Table of contents
- 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.
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