News & Analysis as of

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

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

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

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

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

Cooley LLP

UK Reporting for Share Plans With UK Participants Due 6 July

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The deadline is approaching for the HM Revenue & Customs (HMRC) year-end reporting requirements for companies in the UK, US and elsewhere with share options and other share awards granted to – and share acquisitions by – UK...more

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...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

Hogan Lovells

UK pensions legal landscape: What’s new in February / March 2025

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In this news update, we highlight legal developments in UK pensions over the past five weeks. This update covers: News from the Pensions Regulator (TPR) Data strategy Preventing pension scams Priorities for 2025 DC and...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

A&O Shearman

Pensions: what's new this week - January 27, 2025

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Welcome to your weekly update from the A&O Shearman pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions. Auto-enrolment trigger and earnings band to remain unchanged...more

Proskauer - Tax Talks

BlueCrest – the Court of Appeal considers Condition B of the salaried members rules

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The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain...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

Carried interest taxation in the UK: reform but not abolition

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In the Autumn 2024 Budget, the UK Government announced fundamental changes to the way that carried interest will be taxed in the UK. Major change in this area was expected and there will be a number of qualifying conditions,...more

Walkers

Channel Islands Regulatory Update - January 2025

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On 5 December 2024 the UK's Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 came into force. The UK Regulations are made under the UK Sanctions and Anti-Money Laundering Act 2018 ("SAMLA") and make...more

Proskauer Rose LLP

UK Tax Round Up - December 2024

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Welcome to the December 2024 edition of our UK Tax Round Up. This month has seen interesting decisions on the basis for rescission of an arrangement with adverse tax consequences, the treatment of a loan from an EBT, the tax...more

Cadwalader, Wickersham & Taft LLP

Wrapping Up the UK’s CARF

In November 2023, the United Kingdom (“UK”) and 47 other jurisdictions agreed to implement the Organisation for Economic Co-operation and Development (“OECD”) Crypto-asset Reporting Framework (“CARF”) into domestic law....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

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