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Entrepreneurs’ relief and trusts (HMRC v The Quentin Skinner 2005 Settlement L and others)

Entrepreneurs’ relief and trusts (HMRC v The Quentin Skinner 2005 Settlement L and others)
Published on: 23 February 2021
Published by: LexisPSL
  • Entrepreneurs’ relief and trusts (HMRC v The Quentin Skinner 2005 Settlement L and others)
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Article summary

Tax analysis: In HMRC v The Quentin Skinner 2005 Settlement L and others the Upper Tribunal (UT) allowed HMRC’s appeal against a First-tier Tax Tribunal (FTT) decision, finding a number of errors in law. The UT found that section 169J of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) does require a beneficiary to have been a qualifying beneficiary throughout the period of one year ending not earlier than three years before the disposal. or take a trial to read the full analysis.

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