Introductory tax guides

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This subtopic contains introductory guides to the main taxes and tax concepts which are relevant for Private Client practitioners. Previously referred to as Quick Tax Guides, each guide is intended to be an introduction to the key aspects of a particular tax and its applications, as well as compliance aspects.

Inheritance tax (IHT)

The most common incidence of IHT is on the deemed transfer of value that takes place on a person's death. IHT may also be payable on certain lifetime transactions (such as transfers into trust). For a UK domiciled individual, IHT is payable on worldwide assets (with credit for tax paid overseas), whereas a non-UK domiciled individual will, in general and subject to exceptions, only pay tax on assets situated in the UK. The concept of domicile is critical to the scope of IHT.

There are a variety of reliefs and exemptions from IHT, including business property relief, agricultural property relief, normal expenditure out of surplus income, quick succession relief, taper relief and the annual exemption. Furthermore, liabilities and debts may reduce IHT payable.

For a full overview of IHT (including compliance aspects), see Practice

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Latest Private Client News

Upper Tribunal rules on application of purpose tests in the context of Transactions in Securities regime (Osmond and Allen v HMRC)

Tax analysis: In Osmond and Allen v HMRC, the Upper Tribunal (UT) allowed the taxpayers’ appeal, holding that they did not necessarily have a main purpose of obtaining ‘an income tax advantage’ under the Transactions in Securities (TIS) regime simply by virtue of having a main purpose of obtaining the benefit of Enterprise Investment Scheme (EIS) disposal relief. Obtaining EIS relief from capital gains tax created an ‘income tax advantage’ for the purposes of section 687 of the Income Tax Act 2007 (ITA 2007). The First-tier Tax Tribunal (FTT) found as a matter of fact that the taxpayers did not have the subjective purpose of obtaining this income tax advantage. Surprisingly, however, the FTT held that because they had a main purpose of obtaining the EIS benefit (notably, a capital gains tax), it followed that they had a main purpose of obtaining an income tax advantage. Concluding that the FTT had erred as a matter of law, the UT held that the taxpayers’ desire to crystallise their EIS disposal relief did not mean that they necessarily had a main purpose of obtaining an income tax advantage. Written by Susanna Breslin, barrister at 11 New Square.

The Supreme Court tweaks Etridge (Waller Edwards v One Savings Bank plc)

Property Disputes analysis: English property law periodically produces epoch-making decisions of the highest court. In years to come, Waller Edwards v One Savings Bank plc may well become such a decision. It enjoys the respectable jurisprudential lineage of three famous House of Lords’ decisions: Barclays Bank v O’Brien, CIBC Mortgages v Pitt, and Royal Bank of Scotland v Etridge, but it also applies established principles in a novel way. Written by Marc Beaumont, Windsor Chambers.

OSCR announces new trustee information requirements under Scottish charity law reforms

The Office of the Scottish Charity Regulator (OSCR) has announced new requirements for Scottish charities to submit detailed trustee information through OSCR Online from 30 June 2025, as mandated by the Charities (Regulation and Administration) (Scotland) Act 2023 (C(RA)(S)A 2023). Under these new requirements, charities must submit comprehensive trustee details—including full name, home address, email address, telephone number, date of birth, and date of original appointment—through designated OSCR Online charity users. This information is vital for OSCR’s regulatory oversight, with the data being securely stored for two years after a trustee’s departure. From early 2026, only the first and last names of trustees will be published on the Scottish Charity Register, unless an exemption is granted for personal safety or security concerns.

Scottish Government launches consultation on SCIO dissolution regulation amendments

The Office of the Scottish Charity Regulator (OSCR) has announced the launch of the Scottish government's consultation to amend the Scottish Charitable Incorporated Organisation (SCIO) Dissolution Regulations. The proposed changes stem from recommendations made by the SCIO Dissolution Working Group in 2020 and include new powers for the OSCR to remove non-compliant SCIOs without court intervention, streamlined dissolution processing, enhanced creditor protections, and provisions for restoring dissolved SCIOs. A significant aspect of the amendments focuses on risk mitigation, with measures designed to ensure dissolution processes reach their intended conclusion. This addresses previous concerns about incomplete or abandoned procedures that could leave stakeholders in legal limbo. The consultation runs until 11 September 2025 and OSCR encourages all stakeholders—including charity trustees, legal professionals, and third-sector organisations—to contribute their views on these proposed changes before the September deadline.

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