Court rules on whether 2020 legislation for top slicing relief can apply retrospectively

Mark Battersby
clock • 4 min read

The UK's First-tier Tribunal (FTT) has held that changes made to top slicing relief for life products do not apply retrospectively in a challenge to HMRC's view on the case of Sally Judges (as representative for the late R Young) v HMRC [2022] UKFTT 77 (TC). The FTT found that the taxpayer was entitled to adopt a more beneficial method of calculating top slicing relief (TSR) and disagreed with HMRC who had argued that amendments made by the Finance Act 2020 to the Income Tax (Trading and Other Income) Act 2005 (ITTOIA), which prevented the more beneficial method of calculation being adop...

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