United Kingdom: Directors and Officers

HMRC has proposed sweeping new reporting requirements for close companies that would mandate detailed disclosure of all transactions with participators, extending far beyond the current framework which only captures loans triggering tax charges. The consultation raises critical questions about the burden on privately-owned groups and private equity structures, where intra-group transactions could generate extensive reporting obligations despite no underlying tax liability.

Our Senior Consultant Spencer Summerfield has been the Contributing Editor of the Chambers and Partners 2025 Global Practice Guide on Shareholders' Rights & Shareholder Activism.

The dispute arose from a (solvent) members' voluntary liquidation of three venture capital trust companies (the Core VCT companies). In March 2015, Begbies Traynor...