The executors of Beryl Coulter argued that the denial of relief to a Jersey-based charitable beneficiary was against European Union principles of freedom of movement of capital, but the court decided that denying relief was proportionate because information about the charity could not easily be verified.
The UK authorities are entitled to deny inheritance tax relief to gifts made to overseas charitable trusts, the England and Wales Court of Appeal has ruled in the case Routier v HMRC (2017 EWCA Civ 1584).
