Arabella Murphy (Maurice Turnor Gardner) considers the judgment in Bainbridge, where an application to rescind mistaken transfers of farmland to a trust was complicated by the fact that some of the land had been sold.
Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.
Given the potential tax savings and its potentially wide application, tax advisers will need to understand and advise on the new investors’ relief for investments in trading companies or trading groups, write Dipan Shah and Nick Baker (PwC).
Rescission of transfer to trust
Allowable expenditure and goodwill