Pride v Commissioners for HMRC [2023] WTLR 1109

Wills & Trusts Law Reports | Autumn 2023 #192

The appeal was brought by Mr Pride in his capacity as executor of the estate of Geraldine Jill Price (deceased) (Mrs Pride) against notices of determination issued by HMRC on 18 October 2018. Immediately before her death Mrs Pride was the principal beneficiary of a family trust established on 10 October 2002 (the property trust). Immediately prior to Mrs Pride’s death the property trust:

  1. (1) held a property in Poole (the flat), which was leased to an unrelated party;
  2. (2) was the provider of an indemnity to St James’ Place Corporate Nominee Ltd (the nominee), which h...