United Kingdom: Tax Treaties

UK executors administering estates with US shares are facing unprecedented delays of two to three years when seeking IRS estate tax clearance through Form 706-NA applications. These processing bottlenecks, stemming from pandemic-related backlogs and ongoing IRS staffing pressures, are preventing executors from completing estate administration and leaving beneficiaries waiting years to receive their inheritance from US investments.

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

Court of Appeal dismisses HMRC's appeal in Burlington Loan Management decision on Treaty purpose tests.

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.

In Haworth v HMRC [2025] EWCA Civ 822, the Court of Appeal (the Court) has delivered its decision in a tax dispute that began over two decades ago, involving a widely marketed tax scheme at the time...

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.