United Kingdom: Tax

The UK Government has launched a consultation proposing to treat US limited liability companies (LLCs) as transparent for UK tax purposes when held by individuals, addressing long-standing double taxation issues that have deterred internationally mobile individuals from living and investing in the UK.

The UK government has launched a consultation on reforming the taxation of US LLC members, proposing to treat these entities as transparent for UK tax purposes to eliminate effective double taxation that can reach over 70%.

It's hard to imagine in this age of global harmony, but sometimes the US and the UK really don't get along very well. I'm talking of course about the US limited liability company (or LLC) and how it can be a very unfriendly vehicle...

UK trust taxation presents complex challenges for international advisers, particularly with recent changes to inheritance tax rules and the introduction of the Foreign Income and Gains regime.

When someone dies, their estate may be subject to inheritance tax. The rules include allowances that can significantly reduce, or even eliminate, the tax due. For married couples and civil partners, those allowances can be more generous than many people expect.

The UK's trust environment has evolved significantly over the past two decades, with increasingly complex reporting requirements and tax legislation transforming what was once straightforward wealth preservation into a compliance-intensive undertaking. Modern trustees face challenges ranging from HMRC enquiries and beneficiary disputes to mandatory Trust Registration Service declarations and international reporting obligations under CRS and FATCA. Proper administration from the outset can mean the differenc

Supreme Court upholds Court of Appeal decision that structured LLP profit-sharing arrangements are subject to miscellaneous income tax charge, providing guidance on section 850 ITTOIA and section 687 ITTOIA with wider implications for partnership taxation.

HMRC Agent Updates for April and May 2026 detail changes to employment taxes, including expanded EMI thresholds, simplified ERS reporting, new workplace benefit exemptions, and updated NMW and student loan rates.

UK trust taxation presents complex challenges for international advisers, particularly with recent changes to inheritance tax rules and the introduction of the Foreign Income and Gains regime.

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.

The UK government plans to make the foreign permanent establishment exemption mandatory from January 2027, fundamentally changing how UK companies are taxed on overseas operations. This policy shift, accelerated for oil and gas companies to September 2026, will prevent businesses from using foreign branch losses to offset UK profits while exempting future foreign profits from UK tax. What implications will this have for international business structures, loss relief strategies, and the broader competitivene

With the rise and rapid adoption of advanced data analytics and AI tools, transfer pricing compliance and risk assessment is quickly shifting from being a documentation-focused process to a near real time, data-driven one.