Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated guidance on deferred remuneration for internationally mobile employees and consider the resulting risks of double taxation and NICs mismatches.
Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.
Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.
Penny Cogher (Irwin Mitchell) examines the extension of IHT to pension funds from April 2027, including the new concept of ‘notional pension property’, expanded liability for tax, and the significant practical and administrative challenges for PRs, schemes and beneficiaries.
Emma Rawson (ATT) reviews the MTD for Income Tax regulations, highlighting late legislative changes, complex entry and exit rules, quarterly reporting mechanics, and the wide-ranging exemption regime.