Private client review for March
This month, we comment on the recent decision in Haworth, which looks at the interpretation of the "place of effective management" tie-breaker residence test for corporate trustees. When disposing of foreign assets, exchange rate fluctuations may mean that the CGT charge does not reflect the true economic outcome of the transaction, as illustrated by a recent FTT decision.
There is success for HMRC in a recent "mixed property" SDLT case. Updated HMRC guidance on the meaning of "substantial" may well prove to be a double-edged sword for taxpayers looking to claim BADR. Finally, taxpayers are reminded to take a careful, measured approach to the valuation of gifts of qualifying investments to charity.