United Kingdom: Withholding Tax

The Supreme Court’s recent decision in Skatteforvaltningen v MCML Ltd [2026] UKSC 19 is a welcome restatement of the scope of issue estoppel and provides useful guidance on its interaction with abuse of process.

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.

The Supreme Court has held that the Danish Customs and Tax Administration was not barred by issue estoppel from bringing new claims against the same defendant following the dismissal of its earlier claim under the rule which prevents English courts enforcing foreign tax claims.

At the start of April 2026, Statutory Sick Pay (SSP) entered a new phase. With day one entitlement, the removal of the Lower Earnings Limit and earnings‑related payments, the reforms introduced from 6 April, are intended to align statutory provision more closely with how people actually work today.

While most observers see only the finished vessel, the construction and delivery of a superyacht is a highly complex, multi-year undertaking. It demands significant capital investment, detailed consideration of legal and ownership structuring, and seamless coordination across multiple stakeholders.

The UK government has launched a consultation on establishing a corporate re-domiciliation regime that would allow foreign companies to relocate their legal domicile to the UK while maintaining their corporate identity.

On 6 May 2025, the United Kingdom and India finalised a landmark Free Trade Agreement, marking a significant milestone in bilateral relations.

There was a time when moving to the United States was all the rage. One could not hop on a plane fast enough. Nowadays, the topic of relocation from one country to another is still part of civilized conversation...

The 2024 Autumn Budget, to be delivered on 30 October by Chancellor Rachel Reeves, may introduce tax changes including potential Capital Gains Tax reforms, Inheritance Tax adjustments, pension relief cuts, and alterations to non-dom taxation and furnished holiday lets.