United Kingdom: Tax Treaties

Tax Counsel Elizabeth Spencer shares insights from her career in tax law, discussing her diverse practice spanning transactions, advisory work, and contentious matters at McDermott Will & Emery. She reflects on the evolving nature of tax legislation and offers perspective on building expertise in this dynamic field.

HMRC has launched a consultation on simplifying treaty relief from withholding tax on interest payments made overseas, addressing longstanding administrative challenges in the current system. The consultation explores potential reforms including a self-assessment approach that would eliminate the need for prior HMRC direction, fundamentally changing how UK borrowers and overseas lenders navigate cross-border financing arrangements.

HMRC has issued new compliance guidelines for employers managing short-term business visitors to the UK, clarifying common misconceptions about tax liabilities and treaty obligations. The guidance highlights critical errors employers make when handling international mobility, from miscounting UK days to misunderstanding double-taxation treaties.

A crucial requirement for QAHC eligibility is that the company is UK tax-resident, but not that it is a UK company and therefore both Jersey and Guernsey incorporated companies are eligible.

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

Understanding how Italy taxes foreign pensions is crucial for anyone relocating with retirement savings built under different tax models. This analysis explores the fundamental differences between the UK's EET...

Last month, Bloomberg reported that despite the abolition of the UK non-dom regime and the looming prospect of wealth taxes, London remains a magnet for family offices.

When Labour were elected a little over a year ago, we noted some interesting political and cultural similarities with the time of the last Labour victory in 1997 (and some stark differences).

In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach...