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Tax Planning United Kingdom Income Taxes

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

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On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Latham & Watkins LLP

The UK’s New Regime for Carried Interest Taxation - How the Draft Legislation Stacks Up

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On 21 July 2025, the UK government published draft legislation relating to its new carried interest regime. This Client Alert considers key aspects of the new regime and how it may apply to UK-based asset managers and non-UK...more

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Proskauer Rose LLP

UK Tax Round Up - June 2025

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Welcome to the June edition of our UK Tax Round Up, which discusses HMRC’s response to its consultation on the new UK carried interest regime to be introduced next year and interesting cases on the main purpose test in the...more

IR Global

Higher rate tax relief on pension contributions

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Want to make the most of your pension savings? You could claim up to 45% tax relief on contributions, plus carry forward unused allowances. Here’s how to boost your retirement pot with generous HMRC incentives....more

Goodwin

A New UK-based Unauthorised Fund Vehicle Now Available - The Reserved Investor Fund

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The new UK fund vehicle Reserved Investor Fund (RIF) is available beginning today, 19 March 2025. The RIF is available for all investment strategies, but what might make it an appealing option, particularly certain tax...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

Proskauer Rose LLP

UK Tax Round Up - January 2025

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Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax...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

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

IR Global

How donations to charity can provide tax relief

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Gift Aid transforms charitable donations by allowing charities and CASCs to claim 25p extra for every £1 given—at no additional cost to you. Higher and additional rate taxpayers can also claim valuable tax relief, making...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

Hogan Lovells

Establishment of a business in the United Kingdom by a foreign corporation (UPDATE)

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This note describes in outline the laws and taxes which currently apply to a foreign corporation establishing a business operation in the United Kingdom and the administrative requirements which need to be observed once the...more

Morgan Lewis

UK Government Updates Tax Regime for Carried Interest

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As part of the Autumn Statement, the UK government on 30 October 2024 announced a reform of its taxation of carried interest. This follows a call for evidence on the reform of the UK taxation treatment of carried interest in...more

Cadwalader, Wickersham & Taft LLP

The UK Government’s Autumn Budget 2024

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more

Cadwalader, Wickersham & Taft LLP

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

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

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

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As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

Hogan Lovells

UK: HMRC changes to notification process for opting to tax on land and buildings

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Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

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Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...more

Morgan Lewis

Uk to Repeal Off-payroll Working (Ir35) Rules

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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

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

Cadwalader, Wickersham & Taft LLP

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

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

Proskauer Rose LLP

UK Tax Round Up - March 2022

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Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Proskauer Rose LLP

UK Tax Round Up - February 2022

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Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more

A&O Shearman

Government Releases Final Tax Regulations on the Transition from Interbank Offered Rates

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On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...more

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