2021–22—Budget and Finance Bill

ARCHIVED This archived Overview draws together content on the fiscal events throughout the tax year 2021–22 starting with the publication of draft provisions for the Finance Bill 2022 (FB 2022) to the passage through parliament of the Finance Act 2022 (FA 2022). It is not maintained and is for background information only. For more information on the annual Budget and Finance Bill process, see Practice Note: The Budget and Finance Bill process.

All the analysis produced in this topic will be collected in Practice Note: 2021–22—Budget and Finance Bill—Private client analysis.

Finance Act 2022

FB 2022 (officially known as the Finance (No 2) Bill, because it

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All in? Court confirms when a settlement is 'made' for the purposes of excluded property (Accuro Trust (Switzerland) SA v The Commissioners for HMRC)

Private Client analysis: This case considered the meaning of 'relevant property' under the settlements regime of the Inheritance Tax Act 1984 (IHTA 1984) and, in particular, the time at which this definition is to be tested. The question arose as to whether the trustees of an offshore trust established by a non-UK domiciled settlor were subject to the UK settlements regime in respect of property added to the trust after the settlor became deemed domiciled in the UK, or whether they were exempt from such charges as the trust consisted solely of excluded property. The First-tier Tribunal (FTT) held that whether trust property is excluded property is based on the status of the trust at the time that it was established, not at the time that the property in question was added to the settlement. As a result, the trust in this case did consist solely of excluded property and no inheritance tax (IHT) charges arose as a result of either the ten-year anniversary or capital distributions. The FTT was also asked to consider whether their jurisdiction was appellate, or supervisory only. The FTT held that, while their jurisdiction was supervisory, the questions raised by the trustees were relevant in establishing whether HMRC had acted reasonably and that the outcome (ie that the paid IHT should be refunded and that no further IHT was due) would be the same in either case. Written by Katherine Willmott, senior associate solicitor at Foot Anstey LLP.

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