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UK Tax Round Up - July 2024

Welcome to the July edition of the UK Tax Round Up. This month features a call for evidence from the government on potential changes to the tax on carried interest and interesting decisions on the application of the carried...more

UK Tax Round Up - June 2024

Welcome to the June edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision...more

UK Tax Round Up - April 2024

Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more

UK Tax Round Up - March 2024

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

UK Tax Round Up - February 2024

Settlement payment subject to tax as employment income - In Mathur v HMRC, the Upper Tribunal (UT) has upheld the FTT’s decision that a £6 million settlement payment to a former employee following an employment tribunal...more

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

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

UK Tax Round Up - January 2024

Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

UK Tax Round Up - December 2023

Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

HMRC updates guidance on UK tax status of non-UK entities and US LLCs post Anson

On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and other US) limited liability companies (LLCs) in particular (in INTM180000...more

UK Tax Round Up - November 2023

Welcome to November’s edition of the UK Tax Round Up. This month has seen the Chancellor’s Autumn Statement as well as an interesting confirmation from the Court of Appeal on the scope of “arrangements” for capital gains tax...more

UK Tax Round Up - October 2023

Welcome to the October edition of the UK Tax Round Up. This month has seen the Supreme Court’s judgment on the operation of the employment-related securities deeming provision, the Court of Appeal’s decision on what...more

UK Tax Round Up - September 2023

Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more

UK Tax Round Up - August 2023

Welcome to August’s edition of our UK Tax Round Up. This month has seen two interesting decisions from the Upper Tribunal, the first on the loan relationship unallowable purpose test and the second on the meaning of...more

UK Tax Round Up - July 2023

Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more

UK Tax Round Up - June 2023

Welcome to June’s edition of our UK Tax Round Up. Several interesting cases have been reported this month, including a range of issues relevant to UK withholding tax on interest being considered in Hargreaves. HMRC has also...more

UK Tax Round Up - May 2023

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

UK Tax Round Up - April 2023

Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting cases highlighting the need for taxpayers and HMRC alike to apply a realistic approach to the facts in assessing the tax...more

UK Tax Round Up - March 2023 - 2

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

UK Tax Round Up - March 2023

Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more

Upcoming changes to the company share options plan regime

Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise employees in a tax-efficient way. Broadly, where the relevant qualifying...more

UK Tax Round Up - February 2023

VAT incurred on corporate advisory fees not recoverable - In Ince Gordon Dadds LLP v HMRC, the First-tier Tribunal (FTT) has decided that Ince Gordon Dadds LLP (formerly Culver Holdings Limited and the taxpayer) (Culver)...more

UK Tax Round Up - November 2022

Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

UK Tax Round Up - October 2022

Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

Massive U-Turn on Mini Budget

As has been widely reported, a number of the Mini Budget proposals (summarised in our recent Tax Blog) have been scrapped. The new Chancellor of the Exchequer Jeremy Hunt announced these measures claiming that they are...more

UK Tax Round Up - September 2022

Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more

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