United Kingdom: Tax

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Article
Tax Bites - October 2026
RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.
United Kingdom Tax
RPC
Article
Upper Tribunal Dismisses HMRC's Appeal And Confirms That Taxpayers Were Carrying On A Business With A View To Profit
The Upper Tribunal examined whether a limited liability partnership was carrying on a business with a view to profit when loan notes were transferred to it, determining the application of capital gains tax provisions. The case explores the interpretation of 'business' in tax legislation and the application of the Ramsay principle of purposive statutory construction in the context of a tax mitigation arrangement.
United Kingdom Tax
RPC
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Tax Disputes
CT
Corporate Tax

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Inheritance Tax

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Income Tax

Article
Tax Bites - October 2026
RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.
United Kingdom Tax
RPC
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Transfer Pricing

Article
Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases
Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United Kingdom Tax
M
Macfarlanes LLP
Article
Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case
When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European Union Tax
RPC
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Latest Videos

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