Private client review for October 2023
This month, we comment on the BlueCrest salaried members case, with the Upper Tribunal’s decision offering reassurance to LLP members who have significant autonomy in managing aspects of their business. Three further victories for HMRC in relation to SDLT (Kozlowski, Espalier Ventures and Henderson Acquisitions Ltd) serve as a reminder that any taxpayer claims for lower rates will be scrutinised very carefully. Three recent taxpayer wins (in Magic Carpets (Commercial) Ltd, Gopaul and Derrida Holdings Ltd) illustrate the importance of causation and procedure in the context of penalties. Finally, we look at the IFS’ recent report on inheritance tax and consider the possibility of future reforms.