IHT

Tim Lynch and Tahir Ebrahim (BDO) provide a back to basics guide.

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.

Employee benefit trust and IHT: In J McIlhone v HMRC [2026] UKFTT 995 (TC) (2 July), the FTT held that £4m appointed from an EBT to a sub-trust for one of the company’s two employees and his family ceased to qualify for the IHTA...

Donations not part of ‘normal expenditure’

Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...

Interpreting double tax treaties: Vietjet Aviation Joint Stock Company v FW Aviation (Holdings) 1 Ltd [2025] EWCA Civ 783 (24 June) concerned a commercial dispute between two parties relating to the financing of the acquisition of four jet aircraft....

IHT dispute concerning dividing estate residue: In S Changizi v P Changizi and another [2025] EWHC 735 (Ch) (2 April) is a dispute between mother and son as to how the burden of the IHT liability should be met. In this case, the English estate...

Changes to non-doms and IHT have dominated the year, but there have also been some interesting cases, write Claire Weeks and Alyssa Haggarty (Maurice Turnor Gardner).