United Kingdom: Tax

Understanding UK tax residence is crucial for international workers, but many overlook a critical mismatch: social security obligations operate under separate rules from tax residence. This disconnect can leave individuals paying national insurance in unexpected jurisdictions, affecting payroll compliance, benefits eligibility, and future state pension entitlements.

As the UK anticipates its first Budget under Andy Burnham's premiership on 28 October 2026, questions arise about whether 'Manchesterism' will introduce an exit tax regime. This analysis examines how different jurisdictions—from Canada's deemed disposal system to France's targeted charges on substantial holdings—tax individuals leaving their borders, and explores what form a UK exit tax might take if implemented.

Irish executors managing estates with overseas assets face complex legal requirements across multiple jurisdictions. Our International Private Client team provides specialized support for cross-border probate matters, including UK property, Channel Islands assets, North American investments, and US estate tax clearance, helping personal representatives navigate unfamiliar procedures with confidence.

Discover how in-house legal teams are approaching litigation as a strategic tool, with insights from our Leading Litigator Report conducted with The Lawyer. Nearly seven in ten General Counsels now view litigation as either an operational necessity or strategic investment to protect intellectual property, defend reputation, and strengthen market position.

You have probably seen this scene in a film: someone who knows they are dying presses a treasured possession into a loved one’s hands—a watch, a ring, a set of car keys—and says, “I want you to have this.” What you may not realise is that this moment has a name in law: donatio mortis causa, or a deathbed gift.

Two recent First-tier Tribunal cases examine the inheritance tax normal expenditure out of income exemption, clarifying when political donations qualify for relief. The judgments establish that establishing a settled pattern of giving requires more than common purpose—it demands regularity, predictability, and documented commitment to future expenditure.

HMRC has announced a phased approach to mandatory payrolling of benefits in kind, beginning April 2027 with company cars, fuel, vans, and medical benefits. What steps must employers take now to prepare their payroll...

Explore the evolving UK tax landscape for private clients following major reforms to agricultural property relief, business property relief, and non-dom rules. Partners Tim Williams and Emma Heelis-Adams discuss practical planning strategies, from lifetime gifting and family investment companies to insurance solutions and surplus income exemptions.

Keystone Law explores recent developments in HMRC's treatment of visa costs as taxable benefits, examining how the tax authority's approach has evolved and what this means for employers sponsoring international employees. The analysis considers the implications for both employers and employees navigating immigration-related tax obligations.

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.

HMRC has issued several significant guidance updates affecting transfer pricing corrections, construction industry schemes, and short-term business visitors, while recent court decisions provide crucial clarity...

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.