United Kingdom: Tax Authorities

This weekly update from A&O Shearman's Pensions team covers critical developments in UK workplace pensions regulation, including extended consultation deadlines for the Value for Money framework, new guidance on pensions dashboards member queries, and an Upper Tribunal ruling on HMRC compliance obligations. The update provides essential insights for pension trustees and scheme managers navigating evolving regulatory requirements.

UK businesses routinely pay immigration fees on behalf of their workers, but the tax treatment of these costs is often misunderstood. With HMRC increasing its scrutiny and data-sharing with the Home Office expanding, sponsors must understand which costs are taxable benefits in kind and review their arrangements accordingly.

HM Treasury has issued new regulations deferring the UK tax adviser registration requirement for investment managers and other financial services firms until April 2027. The deferral applies to firms conducting regulated activities under the Financial Services and Markets Act 2000, regardless of their global location, while HMRC considers whether to permanently exclude such firms from the regime.

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treaty relief from withholding tax on interest paid overseas, acknowledging that the current system is complex and outdated.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.

The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.

The UK Government has launched a consultation on introducing a new criminal offence targeting reckless untrue statements in direct tax matters, potentially exposing taxpayers and advisers to up to two years' imprisonment. This proposed measure aims to bridge the gap between civil penalties for careless conduct and criminal sanctions for dishonest evasion, fundamentally changing how HMRC can prosecute tax compliance failures.

The High Court has refused permission for judicial review of the Government’s approach to consultation in relation to its reforms to inheritance tax (‘IHT’) reliefs for agricultural and business property...

For many horse owners, managing their own yard is a long-held ambition. Equestrian property, however, combines the complexity of a residential purchase with rural land law, planning regulation, specialist finance...

BCL Solicitors explores the psychological journey individuals face when confronted with HMRC investigations, particularly from the Fraud Investigation Service. The firm examines how taxpayer behaviour influences Schedule 24 penalties and the emotional stages people experience during tax investigations.