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HMRC v Burlington Loan Management is an important Court of Appeal decision on the interpretation of double tax treaty anti-abuse articles...
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Tackling disguised remuneration (DR) has long been a focus for HMRC, and they have had significant success in the area, protecting...
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We have advised on the launch of a significant number of evergreen funds in recent years, particularly in the private credit space. In...
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Spring has arrived, and with it a fresh burst of activity from HMRC and the Tax Tribunals. HMRC's compliance toolkit continues to...
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We have seen a notable rise in HMRC targeting what may be regarded as relatively innocuous employee share plans under the so-called...
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On 19 March 2026, HMRC published a consultation document titled "Reporting company payments to participators – modernising the reporting...
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This bulletin follows the release of the March Agent Update (Issue 141). In this issue we cover the content most relevant to employment...
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The Government is consulting for the second time on introducing a new regime to allow companies formed outside the UK to “redomicile” by...
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This is an updated version of our previous article that discusses ways to mitigate unnecessary VAT leakage in a private capital setting,...
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On 2 February 2026, the Organisation for Economic Co-operation and Development (OECD) published an updated edition of the Manual on...
This bulletin follows the release of the February Agent Updates (Issue 140). In this issue we cover the content most relevant to...
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The Government intends to introduce a new requirement for tax advisers who interact with HMRC on behalf of clients to register with HMRC...
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The Spring Statement was delivered to the UK Parliament yesterday (3 March 2026) by the Chancellor of the Exchequer, Rachel Reeves. The...
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The Upper Tribunal has overturned a decision of the First-tier Tax Tribunal (FTT) by concluding that the Mixed Member Rules (MMRs)...
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Recent developments in case law mean there has been an increased appetite to pursue public law arguments before the First-tier Tribunal...
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In their current form, agricultural property relief (APR) and business property relief (BPR) provide relief from UK inheritance tax...