TAX-TREATMENT

Emily Szasz

In what is expected to be a very significant shake up of the distributions tax rules, the Government has decided to implement (in one form or another) the seven proposals it set out in its consultation on modernising the taxation of distribution and...

Elizabeth Bradley

The biggest news for the real estate sector was a change to the tax treatment of overseas sovereign investors from January 2029. That was a surprise. If an idea is dismissed, the real estate industry can be forgiven for thinking that it would not be...

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) reflects on potential changes to tax policymaking, landlord registration, HMRC’s scrutiny of cryptoassets and adviser conduct, and a recent domicile decision.

Liz Fothergill

The reclassification of OIGs may appear to be a narrow technical adjustment solely related to the operation of the temporary repatriation facility, but it has wider practical implications, as Liz Fothergill (Mercer & Hole) explains.

Kim Ashley

Clarification rather than a fundamental expansion of relief?

Carolyn Steppler Elena Dunn Alice Martin

Alice Martin, Elena Dunn and Carolyn Steppler (Charles Russell Speechlys) consider the UK tax and practical risks arising from offshore trust loans, including unexpected IHT exposure, settlor charges and the consequences of irrecoverable debts.

Jack Prytherch

Yousuf Chughtai

Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans to widen the UTT regime and the practical implications for taxpayers.

Nigel Doran

Lika Jatoeva

Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated guidance on deferred remuneration for internationally mobile employees and consider the resulting risks of double taxation and NICs mismatches.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reviews recent developments including rejected calls to extend IHT payment deadlines, proposed expansion of the UTT regime to individuals and trusts, and practical issues arising from pensions, SDLT and trust changes.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal’s purposive approach to the notional company fiction in Muller, HMRC’s consultation on extending the Uncertain Tax Treatment regime, and the proposed UK corporate re-domiciliation regime.

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