United Kingdom: Corporate Tax

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Article
Travers Smith's Alternative Insights: The Dangers Of Over-Zealous Enforcement
The UK's new government faces a delicate challenge: raising revenue from higher earners while maintaining London's status as a global financial hub. Recent Supreme Court victories by HMRC against major hedge funds signal an increasingly aggressive stance on executive remuneration that could pose fresh obstacles for private capital firms already grappling with carried interest reforms and non-dom rule changes.
United Kingdom Tax
TS
Travers Smith LLP
Article
Family Investment Companies: A Flexible Tool For Private Clients
Family investment companies are gaining traction as wealth planning vehicles in the UK, offering potential tax advantages and succession planning benefits through carefully structured share classes. However, their effectiveness depends heavily on asset profiles, family objectives, and international considerations, with complex technical rules requiring careful navigation to avoid potential pitfalls.
United Kingdom Family
WL
Withers LLP
Article
HMRC Consults On Aligning The Taxation Of Distributions From Non-UK Resident Companies
HMRC has launched a consultation proposing significant reforms to the UK tax framework for distributions and capital repayments, with a key focus on aligning the income tax treatment of distributions from UK and non-UK resident companies. The proposals could fundamentally reshape how returns of value are taxed for individual and trust shareholders, potentially affecting private equity structures, investment funds, and family offices using non-UK holding companies.
United Kingdom Tax
PR
Proskauer Rose LLP
Article
UK Tax Update: Why The UK Remains Open For Business For Investment Managers
Recent UK tax reforms affecting investment managers signal continued government support for the asset management industry, despite initial concerns about competitiveness. While carried interest taxation has evolved and new compliance requirements emerge, simplification of key rules like the Investment Manager Exemption demonstrates the UK's commitment to maintaining its position as a global asset management hub.
United Kingdom Tax
SR
McDermott Will & Schulte
Article
Supreme Court Decides The LLP Salaried Member Rules - But Sends BlueCrest Back To The First-Tier Tax Tribunal
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management, clarifying the salaried member rules that determine whether LLP members are taxed as employees or partners. The ruling refines the legal test for "significant influence" and establishes that influence must derive from enforceable governance frameworks rather than informal practice, with immediate implications for how LLPs structure membership terms and delegated authority.
United Kingdom Tax
M
Macfarlanes LLP
Article
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
The UK Supreme Court has delivered a landmark ruling on the "salaried members rules" for Limited Liability Partnerships, significantly narrowing the interpretation of when members can claim "significant influence" to avoid employee tax treatment. The decision confirms that influence must derive from legal rights in the LLP agreement and be exercised at a strategic level over the partnership's affairs generally, rather than through operational roles or financial importance.
United Kingdom Tax
TS
Travers Smith LLP
Article
Reward Summer Update 2026
This comprehensive update examines significant changes to UK employee share schemes and executive remuneration, including expanded eligibility for the Enterprise Management Incentive scheme, the introduction of PISCES trading platform for private company shares, and modifications to Employee Ownership Trust tax relief. The analysis covers recent tribunal decisions on employment status and proprietary estoppel claims, providing critical insights for companies managing employee equity compensation.
United Kingdom Employment
M
Macfarlanes LLP
Article
Beyond Cost-Plus: What The OECD's New Approach To Intra-Group Services Means For UK Taxpayers
The OECD has proposed significant revisions to its transfer pricing guidance on intra-group services, expanding practical examples and emphasizing the need for robust documentation to evidence service provision and benefits. While core principles remain unchanged, the updates create potential tensions with HMRC's more prescriptive approach to high-value services, particularly around pricing methodologies and the treatment of shareholder activities.
United Kingdom Tax
M
Macfarlanes LLP
Article
When Is A Day Not A Day? UK Tax Residence And The Statutory Residence Test
The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.
United Kingdom Commercial
DG
Dixcart Group Limited
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