Commissioners for HMRC v Personal Representatives of Vigne [2023] WTLR 1259

Winter 2023 #193

The late Mrs Maureen Vigne died on 29 May 2012. At that time, she was the sole owner of approximately 30 acres of land. From 2008 a livery business was operated on or from the land, offering a package which included:

  1. (1) the provision of worming products, including administering them where and when necessary (if an owner was unable and/or unwilling so to do), on a quarterly basis;
  2. (2) providing the horses with hay feed during the winter months when the grass might not provide a sufficient food source – a hay crop was grown on part of the land, referred to as the hay...

Dunsby v Commissioners for Her Majesty’s Revenue and Customs [2021] WTLR 157

Spring 2021 #182

This was an appeal concerning a tax avoidance scheme designed to allow shareholders in private companies to extract profits without paying income tax on them.

Prior to entering into the scheme, T was sole director and shareholder of M Ltd. The scheme had three steps:

  1. (1) On 11 March 2013, the board of directors of M Ltd (ie T as sole director) and T resolved to approve the creation of a new class of ‘S’ ordinary shares and the necessary amendments to M Ltd’s articles of association. On the same day, M Ltd (by resolution of T as sole shareholder) created the new S clas...

Banks v HMRC [2020] WTLR 19

Spring 2020 #178

The appellant taxpayer, Arron Banks, appealed against a notice of determination issued by HMRC. This notice assessed Mr Banks as owing inheritance tax of £162,945.34 on donations of £976,781.38 that he and companies that he controlled made to the UK Independence Party (UKIP) between October 2014 and March 2015 (the donations).

It was common ground that no UKIP MPs were elected at the 2010 UK General Election. UKIP did not therefore meet the statutory definition under s24(2) IHTA 1984 and so the Donations were not treated as exempt from VAT. The appellant argued that this ...