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Before addressing taxation issues, timing requires some mention of the so-called ‘Panama papers’.

Consider this scenario: a recently retired couple sell their family home for £1m with a view to downsizing.

Imagine the following scenario: Stuart and Jean are married and live in York. Stuart is self-employed and works from home traveling to clients in his capacity as a consulting engineer.

The decision in The Queen on the Application of Mr De Silva and Anr v The Commissioners for Her Majesty’s Revenue and Customs has received very little professional comment.

A regular theme of reports by the Office of Tax Simplification (OTS) has been that life would be simpler if income tax/PAYE (IT) and national insurance contributions (NICs) were brought together.

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Background

There has been a raft of changes to the taxation of residential property in recent years.

Extra statutory concession D33 was published in 1988 following the judgment in Zim Properties Ltd v Proctor [58 TC 371].

Business Investment Relief (BIR) is a generous tax relief that is available to non-UK domiciled and UK resident non-domiciled taxpayers who are or have been remittance basis users.

It is some eight years since the government announced the intended introduction of CGT Entrepreneurs’ Relief (‘ER’). Little did we know how important a relief it would become.