United Kingdom: Tax Treaties

Understanding UK tax residence is crucial for international workers, but many overlook a critical mismatch: social security obligations operate under separate rules from tax residence. This disconnect can leave individuals paying national insurance in unexpected jurisdictions, affecting payroll compliance, benefits eligibility, and future state pension entitlements.

As the UK anticipates its first Budget under Andy Burnham's premiership on 28 October 2026, questions arise about whether 'Manchesterism' will introduce an exit tax regime. This analysis examines how different jurisdictions—from Canada's deemed disposal system to France's targeted charges on substantial holdings—tax individuals leaving their borders, and explores what form a UK exit tax might take if implemented.

Irish executors managing estates with overseas assets face complex legal requirements across multiple jurisdictions. Our International Private Client team provides specialized support for cross-border probate matters, including UK property, Channel Islands assets, North American investments, and US estate tax clearance, helping personal representatives navigate unfamiliar procedures with confidence.

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treaty relief from withholding tax on interest paid overseas, acknowledging that the current system is complex and outdated.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 European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.

The UK Government has launched a consultation proposing to treat US limited liability companies (LLCs) as transparent for UK tax purposes when held by individuals, addressing long-standing double taxation issues that have deterred internationally mobile individuals from living and investing in the UK.

There have been major changes this year to the UK's tax regime for individuals with an international connection. Our separate article considers the abolition of the "non-dom" regime...

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...