Private client review for October 2022

This month, we comment (briefly) on the recent ‘mini-Budget’, ensuing economic turmoil and the government’s subsequent U-turns, leaving taxpayers with uncertainty as to the future fiscal landscape.  HMRC has demonstrated its use of data from other government departments in their latest ‘nudge letter’ campaign. Two recent cases – Harrison and Watt – throw light on the tribunals’ (contrasting) approach to assessing ‘reasonable excuse’ regarding the late filing of personal tax returns. The Court of Appeal’s recent decision in Skinner confirms that entrepreneurs’ relief can apply even if a trust beneficiary’s life interest in the business asset being disposed of has existed for a very brief period. Finally, the FTT’s decision in Sehgal merits detailed study for any remittance basis taxpayers entering into agreements which have a connection to the UK.