United Kingdom: Income Tax

Explore how family investment companies and family limited partnerships enable wealth transfer to the next generation while maintaining control. Our lawyers examine the tax implications, governance structures, and jurisdictional considerations that determine which succession planning vehicle best aligns with your family's long-term wealth management objectives.

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

HMRC has launched a consultation on simplifying treaty relief from withholding tax on interest paid overseas, acknowledging that the current system is complex and outdated. The consultation proposes allowing taxpayers to self-assess whether treaty relief applies, moving away from the cumbersome advance treaty application process that can take over a year to complete.

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.

Individuals and unincorporated businesses pay capital gains tax (CGT) on any gain, whilst companies include the gain in their total taxable profit, taxed at the corporate rate.

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.

HMRC's compliance toolkit continues to expand, with proposals to widen the uncertain tax treatment notification regime which would draw significantly more taxpayers into scope.

HMRC has increasingly targeted employee share plans under disguised remuneration rules, challenging arrangements involving third-party participation even when no tax avoidance motive exists.

HMRC's March Agent Update introduces significant changes to employment tax administration, including quarterly reviews of the official rate of interest, new PAYE responsibilities for labour supply chains involving umbrella companies, and modifications to Overseas Workday Relief notifications. These updates will impact how employers manage tax compliance and reporting obligations from April 2026 onwards.