United Kingdom: Income Tax

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Article
UK Changes To Taxing Foreign Profits Would Carry Economic Risk
The UK tax authority is proposing sweeping changes to how it taxes individuals for company distributions and capital reductions, modernizing outdated legislation to ensure economically similar payments receive consistent tax treatment. However, these proposals represent a significant departure from long-established rules that underpin the UK's attractiveness as a place to do business and invest, potentially inflicting collateral damage on wider commercial activity and retail investors.
United Kingdom Tax
M
Macfarlanes LLP
Article
BlueCrest: UK Supreme Court Clarifies “significant Influence” Under The LLP Salaried Members Rules
The Supreme Court has clarified the application of the salaried members rules to investment management LLPs in HMRC v BlueCrest Capital Management, establishing that significant influence must be grounded in legally enforceable rights rather than commercial importance or investment responsibilities. The decision narrows the scope for portfolio managers and desk heads to rely on Condition B, requiring investment management LLPs to review their governance arrangements and member classifications.
United Kingdom Tax
PR
Proskauer Rose LLP
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
Bluecrest - UK Supreme Court Confirms Interpretation Of The LLP Salaried Member Rules
The UK Supreme Court has delivered its judgment in HMRC v Bluecrest Capital Management (UK) LLP, addressing critical questions about when LLP members should be treated as self-employed versus employees for tax purposes. The ruling clarifies the interpretation of "disguised salary" and "significant influence" tests, establishing that influence must derive from legally enforceable rights rather than informal commercial importance.
United Kingdom Tax
D
Dechert
Article
Finance Act 2026: Inheritance Tax Treatment Of Pension Death Benefits
The Finance Act 2026 introduces fundamental changes to how inheritance tax applies to pension death benefits from April 2027, shifting most lump sum payments into deceased members' estates while creating new reporting obligations for personal representatives and scheme trustees. Understanding these changes is critical for pension trustees who must now prepare their administration processes, governance frameworks, and member communications to comply with the new regime.
United Kingdom Tax
MB
Mayer Brown
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