TRUSTEES OF THE PANICO PANAYI ACCUMULATION AND MAINTENANCE SETTLEMENTS NUMBERS 1 TO 4 and REDEVCO PROPERTIES UK1 LIMITED v The Commissioners of His Majesty's Revenue and Customs [2024] UKUT 00319 (TCC)
Upper Tribunal tax and Chancery decision of MR JUSTICE RAJAH and JUDGE NICHOLAS ALEKSANDER on 08 October 2024
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CHARGEABLE GAINS – deemed disposal on ceasing to be resident in the UK and becoming resident in another EU member state – compatibility with EU freedoms – whether a conforming interpretation exists – yes - ss80 and 185 TCGA, para 10A, Sch 9, FA 96, and ss59B and 59D TMA