Andrew Goldstone and Jonathan S. Betesh (Mishcon de Reya) review recent tax developments affecting private clients.
Routier: legacy to Jersey trust is IHT exempt
The appellants in Routier and another v HMRC [2019] UKSC 43 were the executors of Mrs Beryl Coulter who established a charity under her will to build homes for the elderly in Jersey. The issue was whether the deceased’s UK assets that passed to the Jersey charity should qualify for the IHT charity exemption. The key question was whether a movement of capital between the UK and Jersey should be regarded as an internal transaction taking place within a single member state for the purposes of article 56 of the EU Treaty and if not whether the refusal of relief under IHTA 1984 s 23 is justifiable under EU law.
It was held that...
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Andrew Goldstone and Jonathan S. Betesh (Mishcon de Reya) review recent tax developments affecting private clients.
Routier: legacy to Jersey trust is IHT exempt
The appellants in Routier and another v HMRC [2019] UKSC 43 were the executors of Mrs Beryl Coulter who established a charity under her will to build homes for the elderly in Jersey. The issue was whether the deceased’s UK assets that passed to the Jersey charity should qualify for the IHT charity exemption. The key question was whether a movement of capital between the UK and Jersey should be regarded as an internal transaction taking place within a single member state for the purposes of article 56 of the EU Treaty and if not whether the refusal of relief under IHTA 1984 s 23 is justifiable under EU law.
It was held that...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
