Private client review for July 2024
29 July 2024In this article, the July monthly update for Tax Journal, Edward Reed and Kazia Gagg look at a number of private client developments.
This month, we consider what’s in store for private clients with the new Labour Government and the likely timeline for implementation. We comment on a recent FTT decision which accepted HMRC’s broad interpretation of the remittance rules (Alimahomed). Three recent taxpayer wins in relation to SDLT (Hurst, Suterwalla and Marie Guerlain-Desai) demonstrate that, with the right fact pattern, claims for SDLT reliefs can still be successful. Finally, the FTT’s decision in Wardle illustrates the hurdles which must be overcome by the taxpayer in arguing that their business had commenced trading for the purposes of entrepreneurs’ relief.
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