UK tax update April 2024

24 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).