United Kingdom: Tax Treaties

The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this could reduce delays, administrative burden and cash-flow issues under the current regime. However, it could also shift greater responsibility, and potentially greater risk, onto borrowers and other UK payers.

The UK government has published draft legislation for a new Securities Transfer Tax (STT) set to replace stamp duty and SDRT in 2027, marking a significant modernisation of the UK's share taxation regime. While the main 0.5% rate remains unchanged, the reform introduces a single, digitally-administered framework that promises to simplify compliance and accelerate share registration processes. This comprehensive analysis examines ten critical aspects of the proposed legislation, from timing accommodations fo

Changes to UK inheritance tax rules from April 2025 have diminished the appeal of traditional trust planning for non-UK families relocating to Britain. While Americans benefit from favorable US-UK estate tax treaty provisions, family limited partnerships emerge as an increasingly attractive alternative structure, particularly for American families navigating cross-border wealth transfer challenges.

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.

During 2025, HMRC paused their concessionary treatment for administrative errors relating to withholding tax on cross-border interest payments.

On 2 February 2026, the Organisation for Economic Co-operation and Development (OECD) published an updated edition of the Manual on Effective Mutual Agreement Procedures (MEMAP).

The latest round of negotiations on the development of the UN Global Plastic Treaty will commence in Geneva, Switzerland, in August, aiming to deliver the first legally binding treaty tackling plastic pollution...

HMRC has announced that the introduction of mandatory payrolling for most Benefits in Kind (BiKs) will be delayed by one year, until 6 April 2027.

FICs are companies limited by shares (an "Ltd" or "Limited") and often established by parents and/or grandparents ("Founders") to benefit themselves and their family, as shareholders.