Private client review for May 2024

In this article, the May monthly update for Tax Journal, Edward Reed and Klara Kronbergs look at a number of private client developments.

This month, we consider three recent tribunal cases concerning entrepreneurs’ relief – Stolkin, Delaney and Cooke – which indicate an HMRC focus on such claims. We also look at three recent cases involving different aspects of property ownership and associated taxes: Nunn focusing on PPR, Raveendran on resulting trusts and beneficial ownership and Herrmann on a taxpayer’s responsibilities whilst in prison. The cases of Michael and Holding evidence that SDLT mixed use claims remain fertile ground for disputes, with HMRC once again emerging victorious. Finally, we ponder what recent HMRC statistics indicating record high inheritance tax receipts might mean for the future.

Read the full article.