HMRC goes to appeal in Bower case

As detailed in the April issue of International Investment (page 13), Mrs Bower had died age 90 in 2002, shortly after setting up a discounted gift trust with a potentially exempt transfer of £73,000. While HMRC’s view was that the discount to be applied to the failed PET should be no more than £250, because someone of Mrs Bower’s age would be effectively uninsurable, Mrs Bower’s executors argued for a figure of £7,800. The Special Commissioners decided partly in favour of Mrs Bower’s executors and set a revised discount figure. However, HMRC has appealed the decision, and posted a holding...