United Kingdom: Tax

Keystone Law explores recent developments in HMRC's treatment of visa costs as taxable benefits, examining how the tax authority's approach has evolved and what this means for employers sponsoring international employees. The analysis considers the implications for both employers and employees navigating immigration-related tax obligations.

The UK’s last two Budgets have materially reshaped the tax treatment for sales to Employee Ownership Trusts (EOT), tightening requirements and shifting from a full tax exemption to a halved relief, while leaving the broader principles in place.

The Supreme Court has clarified the application of LLP 'salaried members' rules in a landmark tax case involving BlueCrest Capital Management, examining whether members should be treated as employees for tax and National Insurance purposes. The judgment refines the interpretation of 'disguised salary' and 'significant influence' tests, establishing that legal and constitutional significance takes precedence over commercial significance when determining member status. This decision has far-reaching implicati