News

In order for the dwelling house to be a valid residence for PPR relief, from 6 April 2015, there is a statutory condition that must be fulfilled and is assessed every tax year from 2015/16 onwards. This anti-avoidance rule was introduced as part of the NRCGT rules. Any tax year which is ‘non-qualifying’ is treated...

A common source of confusion amongst clients is the difference between mutual wills and mirror wills. Both have distinct legal implications that can significantly impact your clients wishes. Mirror Wills are two almost identical wills typically created by long-term partners or spouses, where each person leaves their estate on the same terms, usually to each...

HMRC’s annual ‘compliance yield’ from wealthy taxpayers more than doubled from GBP2.2 billion in the 2019/20 tax year to GBP5.2 billion in 2023/24, according to a report from the government’s National Audit Office (NAO). The NAO says the large increase suggests that underlying levels of non-compliance among the wealthy population could be greater than previously...

A woman who lived rent-free in a house settled in an offshore trust by her late husband was liable to GBP163,414 income tax under the transfer of assets abroad (TOAA) legislation even though she was not the transferor, the First-tier Tax Tribunal has ruled (Moran v HMRC, 2025 UKFTT 540 TC). It ruled that the ‘motive defence’...

A couple who bought a property for GBP9.75 million, demolished and rebuilt it, then sold it for GBP27.15 million, have won their appeal against a GBP3.3 million capital gains tax charge. Raymond and Diana Eyre successfully claimed they were not developing in the nature of a trade and the house was their principal private residence...

TAXATION: Agents given access to personal tax query resolution service HMRC’s new personal tax query resolution service for agents is now live, offering representatives a quicker way of chasing up unanswered queries to HMRC’s helplines. Before using the service, agents must check the ‘where’s my reply tool’, with at least 20 working days having passed...

TAXATION: Companies cautioned over using prepaid debit cards for tax-free profit extraction HMRC is warning companies not to use a scheme that uses advertising and marketing expenditure to reduce taxable profits and disguise employment income in the form of redeemable loyalty points. Scheme users buy advertising from the arrangement’s promoter and claim a deduction for...

VULNERABLE CLIENT: The Celebrity’s statutory will hearing cannot be published In W v P (2025 EWCOP 11 T3), the wife of a now-incapacitated celebrity (P) applied to the England and Wales Court of Protection to make a statutory will for him for estate planning purposes. She asked for the associated hearing to be held privately. The judge decided...

CONTENTIOUS ESTATES: Missing will must be presumed revoked, says EWHC The judgment in Packer v Packer (2025 EWHC 461 Ch) is the first successful application of the presumption of revocation of a will for almost two decades. It extends the scope of the presumption of due execution. Stephen Packer’s widow alleged that he died intestate; however, his sister...

The First-tier Tax Tribunal (ftt) has ruled that a rabbi who resided in the UK for most of his life, raised a family, and built up a property business in Manchester was UK-domiciled for tax purposes (Weis v HMRC, 2025 UKFTT 348 TC). He claimed he intended to make Israel his permanent home; however, the FTT found...