In Hood v HMRC, the Court of Appeal decided that a mother who had granted a sub-lease to her sons had made a gift subject to a reservation of benefit because the sons had covenanted to comply with the terms of the head lease. In HMRC v The personal representatives of the estate of M Vigne, the Upper Tribunal held that the executors of an estate were justified in claiming business property relief in respect of the deceased’s livery business. In HMRC v Parry and Others, the Court of Appeal decided that a transfer of money from the deceased’s company pension scheme to her personal pension scheme six weeks before her death constituted a transfer of value for inheritance tax purposes. In PML Accounting Ltd v HMRC, the Court of Appeal rejected the taxpayer’s argument that HMRC ought to have destroyed evidence gathered by way of a supposedly invalid information notice.
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