Wills & Trusts Law Reports | December 2013 #135The appellant appealed against a decision of the First-tier Tribunal (FTT). The issue before the FTT was whether Mrs Ramsay had transferred to TPQ Developments Ltd (TPQ) a ‘business as a going concern’ in exchange for shares issued by TPQ so as to qualify for roll-over relief under s162 Taxation of Chargeable Gains Act 1992 (TCGA 1992). The FTT found that what Mrs Ramsay had transferred to TPQ was not a business within the meaning of s162 of the TCGA 1992.
Mr and Mrs Ramsay owned a property known as Moat House in Belfast (the property). On 1...
The result of the Pawson appeal has done little to clarify the criteria for claiming BPR in the case of furnished holiday lettings, as Matthew Woods and Sophie Carter relate ‘It was understood that HMRC were awaiting the outcome of this decision before issuing determinations on a number of other claims for business property relief …
Continue reading "Business Property Relief: Scrutiny of services"
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The result of the Pawson appeal has done little to clarify the criteria for claiming BPR in the case of furnished holiday lettings, as Matthew Woods and Sophie Carter relate Interpretation of an intelligent businessman versed on all the available law begins to sound like a tribunal judge, rather than the man on the Clapham …
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James Radcliffe explains how Pawson has changed tax treatment for furnished holiday lettings ‘Whether or not accommodation is qualifying holiday accommodation under the FHL rules is not a determining factor in assessing the availability of business property relief (BPR) for the purposes of inheritance tax.’ The taxation of furnished holding letting accommodation (FHLs) has evolved …
Continue reading "Tax: Pause for thought?"
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Wills & Trusts Law Reports | May 2012 #119The appellants were the personal representatives of Nicolette Vivian Pawson (Mrs Pawson) and appealed against a notice of determination dated 1 October 2008. The notice had determined that Mrs Pawson’s 25% interest in a property known as Fairhaven, Thorpeness, Suffolk (Fairhaven) was subject to inheritance tax on a deemed disposal at the date of her death. The appellants contended that Fairhaven was entitled to relief as a relevant business property. Fairhaven was a large bungalow overlooking the sea in a holiday area. It had made a profit for each year since 2003, save for 2005/06...
