Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
A New Criminal Offence For Reckless Untrue Statements In Direct Tax
The UK Government has launched a consultation on introducing a new criminal offence targeting reckless untrue statements in direct tax matters, potentially exposing taxpayers and advisers to up to two years' imprisonment. This proposed measure aims to bridge the gap between civil penalties for careless conduct and criminal sanctions for dishonest evasion, fundamentally changing how HMRC can prosecute tax compliance failures.
United Kingdom Tax
M
Macfarlanes LLP
Article
HMRC Consults On The Tax Treatment Of Non-UK Company Distributions
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
Article
How Reforms To Global Minimum Tax Standards Could Impact Dealmaking
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.
United Kingdom Tax
AO
A&O Shearman
Article
HMRC Consults On Aligning The Taxation Of Distributions From Non-UK Resident Companies
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
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National Insurance

Article
Supreme Court Decides The LLP Salaried Member Rules - But Sends BlueCrest Back To The First-Tier Tax Tribunal
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management, clarifying the salaried member rules that determine whether LLP members are taxed as employees or partners. The ruling refines the legal test for "significant influence" and establishes that influence must derive from enforceable governance frameworks rather than informal practice, with immediate implications for how LLPs structure membership terms and delegated authority.
United Kingdom Tax
M
Macfarlanes LLP
Article
Employee Pension Contributions And Salary Sacrifice Arrangements: Restriction Of National Insurance Exemption
The UK government has introduced legislation to limit the National Insurance contributions exemption for employee pension contributions made through salary sacrifice arrangements. Starting April 2029, only the first £2,000 of annual employee pension contributions will remain exempt from NICs, fundamentally altering the cost-benefit calculation that has made salary sacrifice arrangements attractive to employers for decades.
United Kingdom Employment
MB
Mayer Brown
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Inheritance Tax

Article
Why Uncertainty Is The Biggest Challenge For Businesses In Scotland’s Rural Sector
Petra Grunenberg, Head of Rural Property and Business at Shepherd and Wedderburn, discusses the mounting challenges facing Scotland's rural sector as legislative changes converge with political uncertainty. With inheritance tax reforms, land reform legislation, and subsidy scheme overhauls all progressing simultaneously, she explains why rural business owners must seek professional advice now rather than wait for clarity.
United Kingdom Tax
Sa
Shepherd and Wedderburn LLP
Article
UK Pensions: DC trustee agenda update—July 2026
HMRC has released detailed guidance on applying inheritance tax to pensions from 2027, while the Pension Schemes Act 2026 introduces sweeping changes including a new DC Value for Money framework and consolidation requirements for small pension pots. The Pensions Regulator has also published expectations for AI governance in workplace pension arrangements, alongside updated dashboards guidance as the industry prepares for the likely 2027/28 go-live date.
United Kingdom Employment
AO
A&O Shearman
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Capital Gains Tax

Article
HMRC Consults On The Tax Treatment Of Non-UK Company Distributions
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
Article
HMRC Consults On Aligning The Taxation Of Distributions From Non-UK Resident Companies
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
See more

Transfer Pricing

Article
How Reforms To Global Minimum Tax Standards Could Impact Dealmaking
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.
United Kingdom Tax
AO
A&O Shearman
Article
European Commission's Tax Simplification Package And The Future Of The Unshell Substance Tests
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.
United Kingdom Tax
M
Macfarlanes LLP
Article
Beyond Cost-Plus: What The OECD's New Approach To Intra-Group Services Means For UK Taxpayers
The OECD has proposed significant revisions to its transfer pricing guidance on intra-group services, expanding practical examples and emphasizing the need for robust documentation to evidence service provision and benefits. While core principles remain unchanged, the updates create potential tensions with HMRC's more prescriptive approach to high-value services, particularly around pricing methodologies and the treatment of shareholder activities.
United Kingdom Tax
M
Macfarlanes LLP
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