Tax Law and International Tax Law

Welcome to the June edition of our UK Tax Round Up, which discusses HMRC's response to its consultation on the new UK carried interest regime to be introduced next year...

Following the recent tax changes in the UK, there has been a wave of non-doms leaving the UK in search of more tax friendly jurisdictions. But for many their children have strong ties to the UK, in many cases having been born or raised and educated here and, in most cases, having British nationality.

Jeremy started his new position with Anthony Gold on April 1st and the new Tax year started four days later. Here he highlights what's changed and what hasn't. If you think you need advice on the issues raised...

HMRC has announced a new policy on the recovery by employers of VAT charged on investment services provided to their DB pension schemes.

HMRC has announced that the introduction of mandatory payrolling for most Benefits in Kind (BiKs) will be delayed by one year, until 6 April 2027.

FICs are companies limited by shares (an "Ltd" or "Limited") and often established by parents and/or grandparents ("Founders") to benefit themselves and their family, as shareholders.

Significant changes were introduced to the UK's tax rules for non-domiciled individuals from 6 April 2025. The remittance basis for non-UK domiciled individuals has been replaced with a residency-based system.

The standout item is the recent introduction of the Reserved Investor Fund, a new type of investment fund expected to be of particular interest to commercial real estate strategies.

The Register of Overseas Entities, effective from 1 August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022, requires overseas companies and other non-human entities owning property in the UK to register with Companies House and disclose their beneficial owners or managing officers.

Until April 2012, it had been looking like a rather quiet quarter on the sovereign risk front.

The Chancellor of the Exchequer announced the 2012 Budget on 21 March. While aspects of the Budget are clearly favourable to UK business, particularly the reduction in the main rate of corporation tax to 24 per cent from 1 April 2012 with further reductions in the rate to 22 per cent to come by April 2014, the specific measures introduced in relation to real estate are less positive and largely anti-avoidance in nature.

In the weeks leading up to the 2012 Budget the rumour mill was working overtime.