United Kingdom: Tax

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.

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

Understanding how Italy taxes foreign pensions is crucial for anyone relocating with retirement savings built under different tax models. This analysis explores the fundamental differences between the UK's EET...

When drafting or updating your Will, understanding the financial and tax implications can significantly impact how your estate is distributed. From inheritance tax calculations and residence nil rate bands to charitable...

This comprehensive update covers critical developments in UK pension scheme regulation, including new inheritance tax requirements for pensions, the landmark Pension Schemes Act 2026...

Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support...

HMRC has confirmed that some non-UK residents with UK rental or self-employment income may receive an automatic one-year deferral from Making Tax Digital for Income Tax (MTD IT). Eligible individuals who filed non-residence pages (SA109) for 2024/25 may not need to join the regime until April 2027.

The UK government is proposing new reporting obligations for close companies regarding loans to participators, requiring detailed disclosure of transactions that previously went unreported.

The Upper Tribunal's decision in Putney Power Limited clarifies a critical question in UK tax law: when does a company actually begin trading versus merely preparing to trade? This distinction carries significant consequences for Enterprise Investment Scheme relief and other tax benefits, as the court rejected rigid legal tests in favor of a nuanced, fact-specific analysis of each company's activities and circumstances.

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

With the rise and rapid adoption of advanced data analytics and AI tools, transfer pricing compliance and risk assessment is quickly shifting from being a documentation-focused process to a near real time, data-driven one.

HMRC has proposed sweeping new reporting requirements for close companies that would mandate detailed disclosure of all transactions with participators, extending far beyond the current framework which only captures loans triggering tax charges. The consultation raises critical questions about the burden on privately-owned groups and private equity structures, where intra-group transactions could generate extensive reporting obligations despite no underlying tax liability.