Private client review for April 2023

02 May 2023

In this article, the April monthly update review for Tax Journal, Edward Reed and Hannah Kalveks look at a number of private client developments.

There have been two further victories for HMRC in SDLT "mixed-use" rates cases. The FTT decision in Vekaria demonstrates the importance of following correct procedure in HMRC enquiries. We revisit the popular topics of disclosure in HMRC investigations, considering the case of Mitchell, in which the Court of Appeal found that HMRC had discretion to disclose documents pertaining to one taxpayer to another taxpayer, and the decision in Hitchins where the FTT held that HMRC’s remaining questions were "fishing expeditions" and ordered HMRC to issue closure notices. Finally, we comment on the positive CGT developments for separating couples introduced by the Spring Finance Bill.

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