UK tax update April 2024

In this article for the April edition of French estate planning journal Ingénierie patrimoniale, Edward Reed and George Mitkov look at recent developments in the UK.

• The SKAT case: The Supreme Court has held that the claim brought by the Danish tax authority is admissible and will now be heard by the High Court, notwithstanding the so-called "revenue rule".
• Fisher v HMRC: In another Supreme Court case, the justices sided with the Fisher family in the long-running dispute centring around the transfer of assets abroad regime.
• Harber v HMRC: An otherwise unexceptional case has attracted interest on account of the claimant's reliance on a number of purported (but non-existent) cases that were hallucinated by a generative AI system.
• Lee v HMRC: The Upper Tribunal has brought some much-needed clarity on the operation of the principal private residence relief from capital gains tax.
• Tax administration and transparency: The UK tax burden continues to rise, putting pressure on HMRC's helplines; and a map showing the locations of UK properties owned by overseas entities has been created.

Read the full article (this content sits behind a paywall).