Private client review for March

This month, we comment on two victories for HMRC before the tribunal which serve as a reminder of HMRC’s increasing scepticism over claims for SDLT relief. The government confirms it will continue with its regimes for persons of significant control and the register of overseas entities, despite a recent CJEU ruling. A record number of tax returns were submitted on time this year. Another couple of wins for HMRC in relation to discovery assessments confirm that the concept of staleness (following Tooth) may in fact be dead, and also remind us that taxpayers cannot hide behind the "smokescreen" of professional advisers. Finally, a recent FTT decision (relating to an IHT scheme) illustrates that FTT decisions are not binding in other cases.

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