United Kingdom: Corporate Tax

The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.

HM Revenue & Customs is consulting on the way that returns of value to shareholders – specifically, distributions (such as dividends) and capital repayments – are taxed.

Supreme Court upholds Court of Appeal decision that structured LLP profit-sharing arrangements are subject to miscellaneous income tax charge, providing guidance on section 850 ITTOIA and section 687 ITTOIA with wider implications for partnership taxation.

A crucial requirement for QAHC eligibility is that the company is UK tax-resident, but not that it is a UK company and therefore both Jersey and Guernsey incorporated companies are eligible.

Guernsey and Jersey companies have been a mainstay on the LSE for many years – and the same have also been used for listings on NYSE and NASDAQ, as well as other stock exchanges in Europe, North America and Africa.

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.

The Employee Ownership Trust has emerged as a significant vehicle for promoting broader employee ownership since its introduction in Finance Act 2014.

The UK government is introducing a new International Controlled Transactions Schedule (ICTS) that will require approximately 75,000 businesses to file detailed annual reports...

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...