Worldwide: Tax Treaties

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?

UK executors administering estates with US shares are facing unprecedented delays of two to three years when seeking IRS estate tax clearance through Form 706-NA applications. These processing bottlenecks, stemming from pandemic-related backlogs and ongoing IRS staffing pressures, are preventing executors from completing estate administration and leaving beneficiaries waiting years to receive their inheritance from US investments.

The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this could reduce delays, administrative burden and cash-flow issues under the current regime. However, it could also shift greater responsibility, and potentially greater risk, onto borrowers and other UK payers.

HMRC v Burlington Loan Management is an important Court of Appeal decision on the interpretation of double tax treaty anti-abuse articles in the context of the international secondary debt market, which came out of the Lehman Brothers administration.

Court of Appeal dismisses HMRC's appeal in Burlington Loan Management decision on Treaty purpose tests.

The United Kingdom’s Upper Tribunal (UT) decision in CATS North Sea Limited v. HMRC provides an exploration of statutory deeming rules, in particular the extent to which a deemed trade fiction applies when interpreting other legislative provisions.

In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach...

From January 2026, UK taxpayers who use crypto-assets will face new reporting obligations under regulations aligned with the OECD's Crypto-Asset Reporting Framework (CARF).

There are many reasons why individuals may decide to move to, or leave the UK tax year. Whilst complex, the SRT is designed to provide taxpayers with objective clarity on how they will be assessed by HMRC.