DIVIDEND

FA 2025 Sch 6 introduces some fundamental and far-reaching changes to the Employee Ownership Trusts (EOT) tax rules. HMRC view the changes as pure anti-avoidance to provide them with the tools to counter the undoubted abuse of the EOT tax...

Emma Rawson

The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Court of Appeal confirms that dividend replacement scheme failed.

Artem Vasyutin

Sophie Hatton

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

Dominic Stuttaford

Aiden Hepworth

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in Marlborough DP Ltd v HMRC that suggests the shortcomings in HMRC’s general approach following Rangers.

Cristiana Bulbuc

Lee Ellis

The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.

Paula Tallon

Siobhan Sellick

Now that Australia and UK have signed their trade agreement, Paula Tallon and Siobhan Sellick (Prosperity Advisers Group) explain what Australian taxes UK companies will encounter when establishing a business presence there.

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