United Kingdom: Income Tax

HMRC has issued new compliance guidelines for employers managing short-term business visitors to the UK, clarifying common misconceptions about tax liabilities and treaty obligations. The guidance highlights critical errors employers make when handling international mobility, from miscounting UK days to misunderstanding double-taxation treaties.

Adding a family member to your bank account may seem like a simple way to manage finances or prepare for future health issues. However, this seemingly straightforward decision can trigger unexpected legal consequences, including unintended gifts, altered inheritance rights, and significant UK tax liabilities across inheritance tax, capital gains tax, and income tax.

Leaving the UK involves far more than securing a new residence permit. Careful planning before departure can reduce tax exposure, protect wealth, optimise succession planning and help avoid unexpected liabilities. Whether you’re relocating for business, retirement or lifestyle reasons, choosing the right residency and tax strategy is essential before you leave.

The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management (UK) LLP, establishing a restrictive three-part test for determining what constitutes "significant influence" under the salaried member rules. This ruling clarifies that influence must be formally derived from the LLP Agreement, extend to strategic affairs of the entire LLP, and involve substantive participation in important decisions affecting the partnership's conduct.

HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.

HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.

Tackling disguised remuneration (DR) has long been a focus for HMRC, and they have had significant success in the area, protecting billions of pounds of tax revenue.

This bulletin follows the release of the December and January Agent Updates (Issue 138 and Issue 139).

Three months ago we wrote about the countdown to mandatory tax adviser registration and wondered what exactly we were counting down to. On 18 May 2026 HMRC opened its online registration portal.