From Manifesto To Budget: Inheritance Tax: What's Next? (Podcast)

Today HMRC released updated Guidance Notes on implementing FATCA in the UK.

The Chancellor's 2024 Budget introduced moderate changes to Capital Gains Tax (CGT). Rates for basic and higher rate taxpayers increased to 18% and 24%, respectively. Business Asset Disposal Relief and Investors' Relief rates will rise from 10% to 18% by 2026, with anti-forestalling provisions. Rates for residential property disposals remain unchanged.

UK executors administering estates with US shares are facing unprecedented delays of two to three years when seeking IRS estate tax clearance through Form 706-NA applications. These processing bottlenecks, stemming from pandemic-related backlogs and ongoing IRS staffing pressures, are preventing executors from completing estate administration and leaving beneficiaries waiting years to receive their inheritance from US investments.

HMRC is increasing scrutiny of earn-out arrangements, particularly where founders remain involved in the business after completion and deferred consideration depends on future performance of the target company.

From April 2027, HMRC will begin mandatory payrolling of benefits in kind, moving away from the current system of year-end reporting towards real-time deductions through payroll. HMRC has confirmed a two-phased approach: only selected benefits will be subject to mandatory payrolling from April 2027, with full payrolling expected from April 2028 (subject to certain exclusions discussed below).

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.

The Chancellor has today presented his Budget. Some of his announcements and proposals were in line with expectation; others caused more of a stir.

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.

Wealthy clients with complex family structures often seek ways to reduce inheritance tax liabilities to maximize what their beneficiaries receive. From spousal exemptions and charitable giving to strategic lifetime gifts and the seven-year rule, various planning opportunities exist to minimize the 40% tax rate on estates exceeding £325,000. Understanding these exemptions and reliefs, combined with carefully drafted professional Wills, can significantly impact how much of your estate passes to your chos

This is a recent case that acts as a sharp reminder that care and attention is needed to ensure that a non-UK company does not become UK tax resident.

The Chancellor's 2024 Budget introduced moderate changes to Capital Gains Tax (CGT). Rates for basic and higher rate taxpayers increased to 18% and 24%, respectively. Business Asset Disposal Relief and Investors' Relief rates will rise from 10% to 18% by 2026, with anti-forestalling provisions. Rates for residential property disposals remain unchanged.

The European Union has reached a political agreement to significantly extend compliance deadlines for high-risk AI systems under the AI Act, with businesses now having until December 2027 or August 2028 depending on their category. The revised framework introduces separate timelines for different types of high-risk AI applications, narrows certain definitions, and provides regulatory relief for small and medium-sized companies while adding new prohibitions on non-consensual intimate content generation.

In the Spring edition of our biannual UK Legal update, we review recent developments in UK law and practice and scan the horizon for future changes which may have an impact on businesses operating in or trading with the UK.

What employment and immigration law changes are coming in 2026 and 2027? From new unfair dismissal rights and extended tribunal time limits to enhanced harassment protections and trade union access requirements, this comprehensive guide maps out the key legislative reforms affecting UK employers and workers over the next two years.

In this short video, Richard Offord, Katie Hindley and Jonathan Rush provide a 5 minute primer on key pricing issues in commercial contracts.

The UK Government is implementing sweeping reforms to late payment laws that will fundamentally change how businesses manage supplier payments. These changes include substantial fines for persistent late payers, mandatory statutory interest rates, and a prohibition on payment terms exceeding 60 days. With enforcement powers granted to the Small Business Commissioner and a new binding adjudication system...

On 16 December 2025, the UK Financial Conduct Authority (FCA) published its proposals relating to the prudential framework that will apply to firms authorised to carry on cryptoasset-related regulated activities under the new UK cryptoassets regulatory framework

In this four minute video, Rich Offord, Kirsty Emery and Jonathan Rush discuss what suppliers can do to make sure they get paid. Topics covered include tips on how to push back against customer demands for long payment...

At the end of last year, we spent considerable ink (or its virtual equivalent) summarising HM Treasury's now finalised Financial Services and Markets 2000 (Cryptoassets) Regulations 2026 (the SI), and the FCA's barrage of cryptoasset consultation papers that followed in quick succession.

The FCA has issued CP25/18: Tackling non-financial misconduct in financial services which starts the process of formalising non-financial misconduct in its rules.