United Kingdom: Corporate Tax

The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this could reduce delays, administrative burden and cash-flow issues under the current regime. However, it could also shift greater responsibility, and potentially greater risk, onto borrowers and other UK payers.

The UK Supreme Court has ruled on a landmark case involving BlueCrest Capital Management and HMRC's salaried members rules, clarifying how LLP members should be classified for tax purposes. The decision examines whether portfolio managers and desk heads with significant operational responsibilities but limited formal governance rights can avoid being treated as employees for income tax and national insurance purposes.

The UK government has published draft legislation for a new Securities Transfer Tax (STT) that will replace the existing dual regime of stamp duty and stamp duty reserve tax. This comprehensive reform aims to modernize the UK's transfer tax framework through full digitalization and self-assessment, fundamentally changing how securities transactions are reported and taxed. While the headline rates remain unchanged at 0.5% for the main charge and 1.5% for higher-rate transactions, the new regime introduces si

The UK government has published draft legislation for a new Securities Transfer Tax (STT), which is expected to replace the existing stamp duty and stamp duty reserve tax (SDRT) regimes for transfers of securities.

HMRC has launched a consultation proposing fundamental reform to the UK's distribution framework, potentially one of the most consequential tax law consultations in decades. The proposals aim to modernize rules that have remained largely unchanged since 1965, addressing how payments from companies to shareholders are taxed and closing perceived loopholes that allow value extraction at capital gains rates rather than dividend rates. The consultation covers seven key areas including reductions of capital, dem

Family investment companies (FICs) are increasingly being used as succession planning vehicles as an alternative to traditional trusts. This video explores how FICs enable families to transfer wealth to future generations while maintaining control, examining the tax efficiency, governance structures, and practical considerations that determine whether a FIC is the right choice for a family's circumstances.

A shareholder exit does not always require the remaining shareholders to fund the full buyout personally on day one. Private companies can often use structured mechanisms such as a company share buyback, a staged...

The government has published a consultation on draft regulations setting out new conditions for payment of DB scheme surpluses to employers, following the changes made in the Pension Schemes Act 2026...

This comprehensive update examines significant changes to UK employee share schemes and executive remuneration, including expanded eligibility for the Enterprise Management Incentive scheme, the introduction of PISCES trading platform for private company shares, and modifications to Employee Ownership Trust tax relief. The analysis covers recent tribunal decisions on employment status and proprietary estoppel claims, providing critical insights for companies managing employee equity compensation.