“A lot of the work that I do is historic-the maximum sentences change at different points of time. It's really complicated and people get it wrong all the time. That's when having a timeline is really useful.”
1 High PavementAccess all documents on Non-resident landlords scheme (NRLS)
Stop Press: Section 49 and Schedule 7 of the Finance Act 2026 amend the UK’s domestic legislation concerning UK permanent establishments of non-UK companies, taking effect for accounting periods (in respect of corporation tax) or tax years (for income tax) that begin on or after 1 January 2026, respectively. In each case, the measures adjust both the definition of a UK permanent establishment and the rules for attributing profits to a UK permanent establishment, so as to bring them nearer into line with the OECD Model Tax Convention, from that date and thereafter in UK law. Section 46 and Schedule 5 of the Finance Act 2026 provide for the abolition of the DPT regime and its replacement by the ‘unassessed transfer pricing profits’ (UTPP) rules, effective for accounting periods commencing on or after 1 January 2026. HMRC has inserted a new chapter within the HMRC International Manual containing guidance on the UTPP rules at INTM489100. For more information about these changes, see News Analysis: Budget 2025—Tax analysis —...