United Kingdom: 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.

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.

HMRC has announced a phased approach to mandatory payrolling of benefits in kind starting April 2027, alongside updates to the UK-India Double Contributions Convention and clarifications on PAYE Settlement Agreements. What do these changes mean for employers managing international assignments and employee benefits?

Charitable giving can be a useful part of estate planning, both as an effective way of supporting causes that matter to you and, in some cases, reducing the inheritance tax (IHT) payable on your estate on your death.

Owning property in Spain introduces a layer of succession law complexity that an English Will alone may not address. The difficulty is not that the Will is deficient. It is that a Will which works perfectly well under English law can produce outcomes in Spain that bear no relation to what the testator intended, because the two legal systems approach the fundamental question of who inherits very differently.

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.

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 UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.

The OECD's side-by-side package introduces new safe harbors for multinational groups under Pillar Two's global minimum tax regime, responding to U.S. concerns about undertaxed profits rules and existing tax credits. These reforms create significant implications for M&A transactions, particularly affecting due diligence processes, target pricing certainty, and contractual protections for deals involving U.S. acquirers and joint venture structures with mixed investor bases.

The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.