The latest updates and insights on tax law
The UK government has published draft legislation for a new Securities Transfer Tax (STT), which is expected to replace the existing stamp duty and stamp duty reserve tax (SDRT) regimes for transfers of securities.
The proposal is intended to modernise and simplify the UK’s stamp taxes on shares regime by…
HMRC has published a consultation on proposals to modernise the UK tax framework for distributions and repayments of capital made by companies to individual and trust shareholders. A key feature of the consultation is a proposal to align the income tax treatment of distributions made by UK and non-UK resident…
The Supreme Court has handed down its judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal and providing important clarification on the application of the salaried members rules to investment management LLPs.
The decision is particularly significant for asset managers, hedge fund managers and other investment…
HMRC has published updated guidance on the revised share reorganisation anti-avoidance rules following the changes introduced by Finance Act 2026. The guidance provides welcome confirmation that standard private equity management rollover arrangements should continue to benefit from share-for-share exchange relief despite concerns raised by the widening of the anti-avoidance provisions.…
Many of our clients and readers will be familiar with the “loan to participator” rules. These rules apply to loans made by close companies, which in general terms are companies which are controlled by five or fewer participators (or by any number of participators who are also shareholders), to their…
June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from April 2026.
The reforms, first announced in October 2024, mark a significant…
The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain members of BlueCrest, an asset manager engaged in the provision of hedge fund management…
On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of a sale of a group company (actually resulting in a sale of…
On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and other US) limited liability companies (LLCs) in particular (in INTM180000 and INTM180050).
This part of the International Manual sets out HMRC’s views on whether certain foreign…
The Upper Tribunal (UT) has upheld the decision of the First‑tier Tribunal (FTT) regarding the application of the UK’s salaried member rules (the Rules) to certain members of BlueCrest Capital Management (UK) LLP (BlueCrest), an asset manager engaged in the provision of hedge fund management services. We previously reported on…
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