United Kingdom: Tax Treaties

The UK government plans to make the foreign permanent establishment exemption mandatory from January 2027, fundamentally changing how UK companies are taxed on overseas operations. This policy shift, accelerated for oil and gas companies to September 2026, will prevent businesses from using foreign branch losses to offset UK profits while exempting future foreign profits from UK tax. What implications will this have for international business structures, loss relief strategies, and the broader competitivene

Understanding how Italy taxes foreign pensions is crucial for anyone relocating with retirement savings built under different tax models. This analysis explores the fundamental differences between the UK's EET...

Private UK real estate investment trusts have surged in popularity since 2022 legislative changes, offering private equity real estate managers a tax-efficient vehicle for UK property investments.

Among the many rumours surrounding the upcoming 2025 Budget, proposed changes to the UK's Inheritance Tax regime have dominated the headlines.

From 6 April 2026, the UK's carried interest regime will be reformed so that carried interest is taxed within the income tax and National Insurance Contributions...

Planning the future of your wealth is not just about tax efficiency or legal structures; it is about protecting what matters most and creating a legacy that reflects your values.

Despite previously describing the Ramsay principle as having ‘reached a state of well-settled maturity', in Royal Bank of Canada the Supreme Court...

From 6 April 2025, the UK will move to a new residence-based system for Inheritance Tax (IHT), marking one of the most significant shifts in the taxation of wealth in recent decades.

Gifting assets during your lifetime can be an effective estate planning tool—but it must be done carefully to avoid unexpected inheritance tax (IHT) consequences.