United Kingdom: Corporate Tax

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
UT Remits £880m Loan Relationship Dispute Back To The FTT
The Upper Tribunal examined whether £3 billion paid to Barclays Bank during the 2008 financial crisis was wholly for reserve capital instruments or partly for warrants issued by its parent company. The case highlights the complexities of determining fair value allocation in structured financial transactions and the challenges taxpayers face when appealing factual findings, as the tribunal remitted the matter for reconsideration despite finding errors in the original decision.
United Kingdom Finance
RPC
Article
Rural Real Estate And Natural Capital Interview: Peter Harker, Saffery
Peter Harker, head of Natural Capital at Saffery, discusses how landowners are navigating the transition from traditional farming subsidies to ecosystem service payments, exploring the opportunities and challenges of biodiversity net gain schemes, carbon credits, and environmental commitments that can span generations. The conversation examines whether natural capital represents a genuine strategic opportunity or simply a replacement income stream...
United Kingdom Environment
WL
Withers LLP
Article
UK ‘Windfall’ Bank Tax Would Worsen An Already Complex System
UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.
United Kingdom Tax
RPC
Article
How The Finance Act 2026 Could Impact Contractor Engagement Across The Life Sciences Sector
The Finance Act 2026 introduces joint and several liability rules that fundamentally change how tax compliance works in labour supply chains involving umbrella companies and personal service companies. Life sciences businesses that rely on contractors for clinical trials, research programmes, and regulatory projects face new risks that extend beyond traditional IR35 obligations, with potential liability even for small businesses previously exempt from off-payroll working requirements.
United Kingdom Tax
PS
Penningtons Manches Cooper LLP
Article
Tax Investigations And Disputes Newsletter - September 2026
HMRC's enforcement agenda continues to intensify with new criminal offences for reckless statements, mandatory error correction obligations, and expanded compliance burdens on taxpayers and advisers. Recent Supreme Court decisions in BlueCrest and HFFX have narrowed the ground available to taxpayers, while the Court of Appeal's pushback in M R Currell offers some relief against overreach in disguised remuneration rules.
United Kingdom Tax
M
Macfarlanes LLP
Article
HMRC Prevented From Imposing Late Payment Penalties Following Reallocation Of Earlier Payments Made On Time
The First-tier Tribunal examined whether HMRC could retrospectively impose late payment penalties and surcharges after reallocating tax payments made by a taxpayer who had entered into unsuccessful tax avoidance schemes. The case centered on the critical question of whether tax liability should be assessed at a specific point in time or whether subsequent payment reallocations could create retroactive late payment scenarios.
United Kingdom Tax
RPC
Article
Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case
When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European Union Tax
RPC
Article
Can We Fix It? Yes, We Must! HMRC’s New Error Correction Powers
The UK Government has introduced draft legislation requiring taxpayers to actively correct errors in their tax returns, fundamentally shifting responsibility from HMRC to individuals and businesses. The new framework includes a general obligation to self-correct inaccuracies and introduces Customer Correction Notices, which allow HMRC to require taxpayers to review specific positions. Failure to correct identified errors will result in them being reclassified as deliberate, triggering significantly harsher
United Kingdom Tax
M
Macfarlanes LLP
Article
Recent Changes To UK Tax Clearance For Restructuring
Recent UK Budget 2025 reforms have fundamentally altered the tax clearance regime for corporate restructurings, removing the explicit "bona fide commercial reasons" test and the 5% shareholder exemption while introducing new counteraction powers. These changes require businesses to provide more robust documentation of commercial objectives and prepare for heightened scrutiny from HMRC when seeking clearance for transactions including share exchanges, demergers, and company reconstructions.
United Kingdom Tax
GGI Global Alliance
Article
What's Happening In Pensions - Issue 124
The UK government has introduced draft legislation enabling defined benefit pension schemes to release surplus funds directly to members from April 2027, while HMRC updates to VAT guidance create uncertainty around input tax recovery for scheme administration costs. Meanwhile, new inheritance tax information-sharing requirements take effect, and the Pensions Regulator sets out its five-year strategic priorities focused on innovation, value for money, and supporting UK economic growth.
United Kingdom Employment
TS
Travers Smith LLP
Article
Tax Odyssey II: Charting The Securities Transfer Tax
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
United Kingdom Tax
AO
A&O Shearman
Article
Inheritance Tax Planning: Protecting Your Wealth Without Fracturing Your Family
For many of our clients, the next twelve months will be a turning point in how they think about passing on wealth. The nil-rate band remains frozen at £325,000, with the residence nil-rate band fixed at £175,000 until at least April 2031. From April 2026, 100% agricultural and business property relief has been capped at £1 million of combined value and from 6 April 2027 most unused pension funds will be brought into the scope of inheritance tax for the first time.
Global Commercial
DG
Dixcart Group Limited
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