United Kingdom: Withholding Tax

For many of our clients, the next twelve months will be a turning point in how they think about passing on wealth. The nil-rate band remains frozen at £325,000, with the residence nil-rate band fixed at £175,000 until at least April 2031. From April 2026, 100% agricultural and business property relief has been capped at £1 million of combined value and from 6 April 2027 most unused pension funds will be brought into the scope of inheritance tax for the first time.

Starting a business is an exciting milestone. Yet while many entrepreneurs focus on their product, service, or big idea, the reality is that building a successful business requires much more than simply generating sales.

Grave goods are objects placed in burials to accompany the dead, and they offer important evidence of how past societies understood death, status, and the afterlife. In Neolithic cultures, such items often included pottery, tools, ornaments, and food offerings, suggesting both practical and symbolic concerns for the deceased

If you already have a Will in your country of residence covering your worldwide assets, it is understandable to assume that your affairs are fully in order.

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

It is February 2026 and two people are sitting at the departure gate at Heathrow waiting for their (inevitably) delayed flight to the Bahamas. They start a conversation about why they are heading to this Caribbean island.

Welcome to the latest edition of our UK tax outlook designed to offer legal and practical insights into UK tax developments that have cross-border interest and relevance for your clients.

In HMRC v Burlington Loan Management DAC, the Upper Tribunal upheld that the anti-abuse provision in the UK/Ireland double tax treaty didn't apply, allowing Burlington to claim tax relief. The case underscores careful consideration of double tax treaties in structuring transactions.

The June UK Tax Round Up highlighted Court of Appeal's denial of interest deductions in JTI Acquisitions, Upper Tribunal's rejection of treaty abuse claims in Burlington Loan Management, and overturning of IR35 decision in Basic Broadcasting Ltd