Market Intelligence

The OECD has updated its guidance on when remote working arrangements create a permanent establishment for tax purposes, introducing a new 50% threshold test and a 'commercial reason' analysis. These changes fundamentally alter how businesses must evaluate their cross-border home working policies and could result in unexpected tax obligations in jurisdictions where employees work remotely.

Recent changes to Agricultural Property Relief and Business Property Relief have sparked renewed interest in conditional exemption from inheritance tax for heritage property.

With the Autumn Budget 2026 approaching on October 28th, speculation mounts about potential changes to inheritance tax, capital gains tax, and income tax that could significantly impact charitable legacies. Prime Minister Andy Burnham has previously discussed major IHT reforms, including a possible 10% social care levy on all estates, while CGT rates may increase substantially and the tax-free uplift on death faces potential abolition.

Remote work from second homes or holiday locations can unexpectedly create permanent establishments (PEs) in foreign jurisdictions, triggering complex tax obligations and reporting requirements for businesses and individuals. With the UK's expanded agency PE rules taking effect in January 2026, understanding how routine business activities conducted from secondary locations establish taxable presence has become increasingly critical for corporate structures and family offices.

In November 2025, the previous Chancellor set out plans, among other things, to tackle fraud within the Construction Industry Scheme (“CIS”) and announced a technical consultation “aimed at simplifying and improving the administration of the scheme”.

HMRC's new anti-avoidance information notices grant significantly broader powers to investigate tax avoidance promotion and facilitation, reaching beyond promoters to businesses and intermediaries. The regime introduces substantial financial and criminal sanctions for non-compliance, with penalties up to £1,000 daily and potential imprisonment of two years. Understanding who qualifies as a "connected person" and what information HMRC can demand is now critical for businesses and professional advisers i