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Top Slicing Relief and Silver - too late to claim?

Would you submit a claim now?

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I have been folloing the top slicing relief and Silver case with interest.  I acquired a client in 2014 whose 2013 tax return was subject to an enquiry as she had not entered a chargeable event into the return.  The level of the gain was such that all of her personal allowance was removed, although using the Silver principles, this is wrong now.

The enquiry was closed off long ago, but does anyone think there is any way we can revisit this now?  Is it worth a shot?  Tim Good has suggested in an article that a claim could be made under ESC B41 but do you think this would work in a scenario where the year was subject to an enquiry?  I don't want to get my clients hopes up too high nor waste a lot of time on a fruitless exercise...

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RLI
By lionofludesch
12th Sep 2020 23:05

I would.

I always loved an argument with HMRC.

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