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Trusts & estates
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Trusts & estates
TRUSTS ESTATES
Back to basics: SDLT and trusts
Simon Howley
When it comes to trusts, is it the trustees or the beneficiaries who are treated as the purchaser for SDLT purposes? Simon Howley (Bell Howley Perrotton) provides a refresher guide.
Remuneration trusts: the importance of facts
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in
Marlborough DP Ltd v HMRC
that suggests the shortcomings in HMRC’s general approach following
Rangers
.
Offshore trusts and onward gifts
Fiona Poole
The onwards gift rules came into effect on 6 April 2018. Fiona Poole (Maurice Turnor Gardner) navigates the legislation.
Back to basics: Employee ownership trusts
Oliver Dewdney
Oliver Dewdney (Smith & Williamson) provides a guide to this alternative
ownership structure.
The UK asset holding company regime: what’s proposed
Elena Rowlands
Cathryn Vanderspar
Ian Zeider
Elena Rowlands, Cathryn Vanderspar and Ian Zeider (Travers Smith) are hopeful that the government will seize the opportunity for positive change to support the UK’s funds industry.
5MLD: major changes to the UK trust register
Sam Epstein
Ethan Yu
Jennifer Smithson
Jennifer Smithson, Sam Epstein and Ethan Yu (Macfarlanes) set out the resulting additional compliance obligations for many trustees.
Private client review for July 2020
Annie Bouch
Andrew Goldstone
Annie Bouch and Andrew Goldstone (Mishcon de Reya) review recent tax
developments affecting private clients.
Protected settlements: tainted love
Catrin Harrison
Sophie Dworetzsky
Sophie Dworetzsky and Catrin Harrison (
Charles Russell Speechlys)
consider what is meant by ‘settlor’ in the context of the protected settlement and tainting rules.
How to handle the reservation of benefit provisions
Emma Chamberlain
The reservation of benefit legislation continues to be relevant to IHT planning, and the 2017 changes to foreign domiciliaries have extended its scope and importance. Emma Chamberlain (Pump Court Tax Chambers) provides a practical guide to navigating the rules.
Comment: How to reform inheritance tax
Emma Chamberlain
Taxing wealth better requires some radical reforms, writes Emma Chamberlain (Pump Court Tax Chambers).
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EDITOR'S PICK
Spare us the cUTTer
Nick Thornton
1 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
2 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
3 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
4 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
5 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
6 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
7 /7
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
NEWS
Read all
Foreign Permanent Establishment exemption to be made mandatory
Chancellor announces package of road fuel measures
Quarterly advisory fuel rates published
New Isle of Man social security agreement signed
Streeting proposes CGT equalisation in ‘wealth tax’ plan
CASES
Read all
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
H Gwyn-Jones v HMRC
Other cases that caught our eye: 29 May 2026
HC-One No 1 Ltd v HMRC
IN BRIEF
Read all
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
The growing problem of the personal allowance phase down
Situs: loan notes
MOST READ
Read all
HC-One No 1 Ltd v HMRC
Take 3.9 TV Partnership and others v HMRC
When Homer nods: the rise of the Inco principle in tax
The growing problem of the personal allowance phase down
Trustees IHT exposure from 6 April 2025