Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Panayi: conforming interpretation of exit tax rules
In The Trustees of the P Panayi Trusts [2019] UKFTT 622 the First-tier Tribunal (FTT) had to apply the CJEU’s ruling that the exit charge on trustees relocating from the UK contained in TCGA 1992 s 80 was incompatible with EU law where trustees relocated to another EU member state because there was no possibility of deferral of the tax charge.
In Panayi shares had been sold by the trustees in December 2005 which was before the date for payment of the exit charge under UK law (31 January 2006) a fact pattern which has not arisen in previous cases before the CJEU which have concerned the taxation of latent gains before actual realisation. The CJEU ruled in line...
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Panayi: conforming interpretation of exit tax rules
In The Trustees of the P Panayi Trusts [2019] UKFTT 622 the First-tier Tribunal (FTT) had to apply the CJEU’s ruling that the exit charge on trustees relocating from the UK contained in TCGA 1992 s 80 was incompatible with EU law where trustees relocated to another EU member state because there was no possibility of deferral of the tax charge.
In Panayi shares had been sold by the trustees in December 2005 which was before the date for payment of the exit charge under UK law (31 January 2006) a fact pattern which has not arisen in previous cases before the CJEU which have concerned the taxation of latent gains before actual realisation. The CJEU ruled in line...
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:
