From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
On 27 October 2021, HM Treasury, BEIS and HMRC published a consultation paper seeking views on proposals for a UK re-domiciliation regime under which foreign-incorporated companies could change their place of incorporation to...more
Following public consultation earlier this year, draft legislation for a new residential property developer tax has been published by HM Treasury. The aim is to help fund the growing costs of cladding remediation works,...more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more