Tax Law and International Tax Law

BBC Panorama's investigation into Roman Abramovich's financial affairs has reignited critical debates around offshore structures, tax transparency and the fine line between legitimate...

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.

RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.

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...

The Supreme Court has clarified the application of LLP 'salaried members' rules in a landmark tax case involving BlueCrest Capital Management, examining whether members should be treated as employees for tax and National Insurance purposes. The judgment refines the interpretation of 'disguised salary' and 'significant influence' tests, establishing that legal and constitutional significance takes precedence over commercial significance when determining member status. This decision has far-reaching implicati

The Finance Act 2026 introduces joint and several liability rules that fundamentally change how tax compliance works in labour supply chains involving umbrella companies and personal service companies. Life sciences businesses that rely on contractors for clinical trials, research programmes, and regulatory projects face new risks that extend beyond traditional IR35 obligations, with potential liability even for small businesses previously exempt from off-payroll working requirements.

International property owners face significant tax implications when investing in UK real estate in 2026. Understanding the evolving tax landscape, from capital gains to inheritance tax, is crucial for making informed investment decisions. This guide explores the key considerations and obligations that overseas investors must navigate in the current UK property market.

The UK’s last two Budgets have materially reshaped the tax treatment for sales to Employee Ownership Trusts (EOT), tightening requirements and shifting from a full tax exemption to a halved relief, while leaving the broader principles in place.

The Upper Tribunal examined whether a limited liability partnership was carrying on a business with a view to profit when loan notes were transferred to it, determining the application of capital gains tax provisions. The case explores the interpretation of 'business' in tax legislation and the application of the Ramsay principle of purposive statutory construction in the context of a tax mitigation arrangement.

Isle of Man Limited Partnerships can offer Irish businesses a flexible structure for international expansion, investment and asset holding. LPs provide a distinction between management and capital, while LLPs can offer limited liability with greater flexibility for members to participate in management.

Overseas companies that do not want to be tax resident in the UK or have a permanent establishment (PE) in the UK should take note of recent developments.

This September 2026 VAT update from RPC examines HMRC's latest guidance on education VAT exemptions, VAT group refund procedures, and fund management services, while analyzing three significant tribunal decisions involving VAT fraud knowledge attribution, input tax recovery on luxury vehicles, and the VAT treatment of outsourced payroll arrangements.