I do not, if I can help it, catch a train to anywhere on a Sunday. Yet there I was at 9.14 a.m. heading out from Woodbridge in Suffolk towards Cambridge to view a painting by Walter Sickert, a work I had not seen before and whose vital statistics – what even the work was of – I had no way of knowing; its owner had refused to send a photograph or describe it over the telephone.

Arriving at the owner’s address, I was met by a neighbour who told me that in the name of letting go and embracing surprise, they had decided to visit a relative in Scotland the night before.

A one-on-one with such a beautiful, personal painting is a very special experience

In common with tens of thousands of other art works, rare books, furniture, glassware, silverware and what might be classified as objets d’art, this Sickert is listed under HMRC’s Conditional Exemption Tax Incentive scheme (CETI). Under the measure owners are exempt from paying inheritance or capital gains tax on ‘pre-eminent’ work when it passes to a new owner as long as they maintain, preserve and provide public access to whatever is covered by the agreement.

The owner or their representative is then responsible for informing HMRC of any change in circumstances that may affect their ability to comply with the conditions in the agreement. Tax is payable if any of these conditions are not met.

In this context, ‘public access’ does not mean access only with a prior appointment. It requires the owner of the listed item or collection to open up their home to the public for a certain number of days per year. In practice, this means access usually has to be given for at least 28 days of the year and outside of those days, the item must be........

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