In this month’s briefing, Andrew Goldstone and Stuart Crippin (Mishcon de Reya) review the key developments in the private client arena, including setting aside a trust which had triggered unexpected tax charges; the availability of entrepreneurs’ relief on the disposal of an asset used in a business; the accelerated payment notices regime; Samarkand and HMRC guidance; and a case highlighting the investment nature of furnished holiday lets.
found that a trust may be rescinded if: (i) the settlor in question had mistakenly thought that setting up the trust would not incur any tax charge; and (ii) the trust was not set up in order to avoid tax.
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