United Kingdom: Corporate Tax

The UK government has released a comprehensive update to its pensions roadmap, revising key implementation timelines for the Pension Schemes Act 2026 and introducing new frameworks for Value for Money assessments, scale requirements, and guided retirement provisions. HMRC has also updated critical guidance on VAT recovery for pension scheme expenditure, while new regulations clarify inheritance tax information-sharing duties and authorize direct surplus payments to members.

HMRC has launched a comprehensive consultation on modernising the UK tax rules governing distributions and capital repayments by companies, proposing significant changes that could affect how returns of value to individual shareholders are taxed.

The UK government plans to make the foreign permanent establishment exemption mandatory from January 2027, fundamentally changing how UK companies are taxed on overseas operations. This policy shift, accelerated for oil and gas companies to September 2026, will prevent businesses from using foreign branch losses to offset UK profits while exempting future foreign profits from UK tax. What implications will this have for international business structures, loss relief strategies, and the broader competitivene