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...

Bilfinger Salamis UK Limited v HMRC [2026] UKUT 143 (TCC) BUK delivered services to a North Sea oil platform operator (M) using its own staff. The arrangement was later reworked into an offshore employment model designed to avoid secondary Class 1 National Insurance contributions, namely employers’ NICs. The core group of BUK employees was transferred to a Guernsey subsidiary, Bilfinger Guernsey (BG), and BG then supplied the labour for M’s benefit. BUK nevertheless remained the contracting party with M, and there was no contract in place between M and BG. Separately, BG contracted with BUK to provide labour, scaffold and equipment. The core team of BG employees operated on M’s oil platforms in discharging BUK’s contractual obligations to M (see UT at [6], [7] and [31], the latter referring to FTT at [218]). The issue before both the FTT and the UT was whether...