United Kingdom: Income Tax

The Finance Act 2026 introduces fundamental changes to how inheritance tax applies to pension death benefits from April 2027, shifting most lump sum payments into deceased members' estates while creating new reporting obligations for personal representatives and scheme trustees. Understanding these changes is critical for pension trustees who must now prepare their administration processes, governance frameworks, and member communications to comply with the new regime.

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.

The United Kingdom’s Upper Tribunal (UT) decision in CATS North Sea Limited v. HMRC provides an exploration of statutory deeming rules, in particular the extent to which a deemed trade fiction applies when interpreting other legislative provisions.

As we approach the end of the 2025/26 tax year, now is the ideal time to review your personal tax position and assess whether you are making full use of the reliefs and allowances available.

AI adoption coupled with developments in robots and other technology means many are predicting a medium-term future of reduced job opportunities, whatever the long-term outcome.

The OECD's "Side-by-Side" deal (published 5 January 2026) grants a significant exemption from much of the Pillar Two minimum tax rules to US-headquartered multinationals.

Share plans are a powerful mechanism for companies to recruit, retain and motivate talent. By taking a stake in the business they work for, employees can align their interests with the company's long-term goals.

In this Winter Update we reflect on key events affecting Incentives and Remuneration and look at what 2026 has in store.

With changes to salary sacrifice on the horizon, we explain why now's a good time to assess your pension arrangements and get up to speed with tax compliance.