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Routier and EU provisions and inheritance tax

11 December 2019 / Helen Ratcliffe
Issue: 4724 / Categories: Comment & Analysis
12613
A matter of interpretation

 

On 16 October 2019 the Supreme Court issued its judgment in Routier and another v CRC [2019] UKSC 43 the case having previously been heard in the Court of Appeal ([2017] EWCA Civ 1584). The case the arguments raised and the judgment provide the private client practitioner with valuable insights into the interaction of domestic legislation and EU principles in the context of inheritance tax.

 

The facts

Mrs Beryl Coulter died in Jersey in October 2007 leaving her residuary estate (which included UK assets) on trust for charitable purposes in Jersey which were agreed to be exclusively charitable under English law. The appellant executors were domiciled in Jersey and the will trust was to be governed by Jersey law. Subsequently the appellants retired as trustees in favour of a UK resident trustee and the proper law of the will trust was changed to the law of England...

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