Tax Law and International Tax Law

This bulletin follows the release of the June Agent Update (Issue 132). In this issue we cover the content most relevant to employment taxes and reward activities.

HMRC has announced that the introduction of mandatory payrolling for most Benefits in Kind (BiKs) will be delayed by one year, until 6 April 2027.

FICs are companies limited by shares (an "Ltd" or "Limited") and often established by parents and/or grandparents ("Founders") to benefit themselves and their family, as shareholders.

Traditionally, inheritance tax (IHT) treatment was determined by an individual's domicile status: an individual who was domiciled or deemed domiciled in the UK was subject to IHT on their worldwide estate.

Many people want to help their children or loved ones while they are still alive to see the benefit.

It is now June 2025, and the UK's sweeping reforms to its tax regime for non-domiciled individuals have officially come into force.

Significant changes were introduced to the UK's tax rules for non-domiciled individuals from 6 April 2025. The remittance basis for non-UK domiciled individuals has been replaced with a residency-based system.

The standout item is the recent introduction of the Reserved Investor Fund, a new type of investment fund expected to be of particular interest to commercial real estate strategies.

The Register of Overseas Entities, effective from 1 August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022, requires overseas companies and other non-human entities owning property in the UK to register with Companies House and disclose their beneficial owners or managing officers.

Until April 2012, it had been looking like a rather quiet quarter on the sovereign risk front.

The Chancellor of the Exchequer announced the 2012 Budget on 21 March. While aspects of the Budget are clearly favourable to UK business, particularly the reduction in the main rate of corporation tax to 24 per cent from 1 April 2012 with further reductions in the rate to 22 per cent to come by April 2014, the specific measures introduced in relation to real estate are less positive and largely anti-avoidance in nature.

In the weeks leading up to the 2012 Budget the rumour mill was working overtime.