A UK Topical Tax Update

HMRC has issued several significant guidance updates affecting transfer pricing corrections, construction industry schemes, and short-term business visitors, while recent court decisions provide crucial clarity...

Increasingly, trust administration is no longer simply a matter of maintaining records and considering occasional distributions. Trustees are operating within an environment of enhanced transparency, ongoing reporting requirements, and tax compliance obligations. Failure to identify and manage these responsibilities can lead to delays, unexpected costs and, in some cases, regulatory or tax consequences.

The Supreme Court has clarified how to determine whether LLP members have "significant influence" for tax purposes, establishing that qualifying influence must derive from legally enforceable rights traceable to the LLP agreement rather than informal power or strong performance. This landmark ruling provides a structured framework for assessing member status prospectively...

The UK Government has launched a consultation proposing significant changes to the withholding tax regime on interest payments to overseas lenders. The proposed reforms would shift from HMRC's current gatekeeping role to a self-assessment system where UK borrowers independently determine treaty relief eligibility, fundamentally altering compliance responsibilities and risk allocation in cross-border lending arrangements.

Recent changes to inheritance tax rules have narrowed the charity exemption, potentially affecting charitable gifts in Wills made for "general charitable purposes." Donor-advised funds offer a flexible, tax-efficient alternative that allows individuals to maintain philanthropic intent while adapting to evolving circumstances and involving future generations in charitable giving.

HMRC has proposed new legislation requiring taxpayers to correct known inaccuracies in tax returns, with failures to act being treated as deliberate behaviour attracting higher penalties and extended assessment periods. The draft legislation introduces a statutory duty to correct errors once identified and grants HMRC power to issue Customer Correction Notices, fundamentally shifting tax compliance from a technical exercise to a governance obligation that boards must actively oversee.

Understanding the complexities of inheritance tax on trusts can be challenging for practitioners navigating Scottish private client law. This practical guide demystifies the 10-year anniversary charge, providing essential insights into calculation methods, exemptions, and strategic planning considerations that trustees and advisors need to master.

The Government's draft legislation for a new Securities Transfer Tax (STT), published on 13 July 2026, was a bit of a landmark. Tax advisers will tell you, with a mix of shame and pride, that we still occasionally have to refer to nineteenth century legislation. The Stamp Act 1891 remains the foundation of stamp duty payable on share sales. The whole law in this area is a patchwork of bits of legislation spanning more than a century.

HMRC's enforcement agenda continues to intensify with new criminal offences for reckless statements, mandatory error correction obligations, and expanded compliance burdens on taxpayers and advisers. Recent Supreme Court decisions in BlueCrest and HFFX have narrowed the ground available to taxpayers, while the Court of Appeal's pushback in M R Currell offers some relief against overreach in disguised remuneration rules.

The First-tier Tribunal examined whether HMRC could retrospectively impose late payment penalties and surcharges after reallocating tax payments made by a taxpayer who had entered into unsuccessful tax avoidance schemes. The case centered on the critical question of whether tax liability should be assessed at a specific point in time or whether subsequent payment reallocations could create retroactive late payment scenarios.

When Gibraltar’s new Residency Regulations 2026 came into force last month, they introduced a comprehensive new framework governing the right of individuals to reside in Gibraltar.

ISOLAS LLP operates as a limited liability partnership in Gibraltar, registered under number 00001 with offices at Suite 23, Portland House, Glacis Road.

Following the entry into force of the Treaty on Gibraltar and the European Union, HM Government of Gibraltar has now published the TGEU Implementation (Frontier Workers) Regulations 2026 (LN.2026/319), which came into force on 13 August 2026.

Following HM Government of Gibraltar’s announcement of the new residency criteria and the subsequent publication of the Residency Regulations 2026 (the “Regulations“), Gibraltar has introduced a new framework governing the right to reside in Gibraltar.

ISOLAS LLP, a Gibraltar-based limited liability partnership, provides legal services through its team of partners, employees, and consultants. The firm operates from its registered office at Suite 23, Portland House, Glacis Road, Gibraltar, maintaining professional standards in legal practice.

Gibraltar has become one of the first jurisdictions to establish a standalone regulatory regime for prediction markets, distinct from its traditional gambling licensing framework. The Prediction Market Regulations 2026 (LN.2026/176) came into force on 13 July 2026, made by the Minister with responsibility for gambling under sections 34 and 159 of the Gambling Act 2025.

Gibraltar has become one of the first jurisdictions to establish a standalone regulatory regime for prediction markets, distinct from its traditional gambling licensing framework. The Prediction Market Regulations 2026 (LN.2026/176) came into force on 13 July 2026, made by the Minister with responsibility for gambling under sections 34 and 159 of the Gambling Act 2025. Operators, investors, and payment providers active in or considering entry into this fast-growing sector should take note of the framework’s key features and what it means in practice.

ISOLAS LLP operates as a limited liability partnership in Gibraltar, registered under number 00001 with offices at Suite 23, Portland House, Glacis Road. The firm's structure includes partners, employees, and consultants who maintain equivalent professional standing and qualifications within the organization.

Gibraltar has updated its Category 2 residency status eligibility criteria, introducing new requirements for individuals seeking this immigration classification. The changes affect application procedures and qualification standards for those looking to establish residency in Gibraltar under this specific category.

The Government of Gibraltar has published the new residency criteria designed to ensure that applicants demonstrate a genuine economic connection to the jurisdiction, while safeguarding public resources and promoting sustainable growth.