ARTICLE
25 September 2023

Private Client Review For September 2023

M
Macfarlanes LLP

Contributor

We are a London-based law firm, built and shaped around the needs of our clients. Our blend of expertise, agility and culture means we have the flexibility to meet our clients’ most challenging demands and to champion innovation. We operate in three broad areas: assisting clients with their major transactions, from complex M&A and real estate transactions to the creation of sophisticated financial products; aiding our clients with their most consequential litigation and investigations; and advising on all aspects of our clients’ private capital needs, working with asset managers, family offices and individual entrepreneurs. The scope of our services is distinct, and we are a foremost firm in each of these areas.
In this article, the September monthly update for Tax Journal, Edward Reed and Kathryn Hart look at a number of private client developments.
United Kingdom Tax

In this article, the September monthly update for Tax Journal, Edward Reed and Kathryn Hart look at a number of private client developments.

This month, we report two recent cases, Shah and Strachan, which serve as a reminder that domicile claims may lead to detailed scrutiny of a taxpayer's personal affairs in a public forum. Recent taxpayer statistics highlight that HMRC are netting record amounts of inheritance and capital gains tax, whilst the "tax gap" and the number of "non-dom" taxpayers remain relatively steady. The much-reported case ofA Taxpayerindicates that sufficient evidence is key in a taxpayer successfully establishing "exceptional circumstances" under the statutory residence test and on this topic, HMRC are closely scrutinising related claims from the Covid era. Finally, the cases of Vision HR Solutions Ltd and Stenhouse serve as reminders that permission for judicial review is not easily granted by the tribunal.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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