Andrew Goldstone and Alexander Makinson (Mishcon de Reya) review the latest tax developments affecting private clients.
Quentin Skinner: not much skin in the game needed for ER?
In The Quentin Skinner 2005 Settlement L and others v HMRC [2019] UKFTT 516 (TC) the First-tier Tribunal (FTT) found that entrepreneurs’ relief was available to the appellant trustees (T) where the beneficiaries of three trusts each had interests in possession in the respective trusts. In the absence of an express intention of Parliament to impose a condition there was no requirement for the beneficiaries to be a ‘qualifying beneficiary’ for a period of one year ending not earlier than three years before the date of disposal of the shares.
Three beneficiaries of three trusts were given respective interests in possession in the whole of each settlement in July 2015. By deed of...
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Andrew Goldstone and Alexander Makinson (Mishcon de Reya) review the latest tax developments affecting private clients.
Quentin Skinner: not much skin in the game needed for ER?
In The Quentin Skinner 2005 Settlement L and others v HMRC [2019] UKFTT 516 (TC) the First-tier Tribunal (FTT) found that entrepreneurs’ relief was available to the appellant trustees (T) where the beneficiaries of three trusts each had interests in possession in the respective trusts. In the absence of an express intention of Parliament to impose a condition there was no requirement for the beneficiaries to be a ‘qualifying beneficiary’ for a period of one year ending not earlier than three years before the date of disposal of the shares.
Three beneficiaries of three trusts were given respective interests in possession in the whole of each settlement in July 2015. By deed of...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
