Corporate tax insights
The OECD’s proposed revisions to Chapter VII of the Transfer Pricing Guidelines do not fundamentally change the framework for evaluating and pricing intra-group services. However, they do sharpen the focus on how taxpayers define the transaction, evidence the benefit received and support the pricing approach taken.
HMRC's proposed International Controlled Transactions Schedule (ICTS) is expected to significantly increase transfer pricing compliance demands for UK businesses. ICTS transfer pricing in 2027 could be the first year in scope, so early preparation is critical to avoid last-minute data, systems and reporting challenges.
Mandatory payrolling of benefits in kind (BiKs) is no longer a future consideration. HMRC has confirmed phased implementation will begin in April 2027 and while this gives employers more time to prepare, this is not simply a payroll system update, it’s one of the most significant changes to payroll, employment tax and benefits reporting in recent years.
A significant VAT change is on the horizon for the energy sector. From 1 October 2026, the UK Government plans to reduce VAT on domestic electricity supplies from 5% to 0%.
HMRC Guidelines for Compliance (GfCs) outline the expectations for VAT accounting, risk management and documentation.
Helping your teams stay confident, compliant and up to date with VAT changes.
From 1 July 2026, the EU is set to introduce a fixed €3 customs duty on low-value imports entering the EU from third countries. The measure will apply to small consignments valued at less than €150, largely driven by the rapid growth of cross-border e-commerce.
On 17 June 2026, HM Revenue & Customs (HMRC) released updated guidance expanding and renaming the Profit Diversion Compliance Facility (PDCF) as the Transfer Pricing & Profit Diversion Compliance Facility (TP&PDCF). This change represents a substantive shift in HMRC’s approach to international tax risk management.
On 16 June 2026, HMRC published a technical consultation on the proposed International Controlled Transactions Schedule (ICTS). The ICTS will require in-scope multinational groups to submit an annual, standardised dataset of cross-border related-party transactions, expected to be filed alongside the corporation tax return.
Many UK businesses expanding internationally can get caught out by the complexity of overseas VAT compliance, which is very different to the UK regime.
In a bid to support families and businesses this summer, HMRC has announced a temporary reduction in VAT to 5% on children’s meals, entertainment tickets and family attractions.
Over two decades on from their last Premier League title, north London is celebrating as Arsenal are finally crowned champions following Manchester City’s draw with Bournemouth.
On 1 May 2026, the First-Tier Tribunal (FTT) released its long-awaited remitted decision in the case of Professional Game Match Officials Ltd v HMRC.
HMRC’s Code of Practice 9 (COP9) is one of the most serious civil tax investigation procedures used by the UK tax authority. COP9 cases require careful handling, strategic disclosure and specialist representation due to the significant financial, legal and reputational risks.
If you receive a letter from HMRC suggesting your historic tax affairs may be incorrect, this can be very unnerving. Whether your letter relates to a compliance check or another tax matter, knowing what to do next and having the right specialist support can save you time, stress, and in some cases, money.
Alternative Dispute Resolution is a formal mediation process that can be used to unlock long-running tax disputes with HMRC. Alternative Dispute Resolution can be an effective way of reaching a mutually acceptable settlement, whilst avoiding potentially costly and time-consuming litigation.
A cross-tax or full enquiry is an all-encompassing review of a business' historical corporation tax, VAT and employer duties (PAYE/NIC) position, seeking to understand if respective tax returns, including any claims, have been filed correctly. This contrasts with an aspect enquiry, where HMRC are looking to check a specific entry or matter associated within a tax return.
Our calendar for the 2026/27 tax year is designed to help employers stay on top of important deadlines and ensure compliance with HMRC requirements.
From 7 June 2026, all EU and UK employers with EU-based employees and/or operations in the EU must comply with the EU Pay Transparency Directive.
There has been a further development in the United States regarding the refund of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), following the US Supreme Court’s earlier ruling that those tariffs were unlawful.
The VAT in the Digital Age (VIDA) package has now been approved and will soon start to be implemented in phases; this is one of the most significant reforms to the EU VAT system in decades. Although the UK is no longer part of the EU, these changes will have substantial implications for UK businesses trading with, supplying services to or operating digital platforms within the EU.
There has been a notable development in the United States regarding the emergency import tariffs introduced in 2025 by President Trump. The U.S. Supreme Court has ruled that the tariff increases were not lawfully implemented, a decision that could open the door for importers to pursue refunds of duties paid under those measures.
From 6 April 2026, specific sole traders and landlords are now required to use Making Tax Digital (MTD) to report their income and expenses to HMRC. Whether an individual is affected will depend on their total annual income from self-employment and property.
The OECD has announced important changes to Pillar 2 with permanent safe harbours, revised tax credit rules and new calculation options.
On 26th November, Rachel Reeves delivered her Autumn Budget for 2025. We analyse the impact this will have on firms operating in the financial services sector.
As part of its white paper "Restoring control over the immigration system", the UK Government has proposed a package of immigration reforms intended to reduce net migration, refocus visas on higher-skilled migrants and tighten sponsor compliance.
On 18 September 2025 HMRC provided clarification on the NIC treatment of cash earnings paid to IMEs. If earnings are earned in a period an employee is liable to NIC, this income will be liable to NIC regardless of the date of payment.
As the UK continues its trajectory toward wage growth and parity across age groups, the Low Pay Commission (LPC) has provided recommendations on the proposed National Living Wage (NLW) and National Minimum Wage (NMW) rates for 2026/27.
The Home Office has published a Statement of Changes to immigration rules (HC 997), introducing sweeping reforms effective from 22 July.
On 29 May 2025, the Department of Business & Trade (DBT) published their 21st National Living/Minimum Wage “Name & Shame” list.
If you own a solvent company that has reached the end of its useful life, a Members' Voluntary Liquidation (MVL) offers a structured, tax-efficient, and low-risk method to close it down. Whether you're retiring, restructuring, or simply finalising a completed project, a Members' Voluntary Liquidation can help you exit cleanly while maximising returns to shareholders through a formal process.
The UK financial landscape is on the brink of a transformative shift with the introduction of PISCES—the Private Intermittent Securities and Capital Exchange System. Developed by the UK Government in collaboration with the Financial Conduct Authority (FCA), PISCES is designed to modernise how shares in private companies are traded, offering a structured, regulated alternative to traditional secondary...
The Enterprise Management Incentive (EMI) is a powerful tool designed to incentivise employees in a tax-efficient manner.
Non-Tax-Advantaged (NTA) share option plans offer a highly flexible alternative to tax-advantaged schemes while maintaining cash flow benefits. These plans allow companies to grant share options to employees and non-employees, particularly when tax-advantaged plans are unavailable or award limits have been reached under existing schemes.
A Company Share Option Plan (CSOP) offers businesses a tax-efficient and flexible way to reward employees and directors. These schemes can be instrumental in enhancing employee engagement, fostering corporate growth, and driving business success.
July has been a busy month in the world of VAT. Stay up to date as we bring you a bumper 6 VAT updates this month.
Staying up-to-date and compliant is crucial to avoid penalties and ensure smooth payroll management as companies start the new tax year. Here’s a comprehensive overview of the upcoming changes.
Our calendar for the 2025/26 tax year is designed to help employers stay on top of important deadlines and ensure compliance with HMRC requirements.
The Finance Act 2025 finally abolishes the concept of “domicile” in relation to tax. As a result, non-domiciled individuals will no longer be able to claim the remittance basis of tax on their Foreign Income and Gains (FIG).
The UK Home Office has announced substantial increases to visa, sponsorship and related immigration fees, effective 9 April 2025.
The House of Lords has addressed the upcoming National Minimum Wage (NMW) increase and its implications for businesses, workers, and enforcement mechanisms.
On 5 and 6 March, HMRC ran transfer pricing webinars on the Guidelines for Compliance (“GfC7”), titled "Help with Common Risks in Transfer Pricing Approaches.”
In this interview, Matt Dalton, Head of the consumer sector, is joined by Jane Gilmore, Employment Tax Associate Director, to discuss the upcoming changes to the National Living Wage (NLW) and National Minimum Wage (NMW) and how these will affect retailers and the consumer sector at large.
From 6 April 2025, the Remittance Basis of taxation available to non-domiciled individuals will be replaced by the Foreign Income and Gains (FIG) regime. Given the high number of non-domiciled individuals employed in the Financial services sector, firms should be aware of the changes and seek advice if required.
If you (or your clients) are looking to wind down a solvent trading company due to retirement or other reasons, then it’s important to plan now to obtain reduced tax rates.
HMRC has confirmed that the changes to company size thresholds will also apply to off-payroll working rules (colloquially referred to as IR35) from 6 April 2026.
As part of its transparency data series HMRC has published its latest annual statistics on Transfer Pricing (TP) and Diverted Profits Tax (DPT) covering 2023 to 2024. The results provide an insight into HMRC’s commitment to ensuring the right amount of profit (the arm’s length amount) is allocated to the UK.
The Retail Jobs Alliance warns that over 300,000 retail jobs could be at risk by 2028 due to rising costs, including increases in National Insurance Contributions and National Minimum Wage rates.
Employers have several obligations to fulfil each year, including filing annual Employment Related Securities (ERS) returns. Although a reporting requirement, this can often be overlooked as HMRC does not notify or remind employers, often leading to missed deadlines and potential penalties.
We estimate that over £1 billion will be paid annually, and this figure is expected to increase by more than £23 million as a result of employer NI contribution rates set to take effect from 6 April 2025.
The UK government has recently announced plans to increase fees for certain products and services aimed at reducing the financial burden on taxpayers by reducing reliance on government funding for the migration on border systems.
When assessing compliance with the National Minimum Wage (NMW) and National Living Wage (NLW) for salaried workers, it is important to note that simply dividing an annual salary by 12 months (if paid in equal monthly instalments) and comparing this to the basic contractual hours is not sufficient.
Within the detail of Labour’s first Autumn Budget were several tax increases on company vehicles. These changes will most likely impact the level of tax paid by employees and overall net reward, as well as further increase costs for businesses too.
As we approach the end of 2024, we take a look back at the plethora of the largest VAT cases across the board.
As we step into 2025, the effects of the Autumn Budget 2024 will start to take shape, leaving businesses in the pharma and life sciences sector grappling with its implications. Was it a step forward or a setback? Only time will tell as the changes take effect.
Chancellor Rachel Reeves' Autumn Budget contained a sizeable increase in employers' national insurance contributions (NICs). This article examines how this will impact the Financial Services sector's tax cost and compliance requirements.
In the government's first Budget, Chancellor Rachel Reeves announced several measures that will impact the UK's Financial Services sector, and we examine here the impact of the policies announced.
Tips are a significant benefit within the hospitality sector. With new tipping rules and requirements to ensure fair management and distribution among staff being introduced, the question is: are hospitality businesses ready to implement the changes?
In a significant decision for the pharmaceutical industry, the UK First Tier Tribunal (FTT) has ruled in favour of Boehringer Ingelheim, allowing the company to reclaim £21 million of overpaid VAT. This ruling is a major development for suppliers of branded medicines to the NHS, offering clarity on how VAT should be treated in relation to rebate payments under the UK’s voluntary price control schemes.
The Budget presented by Rachel Reeves, the first female Chancellor in UK history, can only be described as a complex budget in challenging times, but how will the announcements impact the UK’s Manufacturing and Automotive businesses?
In response to the Chancellor's announcement regarding the abolition of the non-domicile regime and its replacement with the Foreign Income and Gains (FIG) regime, companies must reassess their approach to managing Internationally Mobile Employees (IMEs) moving to the UK.
UK organisations are finding it significantly challenging to manage the financial costs of rewarding their workforce. So, how can employers balance increasing cost pressures while identifying cost-effective strategies to enhance employee reward packages?
National Living Wage (NLW) rates are to increase from £11.44 per hour to £12.21, an increase of 6.7%, which is yet another large increase to the minimum wage.
The National Minimum Wage (NMW) has seen significant increases since its introduction in 1999 including the introduction of the National Living Wage in 2016 to workers aged 25 and over and lowered to those aged 23 and over in April 2021.
The Construction Industry Scheme (‘CIS’) doesn’t just apply to construction businesses, it can also apply to non-construction businesses who spend on construction operations.
The UK has introduced the Electronic Travel Authorisation (ETA), a new requirement for all non-visa nationals travelling to the UK as visitors. This is part of the UKVI’s move to a more digital approach to visas and travel authorisation and will allow the UK to manage its borders more effectively and securely.
When employees of overseas branches of UK insurance companies makes business trips to work in the UK, or otherwise host STBVs, in the first instance PAYE income tax should be applied to 100% of their earnings in real time.
For accounting periods beginning on or after 1 April 2024, a new merged R&D tax relief scheme (MRDEC) will replace the existing SME and RDEC regimes, a change that was announced during the Autumn Statement 2023.
Below, we explore the benefits for employees and employers of salary sacrifice and the areas employers need to consider ahead of implementing a salary sacrifice arrangement.
A new era for National Minimum Wage and National Living Wage.
As part of its 2024 election manifesto, Labour has committed to the removal of several tax exemptions from private schools resulting in additional VAT costs and compliance obligations.
The pandemic demonstrated beyond any reasonable doubt that the life sciences, pharma and healthcare sectors play a critical role in society. Developing, testing and manufacturing vaccines was key to beating Covid-19.
Clearly, Jeremy Hunt was wanting to champion the importance of the life sciences sector to the UK’s economy. It was probably singled out more times in his speech than any other sector and a few of the reforms announced today go some way to address criticism around the competitiveness of the UK corporation tax system for this sector, particularly in advance of the rise of the headline rate to 25% from...
Why companies within the Pharmaceutical and Life Sciences sector need to be aware of the tax implications before entering into collaborative arrangements.
The tax implications arising from the paradigm shift to remote working and virtual collaboration this past year in the pharmaceutical and life science sector are complex on different levels.
Bringing new drugs to market is risky, lengthy, complex, and costly, so pharmaceutical companies are rationalising their major R&D centres worldwide to collaborate with partners. This is where international R&D tax incentives play their part.
Research and development is at the heart of the pharmaceutical industry and, more generally, the wider life sciences sector. The significance of R&D to the life sciences sector is clearly evidenced by the cumulative R&D expenditure.
During the pandemic, retailers rushed to sell their products online, a move which saved many from going bust. Now, just a short time on from a worldwide health crisis, some retailers are heading the other way, realising they need a bricks-and-mortar presence if they are to remain in business.
There was much in the Chancellor’s Budget to encourage individuals back into the workplace, be that retirees wanting to return to work, those with disabilities or childcare responsibilities, and potential apprentices. These measures should ultimately benefit the Consumer sector, both as a large source of employment and as a means to boost disposable income available for consumer spending by supporting...
Whilst many of the measures announced during the Spring Budget will be welcomed by businesses across all sectors, those within the automotive sector may feel disappointed it stops short of including any real investment to support the strengthening of the UKs Electric Vehicle (“EV”) sector and charging infrastructure.
Based on survey data, the 'Beyond efficiency report' looks to understand Councils' approaches to financial sustainability and risk. The annual 'local government internal audit planning report' analyses common causes for issues being identified, and makes suggestions for areas internal auditors may want to include in their annual plan to gain assurance that the root causes are being addressed.
In 2022, an estimated 18,000 adult social care organisations in England, were involved in providing or organising adult social care. Inevitably, there are issues to consider when looking at recruitment, reward, and retention for the estimated 1.635 million workforce [1].
29/11/2022. Organisations who neglect to follow National Minimum Wage (NMW) compliance can be left liable to costly ramifications, both financially and reputationally.
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