Key developments this month are as follows: HMRC has updated its IHT Manual in respect of specialty debts, changing its previous practice; the draft provisions in relation to the extension of CGT on high value UK residential property have been released; individuals may incur SDLT anti-avoidance charges when de-enveloping structures to avoid the new ARPT and CGT regimes; the Supreme Court has ruled that legal professional privilege does not extend outside the legal profession; HMRC has announced another settlement opportunity, this time for film production partnership schemes; and, the amendments to the transfer of assets abroad rules contain revised rules for determining the matching of ‘relevant income’ to benefits.
