United Kingdom: Capital Gains Tax

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.

There are a number of potential tax advantages when using FICs, including Inheritance Tax, but these will vary depending on the size

The Upper Tribunal's decision in Putney Power Limited clarifies a critical question in UK tax law: when does a company actually begin trading versus merely preparing to trade? This distinction carries significant consequences for Enterprise Investment Scheme relief and other tax benefits, as the court rejected rigid legal tests in favor of a nuanced, fact-specific analysis of each company's activities and circumstances.

Niall Hearty of Rahman Ravelli details the bank’s partial settlement of its role in the share trading tax scandal.

It is February 2026 and two people are sitting at the departure gate at Heathrow waiting for their (inevitably) delayed flight to the Bahamas. They start a conversation about why they are heading to this Caribbean island.

It is often said that those with the broadest shoulders should bear the heaviest loads. This principle is clearly reflected in the UK tax system, where individuals with a greater ability to pay, contribute a larger share of the overall tax burden.

Rolling out a global share plan requires significant investment of time, internal coordination and collaboration with external advisors and administrators.

Enterprise Management Incentive (EMI) plans are an excellent mechanism for employers and employees – when used correctly.

The 2024 Autumn Budget in the UK introduced an immediate rise in capital gains tax (CGT) and changes to the taxation of international individuals, most of which took effect on 06 April 2025.