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Private client review for September 2019

Speed read
In Quentin Skinner, HMRC lost in its attempt to interpret the entrepreneurs’ relief conditions as requiring a trust to have a ‘qualifying beneficiary’ for a set minimum period in order to qualify for relief. In Estera Trust, the High Court refused to order that an acquisition of shares from trustees be structured so as to implement a perceived tax avoidance scheme for the benefit of the trust. In Hyman, the FTT held that ‘grounds and gardens’ have a wide meaning for the purposes of the definition of residential property in the SDLT context. In Fitzjohn, the FTT recognised that a taxpayer must have an intention to permanently occupy in order to benefit from principal private residence relief. In Hunt, the taxpayer was granted relief for capital losses on a payment of a guarantee as the FTT held that the business in which he had invested had commenced trading activities.

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