HMRC Used Wrong Standard In $42M Dispute, Top Court Says

Law360 (July 2, 2021, 4:04 PM EDT) -- HM Revenue & Customs used the wrong legal standard when rejecting a taxpayer's contention that an estate was managed outside the U.K. and subjecting it to £30.8 million ($42.5 million) in estate tax, the U.K. Supreme Court ruled Friday.

HMRC failed to consider the correct standard — whether prior legal precedent dictated that the Haworth family estate could be managed from the African country of Mauritius — in evaluating the estate, the high court held.

The case dealt with interpreting the "follower notice" regime contained in part four of the Finance Act 2014, according to court documents. Under the regime, if...

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