Private client review for March 2024

This month, we consider some of the key announcements in the Spring Budget relevant to private clients, including various changes to the taxation of property transactions and the abolition of the non-dom regime. We also review three recent cases which highlight some interesting procedural points in the context of challenging HMRC enquiries: in Hunt, HMRC successfully applied for the taxpayers’ appeals to be stayed behind another group of cases which involved the same key point; Smith serves as a warning that deadlines should be diarised to avoid late filings; and in Brown, the Court of Appeal confirms that HMRC could rely on an argument which they had not presented to the FTT.

Read the full article.