United Kingdom: Tax Treaties

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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.

UK Government Launches Consultation On Solving The LLC Double Taxation Problem

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.

United Kingdom Tax

M

Macfarlanes LLP

UK Government Proposes Reform Of Taxation Of LLC Members

The UK government has launched a consultation on reforming the taxation of US LLC members, proposing to treat these entities as transparent for UK tax purposes to eliminate effective double taxation that can reach over 70%.

United Kingdom Tax

TS

Travers Smith LLP

US And UK Mismatches: Hope For LLCs?

It's hard to imagine in this age of global harmony, but sometimes the US and the UK really don't get along very well. I'm talking of course about the US limited liability company (or LLC) and how it can be a very unfriendly vehicle...

Worldwide Commercial

LS

Lewis Silkin

Advantages Of Companies As UK Qualified Asset Holding Companies (QAHCs)

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.

United Kingdom Tax

W

Walkers

Exemption For Foreign Permanent Establishments Be Made Mandatory

United Kingdom Tax

TS

Travers Smith LLP

How Are UK Pensions Taxed In Italy?

SI

Spectrum IFA Group

UK REITs And Private Equity Real Estate Funds: Structuring Considerations

United Kingdom Finance

GT

Greenberg Traurig, LLP

Relying On A Tax Treaty Is Not An Abuse Of Law: Lessons From The Lehman Litigation

United Kingdom Tax

M

Macfarlanes LLP

"Taking Advantage" Of Double Tax Treaties?

United Kingdom Tax

TS

Travers Smith LLP

Schrödinger’s CATS: The Indeterminate Extent Of Deemed Trade Fictions

United Kingdom Tax

GT

Greenberg Traurig, LLP

Pause For Thought: Withholding Tax On UK Interest & Claiming Treaty Relief (Podcast)

United Kingdom Tax

TS

Travers Smith LLP

Mutual Agreement Procedures (MAP): OECD Publishes New Manual For Effective International Tax Disputes

United Kingdom Tax

M

Macfarlanes LLP

Understanding Progressive Taxation In The UK: Salary, Dividends And Pensions

DU

Dixcart UK

Impact On UK Tax Residence For Individuals Returning To The UK: Exception For "Exceptional Circumstances"

LS

Lewis Silkin

Síobhra Rush Speaks To RTÉ News On The Rights And Responsibilities In Taking Time Off Work (Video)

United Kingdom Employment

LS

Lewis Silkin

A Global View Of International Arbitration Trends With Gary Born (Podcast)

United Kingdom Litigation

W

WilmerHale

London X China Podcast Series - Episode 7: Trends In Global Pharma M&A

United Kingdom Healthcare

KL

Herbert Smith Freehills Kramer LLP

Too Big To Ignore: Regulating The Data Centre Boom

United Kingdom Energy

TS

Travers Smith LLP

Voices For Change: Leading In Transformational Times With Alexandre Menais (Podcast)

United Kingdom Commercial

AO

A&O Shearman

UK HMRC Pauses Concession On Failures To Withhold Tax On Interest Payments

HM Revenue & Customs (HMRC) has paused operation of its long‑standing practice under which, where UK‑source yearly interest was paid gross to a treaty-entitled overseas lender before HMRC clearance was obtained, the borrower, ...

United Kingdom Tax

MB

Mayer Brown

Autumn Budget 2025: Key Highlights And What They Mean For You

On Wednesday 26 November, Chancellor Rachel Reeves delivered her second Autumn Budget focusing on raising revenue through tax freezes and targeted levies, whilst increasing welfare support and minimum wage to address the cost-of-living pressures.

Worldwide Strategy

DU

Dixcart UK

Beyond The Non-Dom Era: Why A Will Is Central To UK Wealth Management

When the UK ended its non-domicile tax regime in April 2025, the change was more than just a technical tax reform, it was a signal that the country's relationship with global wealth had fundamentally shifted

Worldwide Strategy

DU

Dixcart UK

Reforms To UK Inheritance Tax: The Move To A Residence-based Regime

There have been major changes this year to the UK's tax regime for individuals with an international connection. Our separate article considers the abolition of the "non-dom" regime...

United Kingdom Tax

M

Macfarlanes LLP

Autumn Budget 2025: What To Expect

United Kingdom Strategy

DU

Dixcart UK

Territorial Aspects Of The New Carried Interest Regime

United Kingdom Tax

M

Macfarlanes LLP

Wealth And Inheritance Tax Planning: Strategic Approaches To Preserving And Transferring Your Wealth

United Kingdom Strategy

DU

Dixcart UK

New Identity Verification Requirements With Companies House

Worldwide Strategy

DU

Dixcart UK

Why Family Offices Are Staying In London Despite Proposed Tax Changes

Worldwide Strategy

DU

Dixcart UK

Tax Investigations And Disputes Newsletter - September 2025

United Kingdom Tax

M

Macfarlanes LLP

What Constitutes A POEM?

CW

Cadwalader, Wickersham & Taft LLP

HMRC To Have Access To Crypto-Transaction Data From 2026: What UK Taxpayers Need To Know

United Kingdom Tax

DU

Dixcart UK

The UK Statutory Residence Test (SRT) - What You Need To Know

United Kingdom Tax

AM

Alvarez & Marsal

Haworth v HMRC: There's No Place Like POEM

United Kingdom Tax

M

Macfarlanes LLP

What Constitutes A POEM?

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

CW

Cadwalader, Wickersham & Taft LLP

HMRC To Have Access To Crypto-Transaction Data From 2026: What UK Taxpayers Need To Know

From January 2026, UK taxpayers who use crypto-assets will face new reporting obligations under regulations aligned with the OECD's Crypto-Asset Reporting Framework (CARF).

United Kingdom Tax

DU

Dixcart UK

The UK Statutory Residence Test (SRT) - What You Need To Know

There are many reasons why individuals may decide to move to, or leave the UK tax year. Whilst complex, the SRT is designed to provide taxpayers with objective clarity on how they will be assessed by HMRC.

United Kingdom Tax

AM

Alvarez & Marsal

Haworth v HMRC: There's No Place Like POEM

In Haworth v HMRC [2025] EWCA Civ 822, the Court of Appeal (the Court) has delivered its decision in a tax dispute that began over two decades ago, involving a widely marketed tax scheme at the time...

United Kingdom Tax

M

Macfarlanes LLP

Plastics: Next Steps For The UN Global Plastics Treaty And Key UK And EU Regulatory Developments

United Kingdom Tax

AG

Addleshaw Goddard

From Crackdown To Calibration: The UK's Evolving Carried Interest Regime

In November, we covered the UK government's proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort...

United Kingdom Tax

AG

Akin Gump Strauss Hauer & Feld LLP

The U.S.-UK Trade Agreement Explained: Highlights And Implications

On May 8, 2025, the United States and the United Kingdom announced a significant trade agreement aimed at strengthening economic ties between the two nations.

United Kingdom Strategy

DU

Dixcart UK

UK–India Free Trade Agreement: Opportunities For Indian Individuals And Businesses

On 6 May 2025, the United Kingdom and India finalised a landmark Free Trade Agreement, marking a significant milestone in bilateral relations. This agreement, the UK's most substantial post-Brexit trade deal...

United Kingdom Strategy

DU

Dixcart UK

2025 UK Tax Changes For Non-Doms: Do's And Don'ts

Significant changes were introduced to the UK's tax rules for non-domiciled individuals from 6 April 2025. The remittance basis for non-UK domiciled individuals has been replaced with a residency-based system.

United Kingdom Immigration

DU

Dixcart UK

RBC: From The Island Of Literal Interpretation To The Continental Shelf

United Kingdom Tax

AG

Addleshaw Goddard

A New Era For UK Inheritance Tax: What The 2025 Reforms Mean For You

DU

Dixcart UK

Gifts With Reservation Of Benefit: A Common Pitfall In Inheritance Tax Planning

DU

Dixcart UK

Register Of Overseas Entities And Its Impact On Property Ownership

United Kingdom Tax

DG

Dixcart Group Limited

Non-Dom Alternatives

E

Eptalex Law Firm LLP

Short-Term Business Visitors – Are You Ready To Submit Your Appendix 4 Report?

United Kingdom Tax

M

Macfarlanes LLP

Understanding The UK's New Foreign Income And Gains Rules

DG

Dixcart Group Limited

UK Tax Round Up - February 2025

United Kingdom Tax

PR

Proskauer Rose LLP

New Service For Disclosing Errors In Claims For R&D Tax Relief

United Kingdom Tax

DU

Dixcart UK

Are You A UK Non Domiciled Person? You Must Relocate To Cyprus!

European Union Tax

CA

CYAUSE Audit Services Ltd

Lucy Byrne Examines The First Post-Budget HMRC Non-dom Taxation Subgroup Meeting In ThoughtLeaders4 Private Client Magazine

United Kingdom Tax

HL

Hunters

Understanding Tax Relief On Surgery Costs For Self-Employed Business Owners

DU

Dixcart UK

The End Of UK Non-Dom Tax Benefits: Should You Stay Or Go?

United Kingdom Tax

DG

Dixcart Group Limited

The End Of UK Non-Dom Tax Benefits: Should You Stay Or Go?

Worldwide Immigration

DU

Dixcart UK

The UK Autumn Budget 2024: Key Tax Changes And Implications For Non-Doms

Worldwide Immigration

DG

Dixcart Group Limited

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