September - Private Client Briefing from Tax Journal
Tax Journal
29 September 2017

September - Private Client Briefing from Tax Journal

The publication of Finance Bill 2017 (which reintroduces heldover rules on non-doms) is followed by the release of draft anti-avoidance rules on offshore trusts for inclusion in Finance Bill 2018.  The GAAR panel publishes its first opinion.  In Vigne, the First-tier Tribunal clarifies how it considers the business property relief ‘wholly or mainly’ test on businesses involving land. In X-Wind Power Ltd, the Upper Tribunal (UT) confirms that  using the wrong form for seed enterprise investment scheme relief is fatal. In Morrison, the UT affirmed that disposals of listed shares on the market can still constitute pre-ordained composite transactions for CGT.  HMRC publishes guidance on trustee tax returns and on the residence nil rate band when downsizing.

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