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UT considers range of issues relating to share disposal (Allam v HMRC)

Published on: 01 December 2021
Published by: LexisPSL
  • UT considers range of issues relating to share disposal (Allam v HMRC)
  • Why it matters
  • Case details

Article summary

Tax analysis: In Allam, the Upper Tribunal (UT) considered a number of issues relating to a share disposal: a procedural issue relating to the validity of notices issued by automated processes; the interpretation of the trading test for the purposes of entrepreneurs’ relief (now business asset disposal relief (BADR)); the application of the remittance basis of taxing non-domiciliaries; and the purpose test in the transactions in securities rules. or take a trial to read the full analysis.

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