News & Analysis as of

Tax Liability United Kingdom

IR Global

Why filing early makes sense

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Filing your 2024-25 Self-Assessment return early means faster refunds, better budgeting, and no deadline stress. Do not delay, start gathering your tax details today....more

DLA Piper

Customs Agent Ordered to Pay GBP1m in Import VAT Relating to its Customer's Imports

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Roseline Logistics Ltd (Roseline) acted as a Customs agent for QP Trading Limited (QPTL) and made 32 import declarations between January and May 2022. Roseline claimed postponed VAT accounting (PVA) on QPTL's behalf in each...more

Proskauer Rose LLP

UK Tax Round Up - May 2025

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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

Proskauer - Tax Talks

UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits Clarified

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June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from...more

Goodwin

UK Government announces update on new carried interest tax regime

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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

Akin Gump Strauss Hauer & Feld LLP

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Goodwin

UK Salaried Member Employment Tax Rules - Recent Developments

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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

A&O Shearman

The UK's carbon border adjustment mechanism continues to take shape

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Ahead of the commencement of the UK Carbon Border Adjustment Mechanism (CBAM), key building blocks for its regulatory framework are moving into place. Following consultations in 2023 and 2024, draft legislation and a policy...more

Hogan Lovells

UK VAT on insurance intermediary services – exemption expanded?

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The Court of Appeal (CA) in WTGIL Ltd v HMRC [2025] EWCA Civ 399 considered the scope of the VAT exemption for services supplied by insurance intermediaries. The case concerned motor insurance for young drivers which required...more

Ropes & Gray LLP

Duty-Free: The New UK Single Tax on Securities

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The replacement of the UK’s paper-based stamp duty (SD), and its electronic cousin stamp duty reserve tax (SDRT), with a unified and modernised single tax on securities transactions re-emerged this week as a Government...more

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

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On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more

Walkers

Retiring trustee – reasonable security and retention of assets

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Under section 43(b) of the Trusts (Guernsey) Law, 2007, when a trustee resigns or is removed it may require that it be provided with reasonable security for liabilities before surrendering trust property....more

Katten Muchin Rosenman LLP

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

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

Cadwalader, Wickersham & Taft LLP

Determining Significant Influence

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

IR Global

Stamp Duty Land Tax Changes from April 2025

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Stamp Duty Land Tax Changes from April 2025: What Buyers Need to Know - From 1st April 2025, significant changes to Stamp Duty Land Tax (SDLT) will take effect, impacting buyers across England and Wales. These adjustments...more

Mayer Brown

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Members of UK LLPs and Significant Influence: Commentary on HMRC v. BlueCrest Capital Management (UK) LLP

On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more

Cadwalader, Wickersham & Taft LLP

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

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

Mayer Brown

Autumn Budget 2024 – pensions-related announcements

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The Autumn Budget contained the following key announcements affecting occupational pension schemes...more

Cooley LLP

UK Government Sets Tax Agenda

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On October 30, 2024, the Labour government delivered its first Budget since assuming power in July 2024. The Budget is the main annual fiscal event in the UK, and yesterday’s announcements were an important opportunity for...more

Cadwalader, Wickersham & Taft LLP

Extracting Value

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

Cadwalader, Wickersham & Taft LLP

Not Yet Fixed in Place

In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more

Katten Muchin Rosenman LLP

UK Financial Insights from Katten | Issue 12

UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe....more

Orrick, Herrington & Sutcliffe LLP

Founder Series: Top Tips to Fund Your Innovation

Orrick's Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of our...more

Goodwin

A Token of Appreciation: Cryptoassets and Employee Incentives - a UK Tax Primer

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Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more

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