UK corporate offence of failure to prevent tax evasion
ISSUES AFFECTING ALL SCHEMES INHERITANCE TAX CHANGES - PROVISION OF INFORMATION REQUIREMENTS - HM Revenue & Customs (HMRC) has published draft regulations for consultation setting out the new provision of information...more
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
On 21 May 21 2026, HMRC published a policy paper proposing significant changes to the UK corporation tax treatment of UK resident companies who conduct part of their business through a foreign permanent establishment (PE). ...more
A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: Abolition of lifetime allowance (LTA): draft regulations Draft regulations making further amendments following the abolition...more
Welcome to our monthly update on current legal issues for trustees of DB and hybrid pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support the legal update item on...more
Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support the legal update item on your next...more
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....more
Major changes to inheritance tax (IHT) are on the way. From 6 April 2027, most death benefits paid by registered pension schemes will be treated as part of the deceased member’s estate for IHT purposes. This applies whether...more
A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: Pensions Regulator (TPR): AI plan TPR sets out its initial expectations on use of artificial intelligence (AI); Pensions...more
From April 6, 2027, the way that pension scheme death benefits are treated for inheritance tax (IHT) purposes will change significantly. Unused pension funds and death benefit lump sums will largely be brought within the...more
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. SUMMARY - • HMRC provides more detail on applying...more
A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: Data protection: new data protection complaints requirements Data controllers, including pension scheme trustees, will need...more
The Court of Appeal has confirmed in HMRC v M R Currell Ltd that, prior to the introduction of the disguised remuneration rules, a genuine and repayable loan made via an employee benefit trust (EBT) is not taxable as...more
In a key test case on the relevance of tax losses (and more broadly, HMRC) under Part 26A of the Companies Act 2006, Mr Justice Michael Green in the High Court has sanctioned the second restructuring plan (RP2) of Waldorf...more
Companies that award shares, options, or other securities to UK employees, directors, or officeholders need to be aware of the 6 July deadline to submit an employment related securities (ERS) annual return to HM Revenue &...more
The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking advantage of” it. The treaty anti-abuse rule will only apply where the...more
A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: The Pension Schemes Bill: receives Royal Assent The Pension Schemes Act 2026 has received Royal Assent and passes into law;...more
The UK Court of Appeal confirmed that the ‘related party’ rules in Part 8 of the Corporation Tax Act 2009 apply to LLP structures....more
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. TPR: updated dashboards guidance- TPR has updated its...more
In welcome news for secondary debt markets, the UK Court of Appeal upheld decisions in the lower tribunals in favour of the taxpayer that the “principal purpose test” (PPT) in the UK/Irish double tax treaty (DTT) did not...more
The much-anticipated Court of Appeal judgment in HMRC v. Burlington Loan Management DAC [2026] provides some welcome clarity and reassurance to taxpayers (and their advisers) grappling with the application of purpose tests in...more
The Finance Act 2026 has received Royal Assent, establishing the legal framework for the significant changes to the inheritance tax (IHT) treatment of death benefits paid by registered pension schemes that were announced in...more
The tax case of CooperVision , heard recently by the First Tier Tribunal, feels like a case we’ll hear more about over the next couple of years. This case concerns longstanding executives who had invested in a company and...more
Pension Schemes Bill: what next? On 26 March 2026, the Pension Schemes Bill completed its passage through the House of Lords with Third Reading. A number of minor consequential amendments were passed at this stage but,...more