United Kingdom: Withholding Tax

The Supreme Court has held that the Danish Customs and Tax Administration was not barred by issue estoppel from bringing new claims against the same defendant following the dismissal of its earlier claim under the rule which prevents English courts enforcing foreign tax claims.

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.

The UK government has launched a consultation on establishing a corporate re-domiciliation regime that would allow foreign companies to relocate their legal domicile to the UK while maintaining their corporate identity.

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.

The 2024 Autumn Budget, to be delivered on 30 October by Chancellor Rachel Reeves, may introduce tax changes including potential Capital Gains Tax reforms, Inheritance Tax adjustments, pension relief cuts, and alterations to non-dom taxation and furnished holiday lets.

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.