Income Taxes, Tax Liability, UK

UK Tax Round Up - May 2025

Proskauer Rose LLP on 6/12/2025

Welcome to the May edition of our UK Tax Round Up, which discusses two interesting judgments, one on the question of whether a distribution from a Jersey company was of a “capital nature” and the other on whether a loan to a...more

UK Government announces update on new carried interest tax regime

Goodwin on 6/10/2025

On June 5, 2025, the UK Government announced the result of their recent consultation process regarding their plans to bring carried interest within the income tax regime from April 2026, subject to an effective tax rate of...more

UK Salaried Member Employment Tax Rules - Recent Developments

Goodwin on 5/8/2025

This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more

The Salaried Members Rules and the 'Significant Influence' Test – Does the BlueCrest Case Affect Me (As a Partner) or My Firm?

Katten Muchin Rosenman LLP on 3/13/2025

Salaried Members Rules - Limited liability partnerships or "LLPs" are common corporate vehicles utilised by the financial services sector to establish UK investment management operations and other financial businesses and,...more

Determining Significant Influence

Cadwalader, Wickersham & Taft LLP on 2/25/2025

On 17 January 2025, the United Kingdom Court of Appeal in HMRC v BlueCrest Capital Management (UK) LLP [2025] EWCA Civ 23 (“BlueCrest”) held that the First-tier Tribunal (“FTT”) and the Upper Tribunal (“UT”) had made a...more

Siège de direction effective : la recherche de la substance de l'entreprise et du lieu de prise de décision stratégique

Mayer Brown on 2/4/2025

La cour administrative d'appel de Paris vient remettre en cause la localisation du siège de direction effective d'une société localisée au Royaume-Uni en recherchant le lieu effectif de prise de décisions stratégiques et en...more

Reap What You Sow – UK’s Unallowable Purpose Rule Considered Again

Cadwalader, Wickersham & Taft LLP on 1/22/2025

In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (“Syngenta”), the UK’s First-tier Tribunal (“FTT”) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the...more

Extracting Value

Cadwalader, Wickersham & Taft LLP on 10/23/2024

Establishing the timing of a corporate dividend can be an important feature in a number of transactions where value is being extracted from a company. In the recent case of HMRC v Gould [2024] UKUT 00285 (TCC) (“Gould”), the...more

An option to dispose of property does not necessarily give rise to a taxable disposal

Cadwalader, Wickersham & Taft LLP on 6/3/2024

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Pin-pointing Residence

Cadwalader, Wickersham & Taft LLP on 8/24/2023

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

A Deep Dive into Recent Pension Tax Changes in the UK

Littler on 4/27/2023

In March, the UK government announced changes to the tax regime surrounding pensions as part of the annual Budget. In this piece, we take a deep dive into what these changes are, who they affect, what employers should be...more

UK Tax Round Up - March 2023

Proskauer Rose LLP on 3/20/2023

Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more

Good v HMRC – What Does ‘Entitled To’ Mean?

Cadwalader, Wickersham & Taft LLP on 2/27/2023

The Court of Appeal in Good v HMRC [2023] EWCA Civ 114 upheld the decision of the Upper Tribunal in examining the meaning of “entitled to” in the context of Section 611 of the Income Tax (Trading and Other Income) Act 2005...more

UK Tax Round Up - October 2022

Proskauer Rose LLP on 11/1/2022

Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

Uk to Repeal Off-payroll Working (Ir35) Rules

Morgan Lewis on 9/30/2022

The UK government’s “Growth Plan” (or “mini-budget”), delivered on 23 September, announced that the recent changes to the United Kingdom’s off-payroll working rules will be repealed with effect from April 2023....more

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

Cadwalader, Wickersham & Taft LLP on 9/23/2022

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

BlueCrest Salaried Members Case: Who Is a Significant Influencer?

Cadwalader, Wickersham & Taft LLP on 8/22/2022

BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) is the first case considering the UK salaried members rules under ss 863A – 836G Income Tax (Trading and Other Income) Act 2005 (the “Salaried Members...more

BlueCrest FTT Decision – Salaried Member Rules and Asset Managers

Proskauer - Tax Talks on 7/14/2022

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

UK Tax Round Up - May 2022

Proskauer Rose LLP on 6/8/2022

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

UK Tax Round Up - September 2021

Proskauer Rose LLP on 9/30/2021

In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

McDermott Will & Schulte on 7/28/2021

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Schulte on 6/15/2021

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

Income Taxes › Tax Liability › United Kingdom