Private client review for February

This month, we comment on the ramifications of the recent decision in Embiricos, where the Court of Appeal confirmed that HMRC has no power to issue a partial closure notice in respect of a remittance basis claim without specifying the increased tax due. Economic substance rules in offshore jurisdictions are widening again, with the European Commission targeting a similar regime in the EU. Two recent SDLT cases looking at multiple dwellings relief, together with a government consultation, suggest that this area is ripe for reform, while a PPR case serves as a reminder that the ‘quality’ of a taxpayer’s occupation of a property is a key component in applying the relief. Finally, guidance is developing in relation to the upgraded trust registration service.