United Kingdom: Tax

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Article
The End Of The “significant Influence” Debate? What The Supreme Court’s BlueCrest Decision Means For LLPs
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management (UK) LLP, establishing a restrictive three-part test for determining what constitutes "significant influence" under the salaried member rules. This ruling clarifies that influence must be formally derived from the LLP Agreement, extend to strategic affairs of the entire LLP, and involve substantive participation in important decisions affecting the partnership's conduct.
United Kingdom Tax
SR
McDermott Will & Schulte
Article
UK Tax Authority Will Transform Transfer Pricing Risk Assessment
The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.
United Kingdom Tax
M
Macfarlanes LLP
Article
A New Criminal Offence For Reckless Untrue Statements In Direct Tax
The UK Government has launched a consultation on introducing a new criminal offence targeting reckless untrue statements in direct tax matters, potentially exposing taxpayers and advisers to up to two years' imprisonment. This proposed measure aims to bridge the gap between civil penalties for careless conduct and criminal sanctions for dishonest evasion, fundamentally changing how HMRC can prosecute tax compliance failures.
United Kingdom Tax
M
Macfarlanes LLP
Article
HMRC Consults On The Tax Treatment Of Non-UK Company Distributions
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
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Tax Treaties

Article
European Commission's Tax Simplification Package And The Future Of The Unshell Substance Tests
The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.
United Kingdom Tax
M
Macfarlanes LLP
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Inheritance Tax

Article
Why Uncertainty Is The Biggest Challenge For Businesses In Scotland’s Rural Sector
Petra Grunenberg, Head of Rural Property and Business at Shepherd and Wedderburn, discusses the mounting challenges facing Scotland's rural sector as legislative changes converge with political uncertainty. With inheritance tax reforms, land reform legislation, and subsidy scheme overhauls all progressing simultaneously, she explains why rural business owners must seek professional advice now rather than wait for clarity.
United Kingdom Tax
Sa
Shepherd and Wedderburn LLP
Article
UK Pensions: DC trustee agenda update—July 2026
HMRC has released detailed guidance on applying inheritance tax to pensions from 2027, while the Pension Schemes Act 2026 introduces sweeping changes including a new DC Value for Money framework and consolidation requirements for small pension pots. The Pensions Regulator has also published expectations for AI governance in workplace pension arrangements, alongside updated dashboards guidance as the industry prepares for the likely 2027/28 go-live date.
United Kingdom Employment
AO
A&O Shearman
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Income Tax

Article
The End Of The “significant Influence” Debate? What The Supreme Court’s BlueCrest Decision Means For LLPs
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management (UK) LLP, establishing a restrictive three-part test for determining what constitutes "significant influence" under the salaried member rules. This ruling clarifies that influence must be formally derived from the LLP Agreement, extend to strategic affairs of the entire LLP, and involve substantive participation in important decisions affecting the partnership's conduct.
United Kingdom Tax
SR
McDermott Will & Schulte
Article
HMRC Consults On The Tax Treatment Of Non-UK Company Distributions
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
Article
HMRC Consults On Aligning The Taxation Of Distributions From Non-UK Resident Companies
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
See more

Transfer Pricing

Article
UK Tax Authority Will Transform Transfer Pricing Risk Assessment
The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.
United Kingdom Tax
M
Macfarlanes LLP
Article
How Reforms To Global Minimum Tax Standards Could Impact Dealmaking
The OECD's side-by-side package introduces new safe harbors for multinational groups under Pillar Two's global minimum tax regime, responding to U.S. concerns about undertaxed profits rules and existing tax credits. These reforms create significant implications for M&A transactions, particularly affecting due diligence processes, target pricing certainty, and contractual protections for deals involving U.S. acquirers and joint venture structures with mixed investor bases.
United Kingdom Tax
AO
A&O Shearman
Article
European Commission's Tax Simplification Package And The Future Of The Unshell Substance Tests
The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.
United Kingdom Tax
M
Macfarlanes LLP
See more

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