United Kingdom: Capital Gains Tax

The Scottish Government recently published its review of wealth taxation in Scotland. The report does not recommend introducing a wealth tax, but it does consider whether one could operate effectively within Scotland's fiscal and constitutional framework.

Branded residences combine luxury property ownership with hotel-quality amenities and international brand recognition, but they also introduce complex UK tax implications that investors must carefully navigate. From capital gains tax and inheritance tax exposure to the nuances of the Statutory Residence Test, acquiring a UK branded residence can significantly impact an investor's tax status and that of their family members. Understanding these considerations is essential before making what may appear to be

HMRC's latest statistics reveal a dramatic increase in cryptoasset tax reporting, with 240 taxpayers declaring over £1 million in capital gains and total disposals reaching £13.8 billion in 2024/25. As the UK prepares to implement the Cryptoasset Reporting Framework from January 2026, giving HMRC unprecedented access to transaction data from service providers, the tax risks facing cryptoasset holders are escalating rapidly. With 81,000 warning letters already sent to taxpayers and HMRC's enforceme

Changes to UK inheritance tax rules from April 2025 have diminished the appeal of traditional trust planning for non-UK families relocating to Britain. While Americans benefit from favorable US-UK estate tax treaty provisions, family limited partnerships emerge as an increasingly attractive alternative structure, particularly for American families navigating cross-border wealth transfer challenges.

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.

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.

From April 2027, the UK will fundamentally reshape pension taxation by bringing unused pension funds into the scope of Inheritance Tax for the first time in decades.

HMRC's compliance toolkit continues to expand, with proposals to widen the uncertain tax treatment notification regime which would draw significantly more taxpayers into scope.

The landscape for employee share incentives in the UK has shifted meaningfully in recent months, and for private company owners and their advisers, in particular, the timing has rarely been better to take a fresh...