Private client review for September

This month, we report on forthcoming changes to the capital gains tax rules on transfers of property between separating spouses and civil partners.

Jenner provides a useful reminder that any information requested by HMRC in an information notice must be "reasonably required" to check the taxpayer’s tax position.

In Firth, the taxpayers fail to persuade the FTT that their interest in an "aparthotel" business qualified for BPR. The UT also clarifies, in Priory London Ltd and Jocoguma Properties Ltd, that notices of daily penalties for the late filing of ATED returns can be issued retrospectively.

Finally, we comment on the launch of the new register of overseas entities and its interaction with the Trust Registration Service.

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