JPHLAW Business Lawyers

Taxpayer wins SDLT dispute over manor house used as pub The buyer of a GBP1.8-million manor house has persuaded the First-tier Tax Tribunal (FTT) that the property was not wholly residential and so entitled to mixed-use relief from stamp duty land tax (SLDT). The applicant successfully argued that the property was being used as a hotel, inn or similar establishment (HISE) at the effective date of the transaction and that part of the property was leased out to a farmer for grazing. This consequently saved an additional SDLT bill of GBP47,750. However, the FTT noted it had allowed the appeal on the ‘finest of margins’, partly influenced by the COVID-19 restrictions in place at the relevant times (Hurst v HMRC, 2024 UKFTT 540 TC).

UK house prices rise by 0.8% in July The average UK house price increased by over £2,200 in July compared to June, following three months of little change, according to Halifax’s index. Property experts are optimistic about the housing market, citing the recent interest rate cut by the Bank of England as a potential boost. Amanda Bryden, head of mortgages at Halifax, stated that the average house price in the UK is now £291,268, with an annual growth rate of 2.3%. Affordability constraints and a lack of available properties continue to pose challenges for prospective homeowners. However, with lower mortgage rates and potential further rate reductions, house prices are expected to continue a modest upward trend. Separately, the Royal Institution of Chartered Surveyors said its monthly survey of estate agents pointed to “a meaningful pick-up in sales volumes going forward” in July

HMRC targets senior professionals in latest crackdown HMRC is targeting senior lawyers, accountants, architects, and their employers in its latest crackdown on the self-employed. The tax authority has adjusted its interpretation of Salaried Member Rules to determine whether senior partners at limited liability partnerships (LLPs) should be classified as employed or self-employed for tax purposes. This change could result in significant tax bills for affected individuals and their firms, said Guy Sterling of Moore Kingston Smith. The new guidance from HMRC may lead to an increase in formal enquiries and compliance activity in the coming months. Matthew Spencer at Lubbock Fine added: “These rules have been in existence for 10 years and firms have often used the capital requirement as a failsafe and adapted levels of capital as required. To now say that such adaptations falls under the anti-avoidance provisions seems like a bit of an over-reach from HMRC.

Wealthy preparing to leave UK over Labour tax fears The Telegraph reports on an uptick of wealthy individuals preparing to leave the UK ahead of Labour’s first Budget. David Lesperance, an international tax adviser, said five of his clients had already left the country while 10 others had put plans in place to do so. A hike in capital gains tax in October will lead to a “big increase” in the number of UK-domiciled clients quitting Britain, he warned. According to advisory firm Henley & Partners, a record 9,500 millionaires are forecast to leave Britain in 2024, up from 4,200 in the previous year. Elsewhere in the same paper, Ceri Volkes, a partner at Withers, explained that many wealthy people are already taking drastic measures. “I have got clients leaving the UK in order to trigger capital gains taxes at current levels of 20% on the basis that they feel the UK has become more hostile towards wealth creators,” says Volkes. “We’ve seen some clients selling a business who want the sale to go through ASAP. Accelerating, deferring and leaving - those are the main things that people are talking about at the moment,” Volkes

Britain’s IHT hot spots revealed The UK Government is set to collect £7.5bn from inheritance tax (IHT) this year, marking a 25% increase in just three years. Families residing in London and the home counties are most likely to be affected by IHT, with the largest sums coming from wealth hotspots in the capital. The Chancellor, Rachel Reeves, is under pressure to find new ways to boost government income from IHT in her upcoming Budget. Wealthy individuals are seeking advice from lawyers and accountants to explore options for passing on their wealth before any changes to IHT come into effect. A report by Kingsley Napley reveals that Chichester, Esher and Walton, and Finchley and Golders Green are among the areas with the highest number of estates paying IHT. Partner Sophie Voelcker said beyond the standard advice on reducing liabilities, clients are advised to “just spend!” Daily Express Newry tax advice from

ESTATE ADMINISTRATION: Number of estates caught by IHT continues to grow The number of deaths resulting in an inheritance tax (IHT) charge in the 2021/22 tax year rose by 3 per cent to 27,800, according to HMRC figures. This is about 4.4 per cent of total UK deaths. IHT liabilities for the year increased by 4 per cent to almost GBP6 billion. The most important IHT relief was again the spousal exemption, saving GBP15.5 billion, followed by agricultural and business property relief of GBP4.4 billion and charitable relief of GBP2.1 billion.

Brilliant win - edge of the seat excitement !

With the July holidays coming up our offices will be closed from the 11th July 2024 until the 17th July 2024.☀️🗓️

“The shorter way to do many things is to only do one thing at a time.” Mozart “If I had six hours to chop down a tree, I would spend the first four hours sharpening the axe.” Abraham Lincoln We had the pleasure of having Good Morning Britain Volunteer of the Year Lyle English attend our office by hosting a Time Management Workshop. A big thanks to Lyle for attending with us and to the Rosehip Cafe & Bakery in Banbridge for for providing us with a tray of sandwiches and treats.

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