Clipperton & anr v HMRC WTLR(w) 2021-08

Wills & Trusts Law Reports | Web Only

The Quentin Skinner 2005 Settlement L & ors v HMRC [2019] WTLR 1389

Wills & Trusts Law Reports | Winter 2019 #177

On 1 December 2015 three settlements (“the Skinner Settlements”) disposed of 55,000 ordinary shares (“the Shares”) in a company (“the Company”) at a gain. Under each Skinner Settlement a member of the Skinner family had been given an interest in possession in the whole of the settled property on 30 July 2015.

Following the disposal of the Shares, the Skinner Settlements and their respective Beneficiaries (“the Beneficiaries”) claimed entrepreneurs ‘ relief (“ER”) under s169J of the Taxation of Chargeable Gains Act 1992 (“TCGA 1992“) applying a reduced ra...