Tax Law

In this issue: International Reorganisations, restructuring and insolvency VAT Taxes management and litigation Anti-avoidance Energy and environment Key developments Employment taxes Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information International UK government announces mandatory application of the foreign permanent establishment exemption On 21 May 2026, the government released a policy paper outlining reforms to the taxation of UK-resident companies operating partly through foreign permanent establishments (PEs), making the foreign PE exemption compulsory for most businesses for accounting periods starting on or after 1 January 2027. For UK-resident companies with foreign PEs involved in activities relating to the exploration or exploitation of oil and gas, the measure will take effect from 1 September 2026. This is achieved by deeming those companies’ accounting periods to end on 31...

In this issue: Companies and corporation tax Employment taxes Taxes management and litigation International Energy Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax Supreme Court decides that expenditure on environmental surveys and studies for windfarms was not incurred ‘on’ the provision of plant for capital allowances purposes (HMRC v Orsted West of Dutton Sands (UK) Limited) In Orsted West of Dutton Sands (UK) Limited [2026] UKSC 12, the Supreme Court, unanimously, upheld HMRC’s appeal, finding that spending on environmental surveys and studies carried out for the development of offshore windfarms does not attract capital allowances. The Court held the expenditure was not incurred ‘on’ the provision of plant, as that phrase in section 11(4) of the Capital Allowances Act 2001 (CAA 2001) demands a...

CATS North Sea Ltd (CNSL) should not bear the uplift because it was not a deemed participant in the field where it continued a related company’s transport operations, and statutes bar transferring the incumbent’s oil business for tax purposes, the UT ruled. It also decided that the company’s participation status dictated the legal characterisation of the activities, even if, in practice, they were largely identical. The dispute concerned the interplay between several corporation tax provisions for oil businesses and a balancing charge, being an amount that HM Revenue and Customs (HMRC) adds to taxable profits when an asset is realised for more than its allocated value. HMRC applied its preferred balancing charge after a reorganisation under which CNSL, formerly a wholly owned subsidiary of Amoco Exploration Co LLC part of BP Plc, assumed Amoco’s interest in the Central Area...

Updated in April 2026 Introduction Türkiye has stood at the centre of international politics owing to its role in the Syrian conflict along its southern border and its approach to refugees. The coronavirus (COVID-19) pandemic, as elsewhere, heavily influenced domestic policy and the economy. Disputes in the Mediterranean over the search for natural gas also stayed high on the agenda. Since the final quarter of 2018, the economy has endured recessionary conditions linked to the attempted coup d’état of 15 July 2016, marked by elevated inflation, costlier borrowing, and volatile exchange rates. Although economic projections were shaken in 2020 by the pandemic, Türkiye sought to blunt the fallout through the Economic Stability Shield programme unveiled on 18 March 2020, setting out nationwide supportive and preventative steps to lessen the economic damage, covering taxation, credit and labour-related matters. By late 2021, the Turkish lira had...

This Tax tracker sets out the current position of, and developments arising from, consultations—both formal and informal—run by the UK government (and other bodies) that affect taxation and, where relevant, the legislative consequences of those consultations. It also details the present status of tax-related Bills before the UK Parliament, the Scottish Parliament, the Welsh Parliament and the Northern Ireland Assembly, excluding Finance Bills, which are tracked separately. The tracker is divided into five parts: Tax-related Bills Tax-related Acts Open consultations—ie, consultations open for responses Closed consultations—ie, consultations closed to new responses Concluded consultations—ie, consultations closed to new responses with a published summary or outcome For information on OECD consultations connected to the OECD’s Base Erosion and Profit Shifting Action Plan, see: Tax—Base Erosion and Profit Shifting tracker. Tax-related Bills The table below lists tax-related Bills, other than Finance Bills. On 4...

This Practice Note discusses: the precise nature of a partnership, and why this status can be especially significant and relevant in a VAT setting how a general partnership, limited partnership, Scottish partnership, and a limited liability partnership (LLP) ought to register for VAT the situations in which partnerships may qualify to join a VAT group the extent to which partners are responsible, where applicable, for VAT due from the partnership the VAT effects of dealings between partners and the partnership, in particular: moving assets into or out of the partnership, and transferring an existing partnership interest itself This Practice Note cites relevant case law from the EU Court of Justice. For guidance on whether and to what extent...

[To appear on the client’s headed paper or bearing the client’s logo] Status determination statement This status determination statement is issued in line with the requirements of section 61NA of the Income Tax (Earnings and Pensions) Act 2003, and concerns the off-payroll rules. The off-payroll rules may apply where a worker (often described as a contractor) supplies their services through their own limited company (commonly called a personal service company, or PSC), or via another form of intermediary, to a client that is a public authority, or a medium or large private sector organisation with a UK connection. The rules take effect if a worker delivers services to a client through an intermediary but, if engaged directly, would be treated as an employee for tax purposes; they ensure such individuals pay broadly the same tax and National Insurance contributions (NICs) as...

[To appear on the client’s official letterhead or with the client’s logo] Off-payroll working (IR35): confirmation of the size of our organisation On [ insert date request received ] you contacted us seeking confirmation of our organisation’s size for the application of the off-payroll rules for the tax year [ insert tax year ] as requested by you......

This Agreement is entered into on [ insert day and month ] 20[ insert year ] Parties [ Insert name of selling corporate entity ], a company incorporated in [ England and Wales OR [ insert country of incorporation ] OR with registered number [ insert company number ] ], whose registered office is at [ insert address ] (the Seller); [ Insert name of purchasing corporate entity ], incorporated in England and Wales OR [ insert country of incorporation ] OR with registered number [ insert company number ], with its registered office at [ insert address ] (the Buyer); [ Insert name of guarantor entity ], incorporated in England and Wales OR [ insert country of incorporation ] with registered number [ insert company number ], whose registered office is at [ insert address ] (the Guarantor) [ (each of the Seller, the Buyer and the...

The working assumption is that the land concerned is residential freehold property in England or Wales, and that no tax avoidance is in point. SDLT treatment of the first 40% transaction As set out in Practice Note: Land transactions, chargeable interests and chargeable transactions, a land transaction with no chargeable consideration (for which see Practice Note: SDLT chargeable consideration) is outside the scope of SDLT, an exempt transaction......

We proceed on the basis that the company is UK-resident and that the dividend is not being made between companies within the same group for tax purposes. When analysing the tax consequences for the distributing company, the initial enquiry is to determine whether the transaction sits within the statutory rules on loan relationships or, alternatively, within the corporation tax provisions dealing with chargeable gains. In the ordinary course, a loan note held by a company is regarded, for tax purposes, as a loan relationship, and is treated in line with that classification......

Assignment of a lease The disposal of a lease is ordinarily handled in the same manner as conveying a freehold, and any sum or premium given for the assignment (excluding a reverse premium) falls within the scope of stamp duty land tax (SDLT). However, the incoming tenant’s acceptance of obligations under the lease—such as paying rent or complying with the tenant’s covenants—does not constitute chargeable consideration for SDLT purposes and is disregarded when assessing the tax charge......