2013–14—Autumn Statement to Finance Bill

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This subtopic draws together content on the Finance Bill year 2013/14, ie starting with the Autumn Statement given in December 2013 and following through to the Budget in March 2014, the draft provisions of the Finance Bill and the passage through parliament of the Finance Bill 2014.

Finance Act 2014

The Finance Bill 2014 received Royal Assent on 17 July 2014: Finance Act 2014.

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Question of the week: On a subsequent sale (within one year of the deceased's death), what would be the acquisition value for capital gains tax (CGT) purposes of a shareholding in the deceased's estate where the original shares were mistakenly (against the executors' instructions) sold by the investment advisor and identical shares were then repurchased by the adviser (all within one year of the deceased's death) who covered the increase in share price so that the estate did not suffer loss? (This impacts the value for IHT purposes and whether or not an IHT35 should be submitted for loss on sale of shares relief)

This Q&A considers the CGT and IHT treatment where shares in a deceased's estate are sold (by mistake) and then replacement shares acquired, and those replacement shares then sold, all within one year of the deceased's death.

UK Finance publishes updated estate administration banking protocol

UK Finance has published an updated Estate Administration Banking Protocol for England and Wales to replace the 2012 version. The protocol provides a single, consistent framework for interactions between financial services firms and Probate Practitioners, setting out the documentation required to confirm death, identify accounts and verify a practitioner’s regulatory status, as well as the information practitioners must supply to demonstrate authority to act. Developed with approved legal regulators and aligned with wider bereavement support requirements, it is intended to ensure probate‑related processes are clear, efficient and sensitive while maintaining appropriate regulatory oversight.

UT decides that neither estoppel by convention nor legitimate expectation prevented NICs charge (MWL International Ltd and another v HMRC)

Tax analysis: In MWL International Ltd and another v HMRC, the Upper Tribunal (UT) dismissed the companies’ appeals against HMRC’s decision that Class 1A National Insurance contributions (NICs) were due in respect of cars leased by the companies and used by employees. The UT found that HMRC was not prevented by estoppel by convention from departing from a 1993 agreement that the cars were pooled cars, and that the companies could not rely on a legitimate expectation that the cars would be treated as pooled cars.

The Property (Digital Assets etc) Act 2025—The future is here to stay

Private Client analysis: The widely anticipated Property (Digital Assets etc) Act 2025 (‘the Digital Assets Act 2025’) received Royal Assent on 2 December 2025 which has, at least in England, Wales and Northern Ireland, cleared the pathway for the potential treatment of digital assets and technologies such as crypto-currencies as objects of personal property rights. The word potential is used above because the question of whether or not certain digital assets and technologies ought to be treated as objects of personal property rights is to be left to the courts. In the context of an ever-changing technological landscape, an incremental development of the common law in this respect is the safe and correct option as explained further below. Written by Raghav Trivedi, a barrister from St Philips Chambers in Birmingham

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