- Brexit charge: (Trustees of P Panayi Accumulation & Maintenance Settlements v HMRC)
- Original news
- What is the background to this case? What were the key issues?
- Why is the case important for practitioners?
- Where does this judgment leave the law in this area?
- What are the immediate practical implications of the judgment?
- What should practitioners be mindful of when advising in this area?
Private Client analysis: A judgment from the Court of Justice of the European Union gives tax practitioners new clarity concerning section 80 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992). Reflecting on the principles of freedom of establishment and the relevance of the ruling post-Brexit, James Austen, senior associate at Charles Russell Speechlys, assesses the key points for lawyers and trustees.
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