Tough Line on Late Acceptance
Briggs v CEF Holdings Ltd (2017) Court of Appeal – Gross LJ & Asplin J
The Court of Appeal in Briggs held that it was important not to undermine the salutary purpose of Part 36 offers. Cases were fact-specific but the general rule under Part 36 was that if an offer was not accepted in time, the offeree will bear the costs of the offeror from the date of expiry of the relevant period and it was up to the offeree to demonstrate that it would be unjust. It was not enough to show that it had been difficult to form a view on the likely outcome of the case at the time the offer was made.
Apple and Ireland Win €13bn State Aid Appeal
The General Court of the European Union has today annulled the Commission’s decision regarding two Irish tax rulings in favour of Apple. The Commission had considered that the two rulings constituted State Aid, granting Apple €13bn in unlawful tax advantages.
The Price of Property
Helen McGhee looks at the present state of UK tax rules that must be considered when owning and disposing of UK property.
Inheritance tax problems in Finance Bill 2020
The rules on excluded property trusts are due to change with effect from royal assent. These changes are complex, and the new rules can have an unexpected and retroactive effect. Emma Chamberlain explores these rules to determine whether it may be necessary to exclude the settlor going forward as a beneficiary.
Trust Registration Service- 5MLD update
HMRC’s Trusts and Registration Service (TRS) was born back in 2017 as part of the implementation of 4MLD. 5MLD has mandated notable amendments to the operation of the TRS that clients and practitioners should not overlook. We have created a Q&A to help to navigate the new upcoming compliance obligations.