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Private client review for May 2019

Recent tax developments that matter affecting private clients, reviewed by Andrew Goldstone and Katherine Forster (Mishcon de Reya).

Hargreaves : what constitutes ‘staleness’?

In Hargreaves v HMRC [2019] UKFTT 244 (TC) the First-tier Tribunal (FTT) allowed Hargreaves’ appeal against a discovery assessment that was ‘stale’ with HMRC losing out on £84m of tax.

Hargreaves filed tax returns on the basis that he had become non-UK tax resident in March 2000 two months before disposing of shares for £231m.

On moving to Monaco in March 2000 he first lived in a hotel and then briefly on his yacht before settling in a rented property.

In January 2004 after being alerted to the fact Hargreaves was working for three days a week at the firm’s UK head office...

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