Sam Hart looks at the rules around when trustees can get business asset disposal relief, and how a recent flip-flopping tax case actually gave some good insight into how the courts interpret tax legislation.
Tax advisers get excited about the strangest things (principal private residence relief, anyone?) and trust practitioners are even worse (pre-2006 A&M trust? Yes please!) Sometimes though, we get a tax and trust case that is so controversial, the judgment completely flipped as it passed through the courts and tribunal system.
The Skinner situation
The facts in the Skinner case were not disputed. Three trusts were established by Mr Skinner in 2005, each for the benefit of one of his sons.
The beneficiaries were given respective interests in possession in the whole of each settlement in July 2015.
The settlor then gave 55
