United Kingdom: Corporate Tax

Guernsey and Jersey companies have been a mainstay on the LSE for many years – and the same have also been used for listings on NYSE and NASDAQ, as well as other stock exchanges in Europe, North America and Africa.

The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.

There are a number of potential tax advantages when using FICs, including Inheritance Tax, but these will vary depending on the size

HMRC has proposed sweeping new reporting requirements for close companies that would mandate detailed disclosure of all transactions with participators, extending far beyond the current framework which only captures loans triggering tax charges. The consultation raises critical questions about the burden on privately-owned groups and private equity structures, where intra-group transactions could generate extensive reporting obligations despite no underlying tax liability.

The United Kingdom’s Upper Tribunal (UT) decision in CATS North Sea Limited v. HMRC provides an exploration of statutory deeming rules, in particular the extent to which a deemed trade fiction applies when interpreting other legislative provisions.

HMRC has updated its internal guidance to clarify that pure financing arrangements fall outside the Construction Industry Scheme (CIS), but significant uncertainty remains for lenders and investors who maintain control over development projects.

As we approach the end of the 2025/26 tax year, now is the ideal time to review your personal tax position and assess whether you are making full use of the reliefs and allowances available.

AI adoption coupled with developments in robots and other technology means many are predicting a medium-term future of reduced job opportunities, whatever the long-term outcome.

The latest set of annual statistics from HM Revenue and Customs (HMRC) show that the number of companies elected into Patent Box marginally increased in the tax year 2022 to 2023...