Court of Appeal
Banks v Revenue and Customs Commissioners
[2021] EWCA Civ 1439
2021 May 26, 27; Oct 6
Sir Julian Flaux C, Henderson, Nicola Davies LJJ
RevenueInheritance taxExempt transfers Donations to political parties qualifying for exemption from inheritance tax provided party having achieved specified minimum level of representation in House of Commons at general election immediately preceding donationTaxpayer donating sum to political party without any members of Parliament and therefore not qualifying for exemptionTaxpayer contending condition for exemption discriminating against him in enjoyment of Convention rightsWhether differential treatment based on characteristics specified in Convention and/or “other status”Whether condition amounting to unjustified discrimination of rights Inheritance Tax Act 1984 (c 51), s 24 Human Rights Act 1998 (c 42), Sch 1, Pt I, arts 10, 11, 14, Pt II, art 1

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