Tax – Charles Cooper

Lexgreen Services Ltd v. HMRC [2025] UKFTT 1019 (TC)

A company that has made contributions to a trust can be liable for any Inheritance Tax arising on the 10 year anniversary of that trust by virtue of s.201(1)(d) IHTA 1984 ‘if that company is a live company at the time of the relevant transfer’: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2025/1019
Read more: Lexgreen Services Ltd v. HMRC [2025] UKFTT 1019 (TC)
Beresford (Dec’d) v. HMRC [2024] UKFTT 952 (TC)

The frequency of transactions for serviced office lets were ‘clearly not analogous to a hotel business’ and the business amounted to ‘wholly or mainly making or holding of investments’ for Inheritance Tax Business Property Relief: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2024/952
Read more: Beresford (Dec’d) v. HMRC [2024] UKFTT 952 (TC)
Demetriou & Anor v. HMRC [2024] UKFTT 830 (TC)

A managed chalk stream trout fishery ‘was mainly a business of holding investments’ and does not benefit from Inheritance Tax Business Property Relief under s.104 ITA 1984: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2024/830
Read more: Demetriou & Anor v. HMRC [2024] UKFTT 830 (TC)

Charles Cooper | Barrister