United Kingdom: Income Tax

The UK government is proposing new reporting obligations for close companies regarding loans to participators, requiring detailed disclosure of transactions that previously went unreported.

The Upper Tribunal's decision in Putney Power Limited clarifies a critical question in UK tax law: when does a company actually begin trading versus merely preparing to trade? This distinction carries significant consequences for Enterprise Investment Scheme relief and other tax benefits, as the court rejected rigid legal tests in favor of a nuanced, fact-specific analysis of each company's activities and circumstances.

Tackling disguised remuneration (DR) has long been a focus for HMRC, and they have had significant success in the area, protecting billions of pounds of tax revenue.

HMRC has increasingly targeted employee share plans under disguised remuneration rules, challenging arrangements involving third-party participation even when no tax avoidance motive exists.

HMRC's March Agent Update introduces significant changes to employment tax administration, including quarterly reviews of the official rate of interest, new PAYE responsibilities for labour supply chains involving umbrella companies, and modifications to Overseas Workday Relief notifications. These updates will impact how employers manage tax compliance and reporting obligations from April 2026 onwards.

In addition to the public benefit that comes with it, charitable giving can be a strategic element of personal tax planning. Understanding the intricacies of UK tax rules is, however...

The Upper Tribunal has overturned a decision of the First-tier Tax Tribunal (FTT) by concluding that the Mixed Member Rules (MMRs) applied to profit sharing arrangements operated by the Boston Consulting Group.

Among the array of changes introduced in the Autumn Budget was a development in the relief available when selling a business to an Employee Ownership Trust (EOT).

In a significant ruling for professional services firms and other partnerships, the Upper Tribunal has sided with HMRC in Holden v HMRC / HMRC v The Boston Consulting Group UK LLP...