United Kingdom: Corporate Tax

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
EMI Options, Growth Shares Or Both?
For eligible companies, EMI options and growth shares each offer distinct advantages in employee equity incentives. But what happens when you combine them? This analysis explores how EMI can wrap contingent growth-share interests, the valuation principles that must be respected, and why the hurdle, exercise price and performance conditions need to be designed together to avoid accidentally over-gearing management's participation.
United Kingdom Commercial
BS
Burges Salmon
Article
The UK REIT Market – What Is Happening?
The UK real estate investment trust market has evolved significantly since its inception nearly twenty years ago, transitioning from a landscape dominated by major listed property companies to one embracing a new private REIT regime. This shift, implemented in 2022, has opened opportunities for parties to access REIT benefits without the burden of public listing requirements, fundamentally changing the market dynamics.
United Kingdom Finance
BS
Burges Salmon
Article
Out With The (Very Very) Old: Reform Of Stamp Duty On Shares
The Government's draft legislation for a new Securities Transfer Tax (STT), published on 13 July 2026, was a bit of a landmark. Tax advisers will tell you, with a mix of shame and pride, that we still occasionally have to refer to nineteenth century legislation. The Stamp Act 1891 remains the foundation of stamp duty payable on share sales. The whole law in this area is a patchwork of bits of legislation spanning more than a century.
United Kingdom Tax
LS
Lewis Silkin
Article
Tax Investigations And Disputes Newsletter - September 2026
HMRC's enforcement agenda continues to intensify with new criminal offences for reckless statements, mandatory error correction obligations, and expanded compliance burdens on taxpayers and advisers. Recent Supreme Court decisions in BlueCrest and HFFX have narrowed the ground available to taxpayers, while the Court of Appeal's pushback in M R Currell offers some relief against overreach in disguised remuneration rules.
United Kingdom Tax
M
Macfarlanes LLP
Article
Can We Fix It? Yes, We Must! HMRC’s New Error Correction Powers
The UK Government has introduced draft legislation requiring taxpayers to actively correct errors in their tax returns, fundamentally shifting responsibility from HMRC to individuals and businesses. The new framework includes a general obligation to self-correct inaccuracies and introduces Customer Correction Notices, which allow HMRC to require taxpayers to review specific positions. Failure to correct identified errors will result in them being reclassified as deliberate, triggering significantly harsher
United Kingdom Tax
M
Macfarlanes LLP
Article
Recent Changes To UK Tax Clearance For Restructuring
Recent UK Budget 2025 reforms have fundamentally altered the tax clearance regime for corporate restructurings, removing the explicit "bona fide commercial reasons" test and the 5% shareholder exemption while introducing new counteraction powers. These changes require businesses to provide more robust documentation of commercial objectives and prepare for heightened scrutiny from HMRC when seeking clearance for transactions including share exchanges, demergers, and company reconstructions.
United Kingdom Tax
GGI Global Alliance
Article
What's Happening In Pensions - Issue 124
The UK government has introduced draft legislation enabling defined benefit pension schemes to release surplus funds directly to members from April 2027, while HMRC updates to VAT guidance create uncertainty around input tax recovery for scheme administration costs. Meanwhile, new inheritance tax information-sharing requirements take effect, and the Pensions Regulator sets out its five-year strategic priorities focused on innovation, value for money, and supporting UK economic growth.
United Kingdom Employment
TS
Travers Smith LLP
Article
Inheritance Tax Planning: Protecting Your Wealth Without Fracturing Your Family
For many of our clients, the next twelve months will be a turning point in how they think about passing on wealth. The nil-rate band remains frozen at £325,000, with the residence nil-rate band fixed at £175,000 until at least April 2031. From April 2026, 100% agricultural and business property relief has been capped at £1 million of combined value and from 6 April 2027 most unused pension funds will be brought into the scope of inheritance tax for the first time.
Worldwide Commercial
DG
Dixcart Group Limited
Article
Employer Recovery Of VAT On Pension Scheme Costs: Updated HMRC Policy
HMRC has updated its VAT Input Tax Manual and VAT Notice 700/17, introducing significant changes to how employers and trustees can recover VAT on services provided to funded occupational pension schemes. While some changes reflect previously announced policies, the updates appear to narrow the circumstances for VAT recovery on administration services and remove guidance on tripartite agreements, creating uncertainty about the path forward for pension scheme arrangements.
United Kingdom Tax
MB
Mayer Brown
Article
The New UK Securities Transfer Tax: 10 Key Points
The UK government has published draft legislation for a new Securities Transfer Tax (STT) set to replace stamp duty and SDRT in 2027, marking a significant modernisation of the UK's share taxation regime. While the main 0.5% rate remains unchanged, the reform introduces a single, digitally-administered framework that promises to simplify compliance and accelerate share registration processes. This comprehensive analysis examines ten critical aspects of the proposed legislation, from timing accommodations fo
United Kingdom Tax
MB
Mayer Brown
Article
Tax Focus Podcast: Income Or Capital? HMRC's Consultation On Modernising The Distributions Framework
HMRC has launched a consultation proposing fundamental reform to the UK's distribution framework, potentially one of the most consequential tax law consultations in decades. The proposals aim to modernize rules that have remained largely unchanged since 1965, addressing how payments from companies to shareholders are taxed and closing perceived loopholes that allow value extraction at capital gains rates rather than dividend rates. The consultation covers seven key areas including reductions of capital, dem
United Kingdom Tax
TS
Travers Smith LLP
Video
Introducing Family Investment Companies (Video)
Family investment companies (FICs) are increasingly being used as succession planning vehicles as an alternative to traditional trusts. This video explores how FICs enable families to transfer wealth to future generations while maintaining control, examining the tax efficiency, governance structures, and practical considerations that determine whether a FIC is the right choice for a family's circumstances.
United Kingdom Wealth Mgt
WL
Withers LLP
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