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Private client review for November 2019

Speed read
In Higgins v HMRC, the Court of Appeal considers when the ‘period of ownership’ begins in the context of CGT principal private residence relief for an off-plan property purchase. In Christa Ackroyd Media Ltd v HMRC, the Upper Tribunal considers how ultimate control over how an individual provides their services can result in an employment relationship. In P Panayi Accumulation & Maintenance Trusts, the FTT considers the CJEU judgment as to whether TCGA 1992 s 80 ‘exit charges’ are lawful in the context of EU freedom of establishment legislation and the extent to which a conforming interpretation is possible.

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