Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
The UK Supreme Court has delivered a landmark ruling on the "salaried members rules" for Limited Liability Partnerships, significantly narrowing the interpretation of when members can claim "significant influence" to avoid employee tax treatment. The decision confirms that influence must derive from legal rights in the LLP agreement and be exercised at a strategic level over the partnership's affairs generally, rather than through operational roles or financial importance.
United Kingdom Tax
TS
Travers Smith LLP
Article
Bluecrest - UK Supreme Court Confirms Interpretation Of The LLP Salaried Member Rules
The UK Supreme Court has delivered its judgment in HMRC v Bluecrest Capital Management (UK) LLP, addressing critical questions about when LLP members should be treated as self-employed versus employees for tax purposes. The ruling clarifies the interpretation of "disguised salary" and "significant influence" tests, establishing that influence must derive from legally enforceable rights rather than informal commercial importance.
United Kingdom Tax
D
Dechert
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Article
When Is A Day Not A Day? UK Tax Residence And The Statutory Residence Test
The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.
United Kingdom Commercial
DG
Dixcart Group Limited
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Article
Employee Pension Contributions And Salary Sacrifice Arrangements: Restriction Of National Insurance Exemption
The UK government has introduced legislation to limit the National Insurance contributions exemption for employee pension contributions made through salary sacrifice arrangements. Starting April 2029, only the first £2,000 of annual employee pension contributions will remain exempt from NICs, fundamentally altering the cost-benefit calculation that has made salary sacrifice arrangements attractive to employers for decades.
United Kingdom Employment
MB
Mayer Brown
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Article
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
The UK Supreme Court has delivered a landmark ruling on the "salaried members rules" for Limited Liability Partnerships, significantly narrowing the interpretation of when members can claim "significant influence" to avoid employee tax treatment. The decision confirms that influence must derive from legal rights in the LLP agreement and be exercised at a strategic level over the partnership's affairs generally, rather than through operational roles or financial importance.
United Kingdom Tax
TS
Travers Smith LLP
Article
A Guide To Jersey Property Unit Trusts (JPUTs)
Jersey Property Unit Trusts (JPUTs) offer a tax-efficient, flexible structure for investing in UK commercial real estate, combining the benefits of trust transparency with corporate-style operational features. This comprehensive guide examines how recent regulatory reforms and established tax advantages position JPUTs as a compelling alternative to corporate holding vehicles for institutional, sovereign, and US investors. What makes JPUTs particularly attractive in today's evolving tax landscape, and how do
Jersey Finance
W
Walkers
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