While the UK remains a member of the EU it has to abide by EU treaty provisions. In addition depending on whether a deal is agreed the UK may have to abide by EU law for some years to come. As such FA 2019 s 22 and Sch 7 have been enacted in response to the CJEU finding against the UK in Trustees of the P Panayi Accumulation & Maintenance Settlements (Case C-646/15). The CJEU held that:
Schedule 7 introduces Sch 3ZAA (CGT exit charge payment plans) into TMA 1970.
The actual charging legislation is unchanged...
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While the UK remains a member of the EU it has to abide by EU treaty provisions. In addition depending on whether a deal is agreed the UK may have to abide by EU law for some years to come. As such FA 2019 s 22 and Sch 7 have been enacted in response to the CJEU finding against the UK in Trustees of the P Panayi Accumulation & Maintenance Settlements (Case C-646/15). The CJEU held that:
Schedule 7 introduces Sch 3ZAA (CGT exit charge payment plans) into TMA 1970.
The actual charging legislation is unchanged...
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