United Kingdom: Income Tax

HMRC has announced a phased approach to mandatory payrolling of benefits in kind, beginning April 2027 with company cars, fuel, vans, and medical benefits. What steps must employers take now to prepare their payroll...

Explore the evolving UK tax landscape for private clients following major reforms to agricultural property relief, business property relief, and non-dom rules. Partners Tim Williams and Emma Heelis-Adams discuss practical planning strategies, from lifetime gifting and family investment companies to insurance solutions and surplus income exemptions.

Keystone Law explores recent developments in HMRC's treatment of visa costs as taxable benefits, examining how the tax authority's approach has evolved and what this means for employers sponsoring international employees. The analysis considers the implications for both employers and employees navigating immigration-related tax obligations.

Branded residences combine luxury property ownership with hotel-quality amenities and international brand recognition, but they also introduce complex UK tax implications that investors must carefully navigate. From capital gains tax and inheritance tax exposure to the nuances of the Statutory Residence Test, acquiring a UK branded residence can significantly impact an investor's tax status and that of their family members. Understanding these considerations is essential before making what may appear to be

Hosting overseas employees in the UK creates complex tax, payroll and immigration obligations that extend far beyond contractual arrangements. What practical risks emerge when international working becomes routine, and how can employers ensure compliance when form doesn't override substance?

A recent Upper Tribunal decision confirms that directors of close companies can face unexpected personal tax liabilities when their overdrawn loan accounts are deemed 'written off' by liquidators, even without formal release documentation. The case of HMRC v Gary Quillan demonstrates how a liquidator's statement that no further recovery is expected can trigger immediate income tax charges on directors, regardless of whether the debt remains technically payable.

HMRC has launched a consultation proposing fundamental reform to the UK's distribution framework, potentially one of the most consequential tax law consultations in decades. The proposals aim to modernize rules that have remained largely unchanged since 1965, addressing how payments from companies to shareholders are taxed and closing perceived loopholes that allow value extraction at capital gains rates rather than dividend rates. The consultation covers seven key areas including reductions of capital, dem

HMRC has launched a consultation on simplifying treaty relief from withholding tax on interest paid overseas, acknowledging that the current system is complex and outdated. The consultation proposes allowing taxpayers to self-assess whether treaty relief applies, moving away from the cumbersome advance treaty application process that can take over a year to complete.

The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management (UK) LLP, establishing a restrictive three-part test for determining what constitutes "significant influence" under the salaried member rules. This ruling clarifies that influence must be formally derived from the LLP Agreement, extend to strategic affairs of the entire LLP, and involve substantive participation in important decisions affecting the partnership's conduct.