The case of HMRC v The Quentin Skinner 2005 Settlement L and others the Upper Tribunal (UT) allowed HMRC’s appeal against a First-tier Tax Tribunal (FTT) decision, finding a number of errors in law. The UT found that section 169J of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) does require a beneficiary to have been a qualifying beneficiary throughout the period of one year ending not earlier than three years before the disposal.