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United Kingdom HMRC Taxation

Ropes & Gray LLP

When Tax Meets Automation: Lessons From HMRC's Use (Or Not) Of Artificial Intelligence

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As businesses and individuals in the UK continue to explore the possibilities offered by artificial intelligence, it should come as no surprise that the Government has also embraced AI. Increasing productivity in the civil...more

K&L Gates LLP

Europe: Fundamental Reform of UK Taxation of Carried Interest

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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

Proskauer Rose LLP

UK Tax Round Up - July 2025

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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more

Hogan Lovells

UK Pensions and Inheritance Tax (IHT): Revised Policy from HMRC

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HMRC has taken on board concerns from the pensions industry about its previous proposals for bringing many pension death benefits within the scope of inheritance tax (IHT). On 21 July 2025, HMRC issued a Policy Paper and...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

Mayer Brown

Inheritance Tax on Pension Death Benefits – Revised Proposals

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The government has responded to its consultation on its proposal that from 6 April 2027, most death benefits paid from registered pension schemes (whether DB or DC) will form part of the deceased member’s estate for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

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

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

Mayer Brown

Recovery of VAT on DB Pension Scheme Investment Costs – New HMRC Policy

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HMRC has announced a new policy on the recovery by employers of VAT charged on investment services provided to their DB pension schemes. Until 18 June 2025, the extent to which an employer could recover any VAT paid on...more

Wilson Sonsini Goodrich & Rosati

FAQs: UK Employee Equity Incentive Annual Reporting and EMI Notification Deadline Fast Approaching

Companies operating employee equity incentive arrangements in the UK, including companies incorporated or registered outside of the UK, are mandated to file an online annual return with HM Revenue & Customs (HMRC) no later...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Targets Reform of the Investment Manager Exemption

On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more

Proskauer Rose LLP

UK Tax Round Up - April 2025

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Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

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On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

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Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

A&O Shearman

UK carbon border adjustment mechanism: shaping up ahead of 2027

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In 2027, the UK will introduce a carbon border adjustment mechanism (CBAM) on imports of certain carbon intensive goods. The CBAM will impose a charge on the emissions embodied in relevant imports that take place on or after...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

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The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

Proskauer Rose LLP

UK Tax Round Up - May 2023

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Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more

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