charitable gift to a non-UK charity and the pitfalls associated with such a step. Next, we discuss the long-awaited conclusion of the Fisher dispute and the Supreme Court's decision in favour of the individual taxpayers on the transfer of asset abroad rules.

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News

Tax planning does not equal a tax avoidance main purpose

The recent cases of Olivia Wilkinson & Ors v HMRC [2023] FTT 695 and Delinian Ltd (Formerly Euromoney Institutional Investor PLC) v HMRC [2023] EWCA Civ 1281 provide welcome guidance on when transactional tax planning might result in a taxpayer acquiring a tax avoidance main purpose.

News

Grossing- up is hard to do

It is usual for a will to provide that legacies should be made 'free of tax', meaning that the recipient receives the amount gifted in the will, without a deduction for inheritance tax (IHT).  The burden of IHT then falls on the residue of the deceased's estate.

News
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Neither gardens nor grounds

Over recent years, the Tax Tribunal has been full of cases where HMRC have challenged buyers claiming the "mixed-use" rate of Stamp Duty Land Tax (SDLT) on UK property purchases.

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