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Private client review for January 2024

PPR relief, transfer of assets abroad, information notices and the taxation of finder’s fees are among the topics in this month’s review by Edward Reed and Angus Richardson (Macfarlanes).

PPR relief: more success for taxpayers

In our November 2023 article (Tax Journal 24 November 2023) we discussed the recent taxpayer win in the case of HMRC v G Lee and another [2023] UKUT 242 (TCC) in which the UT upheld the decision of the FTT that in the context of a claim for Principal Private Residence (PPR) relief ‘period of ownership’ of a dwelling-house meant the period during which the relevant house was in existence and did not include a longer period of ownership of the land before the house was built.

Following this decision HMRC announced that they would not appeal the judgment. HMRC have now gone a step further...

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