Private client review for April 2024

In this article, the April monthly update for Tax Journal, Edward Reed and Sam Epstein look at a number of private client developments.

This month, we comment on another string of (mostly) HMRC SDLT tribunal victories in the familiar territory of mixed-use rates and MDR claims, considering Bonsu, Harjono, Dreyfus and a (rare) taxpayer victory in Newsand Ltd: overall, these illustrate HMRC’s continued scepticism of such claims. We also address another recurring theme of taxpayer behaviour, looking at the recent tribunal decisions in Thompson, Hague and Ahmed, which examine qualities associated with "deliberate" and "careless" behaviour. Related to this, Linington reminds us of the tribunals’ dim view of tax avoidance schemes. Finally, we discuss the recent UT decision in Sehgal, particularly, what this means for the future interpretation of "service" under the remittance basis rules.

Read the full article.