Charles Cooper | Barrister

Category: Tax

  • Butler & Ors v. HMRC [2023] UKFTT 00872 (TC)

    Butler & Ors v. HMRC [2023] UKFTT 00872 (TC)

    Where catering is provided by a separate business, a wedding venue is ‘predominantly for the purpose of holding its property as an investment’ and Business Property Relief does not apply for Inheritance Tax purposes: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2023/872

    Read more: Butler & Ors v. HMRC [2023] UKFTT 00872 (TC)
  • HMRC v. A Taxpayer [2023] UKUT 182 (TCC)

    HMRC v. A Taxpayer [2023] UKUT 182 (TCC)

    Moral obligations are not ‘exceptional circumstances’ when calculating the number of days in the UK for the purposes of the ‘Statutory Residence Test’ for tax under Sch.4 Finance Act 2013, and objectively commonplace circumstances do not become ‘exceptional’ by adding a moral obligation: https://caselaw.nationalarchives.gov.uk/ukut/tcc/2023/182

    Read more: HMRC v. A Taxpayer [2023] UKUT 182 (TCC)
  • Shah [2023] UKFTT 00539 (TC)

    Shah [2023] UKFTT 00539 (TC)

    Domicile of choice in England acquired and not abandoned after gaining British citizenship, settling in England, and ‘retaining limited connections with modern India’, even though the Wills declared a domicile in India, only £680k of the £2.48M estate was situated in the UK, and the deceased had expressed an intention to leave the UK: https://financeandtax.decisions.tribunals.gov.uk//judgmentfiles/j12757/TC%2008842.pdf

    Read more: Shah [2023] UKFTT 00539 (TC)