Private client review for February 2024

In this article, the February monthly update for Tax Journal, Edward Reed and Clare Wilson look at a number of private client developments.

This month, we consider the FTT's recent decision in Patwary and the importance of evidence when making a claim for PPR relief. In Trustees of the Peter Buckley Settlement, a failed claim for entrepreneurs' relief by trustees demonstrates the importance of checking the requirements of the relief well in advance of a disposal. Keighley and another looks at the circumstances in which another person's behaviour can be attributed to the taxpayer. Finally, we consider privacy in two contexts: first, examining the tension between open justice and privacy in respect of the taxpayer's application to have their tax appeal heard in private with an anonymised judgment, and then looking at how the UK and other jurisdictions are dealing with the tension between transparency and privacy in the context of beneficial ownership registers.

Read the full article.