Inheritance tax

Inheritance tax

FORTHCOMING CHANGE: The newly elected Labour government announced on 29 July 2024 that it intends to replace the current (2024–25) domiciled-based assessment of inheritance tax (IHT) with a new residence-based system from 6 April 2025, which would bring non-UK assets within the scope of IHT if the owner has been resident in the UK for ten tax years and keep them within the charge to IHT for between three and nine years after that person ceases to be UK resident. Details of the new rules were published in the Budget on 30 October 2024 (Autumn Budget 2024). See paragraph 5.51 of Autumn Budget 2024 and Technical Note: Reforming the taxation of non-UK domiciled individuals.

FORTHCOMING CHANGE: In the Budget on 30 October 2024 (Autumn Budget 2024), the Chancellor of the Exchequer announced that business property relief (BPR) at the current rate of relief of 100%, which applies to the value of certain types of property, will be limited to the first £1 million of that value and the remainder will receive relief at only 50%. If the taxpayer, or the estate of the taxpayer,

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Latest Private Client News

Private Client weekly highlights—6 March 2025

This week’s edition of Private Client highlights includes: (1) HMRC launches consultation on reforms to agricultural property relief and business property relief and their application in relation to trusts; (2) Companies House publishes guidance on how to protect personal details on the Register of Overseas Entities; (3) CIOT’s Finance Bill 2024–25 briefing on the non-dom changes; (4) OSCR updates guidance on charity trustee disqualification; (5) Fane v Wellesley, where the court interpreted 'privileged relation' in company articles and shareholders' agreement to exclude a former spouse of a member; (6) Mond v Charity Commissioner for England and Wales, which concerned an appeal against a Charity Commission decision to disqualify the appellant from being a charitable trustee based on social media comments, and (7) the Finance Bill passing the House of Commons and becoming ‘substantively enacted’.

Disqualification from being a charitable trustee based on social media comments (Mond v Charity Commissioner for England and Wales)

Private Client analysis: The case concerned an appeal by the appellant (‘Mr Mond) from an order of the Charity Commissioner for England and Wales (‘the Commission’) disqualifying Mr Mond from being a charity trustee or trustee of a charity. This was in exercise of the Commission’s powers under section 181A of the Charities Act 2011 (CA 2011). CA 2011, s 181A gives the Commission power to disqualify a person from being a charitee trustee or trustee of a charitee in relation to all charities or in relation to such charities or classes of charity as may be specified. The basis of Mr Mond’s disqualification had been four social media posts. In allowing the appeal, the tribunal considered the nature of the social media posts, the conduct of Mr Mond and his rights to freedom of expression under Article 10 of the European Convention on Human Rights. Written by Lynne Counsell, barrister at Addington Chambers.

Question of the week: Can a sole trustee exercise power of advancement under STEP provisions?

This Q&A considers whether a sole trustee can exercise power of advancement under STEP provisions.

Court of Appeal considers further procedural issues in relation to double tax relief for foreign dividends (HMRC v Appellants in the Post Prudential Closure Notice Group)

Tax analysis: In HMRC v Appellants in the Post Prudential Closure Notice Group, the Court of Appeal considered a number of procedural issues relating to the ongoing group litigation on the pre-2009 dividend regime which contravened EU law.