United Kingdom: Tax Authorities

The global business environment in 2026 is characterised by a level of uncertainty that many companies have not experienced in decades. Geopolitical tensions and instability in strategic regions have led to disruptions to international shipping routes.

HMRC has published final guidance on the reformed UK investment manager exemption (IME), introducing significant changes that broaden its scope and remove the problematic 20% test. The updated guidance clarifies how the exemption applies to transparent funds and carried interest arrangements, providing crucial certainty for non-resident investors and UK asset managers navigating the country's tax regime.

Starting April 6, 2027, the UK will fundamentally transform how pension scheme death benefits are treated for inheritance tax purposes, bringing unused pension funds and death benefit lump sums largely within the scope of IHT. This major policy shift introduces the concept of "Notional Pension Property" and will significantly impact scheme administration, member communications, and estate planning decisions.

The Private Intermittent Securities and Capital Exchange System (PISCES) is a new type of stock market that will allow for secondary trading of private company shares.

A First-tier Tribunal has ruled that football referees engaged by Professional Game Match Officials Ltd were self-employed contractors rather than employees, rejecting HMRC's attempt to recover £584,000 in unpaid employment taxes.

The Court of Appeal has ruled that a genuine, repayable loan made through an employee benefit trust prior to the disguised remuneration rules does not constitute taxable employment income.

For employees and businesses, global mobility and US tax compliance can become unexpectedly complex. One item that is not complex but often missed is the Foreign Bank Account Report (FBAR) filing.

The UK’s IR35 regime, also known as the off-payroll working rules, continues to play an important role in how businesses engage contractors operating through personal service companies.

The UK's tax authority, HM Revenue & Customs (HMRC), has confirmed that the requirement for UK and non-UK firms of tax advisers to register...