GiffGaff_Network_Member_Helper

And the other shocker? IHT policy is unenforceable. ❌ Cannot lawfully apply in NI (Windsor Framework guarantees CAP/state-aid parity). ❌ Cannot lawfully apply against EU citizens (TCA + ECJ rulings forbid discrimination). Result? A two-tier UK tax system that collapses on contact with international law. 👉 1. Barbier (C-364/01, 2003) Concerned a Dutch inheritance tax rule that treated non-resident heirs less favourably than residents. ECJ ruled this was a restriction on free movement of capital (Art. 63 TFEU). Principle: Inheritance tax rules must not discriminate between residents and non-residents when property is cross-border. 2. Lasteyrie du Saillant (C-9/02, 2004) Concerned a French rule taxing unrealised capital gains when someone moved tax residence abroad. ECJ struck it down as an unjustified restriction on freedom of establishment. Principle: Taxation cannot penalise people for exercising EU free movement rights. Relevance to UK reforms Under the Windsor Framework & TCA, EU free movement principles still apply in Northern Ireland and for EU citizens with UK property. If UK IHT reforms penalise EU citizens or create differential treatment (e.g. farms in NI vs GB), they replicate the discrimination struck down in Barbier and Lasteyrie. In practice: any well-advised farm or business can sidestep the reforms by structuring through NI or EU citizenship. 👉 Bottom line: Case law shows inheritance tax regimes that restrict cross-border transfers are unlawful under EU law. Since the UK is still bound by these obligations via the TCA and Windsor Framework, the reforms are legally unsustainable.