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United Kingdom Tax Planning

Orrick, Herrington & Sutcliffe LLP

UK Founder Series: Maximising Funding Opportunities for UK Tech Startups with SEIS and EIS

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. ...more

Cadwalader, Wickersham & Taft LLP

What Constitutes a POEM?

In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach to determining the ‘place of effective management’ (POEM) in the context of the UK’s double tax...more

McDermott Will & Schulte

Carried interest in the UK: The new average holding period (AHP) condition for credit funds

The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more

Carey Olsen

Guernsey funds – special considerations for US managers

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Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

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

Ius Laboris

Pensions on Divorce: Practical Hurdles and the Gender Pension Gap

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The UK pension sharing system often results in poor outcomes for divorced women due to its complexity and low uptake. Practical issues like timing delays, unresponsive ex-spouses, and fluctuating pension credit values further...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

Cadwalader, Wickersham & Taft LLP

UK-Perimeter Tax Rules Under the Spotlight

On 28 April 2025, the UK government launched a consultation (the “Consultation”) on proposed legislation to reform the UK’s transfer pricing (“TP”) and permanent establishment (“PE”) rules, including changes to the investment...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

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

Wilson Sonsini Goodrich & Rosati

Key UK Tax Implications of the Delaware Flip

U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...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

Hogan Lovells

What's new in the UK Pensions legal landscape? 24 March 2025

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This update covers: On 20 March last week, the Finance Bill received Royal Assent and became the Finance Act 2025. The provisions relevant to pensions make changes to: Further details are given below....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

A&O Shearman

UK Pensions: what's new this week - March 10, 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. DWP 'actively considering' whether to give a legislative fix...more

Proskauer Rose LLP

UK Tax Round Up - February 2025

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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Cadwalader, Wickersham & Taft LLP

The New UK Reserved Investor Fund: RIFs and QAHCs Create an Ambitious UK Structuring Toolkit

Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....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

Katten Muchin Rosenman LLP

Will Pillar Two Crumble Before It's Built?

Over 135 jurisdictions signed up for a global Organisation for Economic Cooperation and Development (OECD) project in October 2021 aimed at reforming the international taxation system. A Two-Pillar approach was developed to...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

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