Charles Cooper | Barrister

Category: Tax

Wood v. HMRC [2026] UKFTT 589 (TC)

Considering the decision in HMRC v. Parry [2020] UKSC 35, while the subjective intentions of the donor are relevant to determining whether s.10(1) Inheritance Tax Act 1984 (dispositions not intended to confer gratuitous benefit) applies, donations to further a political objective are still transfers of value and subject to Inheritance Tax – a donor ‘…cannot…
Read more: Wood v. HMRC [2026] UKFTT 589 (TC)
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)