Moving To The UK... A Checklist

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

As the UK anticipates its first Budget under Andy Burnham's premiership on 28 October 2026, questions arise about whether 'Manchesterism' will introduce an exit tax regime. This analysis examines how different jurisdictions—from Canada's deemed disposal system to France's targeted charges on substantial holdings—tax individuals leaving their borders, and explores what form a UK exit tax might take if implemented.

Burnham has consistently advocated for replacing council tax and stamp duty with a land value tax - an annual levy charged on the value of the land itself, rather than the buildings on it.

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.

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.

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.

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.

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).

UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.

This "regrettably growing catalogue of family disputes," as the court noted, provides a multi-million dollar case study in how ambiguity and the "borrowing" of names can catastrophically backfire...

Between November and December 2014, Beijing, Shanghai and Guangzhou courts specialising in intellectual property law initiated their activities.

Florida has enacted significant statutory changes affecting trust administration, probate procedures, and business entity formation. These reforms introduce streamlined nonjudicial processes for trustee discharge, expand access to simplified probate administration, and establish a new framework for protected series LLCs that offers enhanced asset protection and operational flexibility for estate planners and business owners.

"The first family that I helped to move to Singapore already had a family office in Switzerland but decided that Asia was where the next cycle of investment was going to come from," says Daniel Yong...

As the UK anticipates its first Budget under Andy Burnham's premiership on 28 October 2026, questions arise about whether 'Manchesterism' will introduce an exit tax regime. This analysis examines how different jurisdictions—from Canada's deemed disposal system to France's targeted charges on substantial holdings—tax individuals leaving their borders, and explores what form a UK exit tax might take if implemented.

The UK government has published its response to consultation on flexible working reforms, introducing a new reasonableness test for employers refusing requests from 2027. The reforms will require employers to meet with employees before rejecting applications and explain why refusal is reasonable, while consultation data reveals significant gaps between employer and employee perceptions of the current system.

At a time when trusts are coming increasingly under attack, it is quite common for the validity of a trust to be questioned on the basis that the instrument creating it is a sham document or fails to fulfil the requirements for the creation of a valid trust.

Effective for the 2016 reporting year, the filing deadline for the Foreign Bank Account Report (FBAR) will be 15 April rather than 30 June. US citizens and residents abroad will receive an automatic two month filing extension to 15 June.

The Northern Ireland Assembly is advancing the Charities (Amendment) Bill, which introduces significant regulatory changes for charities operating in the jurisdiction. The legislation grants the Charity Commission for Northern Ireland expanded enforcement powers, overhauls accounting and reporting frameworks based on charity size, and clarifies the status of cross-border charitable organizations.

All land in Hong Kong (with the exception of St. John's Cathedral, the only freehold property in Hong Kong) is leasehold property.