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Upper Tribunal held the UK exit-tax payment rules could be read to allow five annual instalments, but it erred in excluding interest.
ESC B18 (1999) does not impose a six-year income limit on credit claims by UK beneficiaries of non-resident trusts; the concession is not ambiguous or qualified in this respect, and the relevant conditions are those expressly stated in the section relating to UK beneficiaries of non-resident trusts.
Source excerpt
Murphy & Anor v Revenue And Customs [2023] EWCA Civ 497 (15 May 2023)
The Court of Appeal held that ESC B18(1999) does not impose a six-year limit on credit claims by UK beneficiaries of non-resident trusts.
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