United Kingdom: Tax Authorities

Subscribe
Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Tax Bites - October 2026
RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.
United Kingdom Tax
RPC
Article
Upper Tribunal Dismisses HMRC's Appeal And Confirms That Taxpayers Were Carrying On A Business With A View To Profit
The Upper Tribunal examined whether a limited liability partnership was carrying on a business with a view to profit when loan notes were transferred to it, determining the application of capital gains tax provisions. The case explores the interpretation of 'business' in tax legislation and the application of the Ramsay principle of purposive statutory construction in the context of a tax mitigation arrangement.
United Kingdom Tax
RPC
Article
HMRC’s New Anti-avoidance Information Notice Powers
HMRC has introduced anti-avoidance information notices (AAINs) under Part 6 of the Finance Act 2026, granting significantly broader powers to investigate tax avoidance promotion and facilitation. These notices can target a wide network of connected persons—including directors, advisers, and intermediaries—without requiring proof that tax was lost or that arrangements were ineffective. With substantial civil and criminal penalties for non-compliance, businesses and advisers must understand who ca
United Kingdom Tax
RPC
Article
Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases
Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United Kingdom Tax
M
Macfarlanes LLP
Article
Consultation On The Withholding Tax Regime: What You Need To Know
The UK Government has launched a consultation proposing significant changes to the withholding tax regime on interest payments to overseas lenders. The proposed reforms would shift from HMRC's current gatekeeping role to a self-assessment system where UK borrowers independently determine treaty relief eligibility, fundamentally altering compliance responsibilities and risk allocation in cross-border lending arrangements.
United Kingdom Tax
Shoosmiths LLP
Article
HMRC’s Proposed New Duty To Correct And The Rise Of Tax Governance: What Employers Need To Know
HMRC has proposed new legislation requiring taxpayers to correct known inaccuracies in tax returns, with failures to act being treated as deliberate behaviour attracting higher penalties and extended assessment periods. The draft legislation introduces a statutory duty to correct errors once identified and grants HMRC power to issue Customer Correction Notices, fundamentally shifting tax compliance from a technical exercise to a governance obligation that boards must actively oversee.
United Kingdom Tax
TLT
Article
Tribunal finds that film partnerships were carrying on a genuine trade
The First-tier Tribunal examined whether film production partnerships could claim tax relief on both equity-funded and debt-funded expenditure, distinguishing between genuine trading activities and arrangements designed primarily to enhance tax benefits. The case centered on partnerships that invested in film production through a combination of direct contributions and bank loans, with HMRC challenging the tax treatment of these transactions some 20 years after the relevant tax years.
United Kingdom Tax
RPC
Article
Can We Fix It? Yes, We Must! HMRC’s New Error Correction Powers
The UK Government has introduced draft legislation requiring taxpayers to actively correct errors in their tax returns, fundamentally shifting responsibility from HMRC to individuals and businesses. The new framework includes a general obligation to self-correct inaccuracies and introduces Customer Correction Notices, which allow HMRC to require taxpayers to review specific positions. Failure to correct identified errors will result in them being reclassified as deliberate, triggering significantly harsher
United Kingdom Tax
M
Macfarlanes LLP
Article
Recent Changes To UK Tax Clearance For Restructuring
Recent UK Budget 2025 reforms have fundamentally altered the tax clearance regime for corporate restructurings, removing the explicit "bona fide commercial reasons" test and the 5% shareholder exemption while introducing new counteraction powers. These changes require businesses to provide more robust documentation of commercial objectives and prepare for heightened scrutiny from HMRC when seeking clearance for transactions including share exchanges, demergers, and company reconstructions.
United Kingdom Tax
GGI Global Alliance
Article
Exemption For Foreign Permanent Establishments To Be Made Mandatory
The UK government plans to fundamentally reshape how British companies are taxed on their overseas operations by making the foreign permanent establishment exemption mandatory from 2027, with oil and gas companies facing an accelerated implementation timeline. This policy shift eliminates the current flexibility that allows UK businesses to offset foreign branch losses against domestic profits, raising critical questions about international competitiveness and investment strategy.
United Kingdom Tax
TS
Travers Smith LLP
See more

Latest Videos

See more