Weil Tax BLOG - Feed https://tax.weil.com/category/whats-new-on-the-blog/ Views and developments from the Tax Department at Weil Thu, 30 Jul 2026 15:24:27 +0000 hourly 1 The Odyssey continues: HMRC consults on the taxation of UK members of US LLCs and other foreign reverse hybrids https://tax.weil.com/insights/the-odyssey-continues-hmrc-consults-on-the-taxation-of-uk-members-of-us-llcs-and-other-foreign-reverse-hybrids/ Thu, 30 Jul 2026 09:26:39 +0000 Oliver Walker Alex Ereira Molly Syme https://tax.weil.com/?p=2679 You would be forgiven for assuming that a “reverse hybrid” is some chimeric monstrosity from ancient mythology, lurking at the edge of the map to gobble up passing heroes. In the world of international taxation, the reality is less fanciful – the term refers instead to foreign entities which are transparent for tax purposes in

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]]> You would be forgiven for assuming that a “reverse hybrid” is some chimeric monstrosity from ancient mythology, lurking at the edge of the map to gobble up passing heroes. In the world of international taxation, the reality is less fanciful – the term refers instead to foreign entities which are transparent for tax purposes in

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]]> Income or Capital? HMRC Consults on Reform of the UK Distributions Code https://tax.weil.com/insights/income-or-capital-hmrc-consults-on-reform-of-the-uk-distributions-code/ Tue, 21 Jul 2026 15:10:59 +0000 Oliver Walker Enda Kerin https://tax.weil.com/?p=2674 On 23 June 2026, HMRC published a consultation on modernising the taxation of distributions and repayments of capital to individuals and trusts. The consultation proposes a significant overhaul of the current UK tax distributions code, with the overall aim of widening the UK income tax net for returns of value from companies and narrowing the

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]]> On 23 June 2026, HMRC published a consultation on modernising the taxation of distributions and repayments of capital to individuals and trusts. The consultation proposes a significant overhaul of the current UK tax distributions code, with the overall aim of widening the UK income tax net for returns of value from companies and narrowing the

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]]> Welcome to the Hotel United Kingdom: the UK’s proposed re-domiciliation regime https://tax.weil.com/insights/welcome-to-the-hotel-united-kingdom-the-uks-proposed-re-domiciliation-regime/ Thu, 16 Jul 2026 15:13:11 +0000 Oliver Walker Ellie Marques https://tax.weil.com/?p=2672 The Government’s proposed UK corporate re-domiciliation regime would allow foreign companies to move their place of incorporation to the UK while preserving legal identity, but only on an inward basis, leaving no route for UK companies to re-domicile overseas. Tax policy remains largely undeveloped, with the consultation focusing on issues including market value rebasing, loss

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]]> The Government’s proposed UK corporate re-domiciliation regime would allow foreign companies to move their place of incorporation to the UK while preserving legal identity, but only on an inward basis, leaving no route for UK companies to re-domicile overseas. Tax policy remains largely undeveloped, with the consultation focusing on issues including market value rebasing, loss

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]]> A decision of significant influence: the Supreme Court decides the BlueCrest case and materially narrows the defences to the salaried member rules on LLP member taxation https://tax.weil.com/insights/a-decision-of-significant-influence-the-supreme-court-decides-the-bluecrest-case-and-materially-narrows-the-defences-to-the-salaried-member-rules-on-llp-member-taxation/ Wed, 08 Jul 2026 12:05:04 +0000 Aron Joy Alex Ereira Jack O’Donohue Lisa Pearson https://tax.weil.com/?p=2669 On 1 July 2026, the Supreme Court handed down its long-awaited judgment in HMRC v BlueCrest Capital Management (UK) LLP [2026] UKSC 18 on the application of the salaried member rules, dismissing BlueCrest’s appeal and upholding the Court of Appeal decision to remit the case to the First-tier Tribunal. As discussed in our most recent

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]]> On 1 July 2026, the Supreme Court handed down its long-awaited judgment in HMRC v BlueCrest Capital Management (UK) LLP [2026] UKSC 18 on the application of the salaried member rules, dismissing BlueCrest’s appeal and upholding the Court of Appeal decision to remit the case to the First-tier Tribunal. As discussed in our most recent

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]]> VAT on servicing fees for debt originators: UK-EU divergence? https://tax.weil.com/insights/vat-on-servicing-fees-for-debt-originators-uk-eu-divergence/ Thu, 02 Jul 2026 10:38:45 +0000 Aron Joy Jacky Kelly Akash Mehta https://tax.weil.com/?p=2666 The European General Court has handed down a significant decision in A Oy (Case T-184/25), in which it found that debt servicing provided by an original lender, to a different owner of the loan, was not exempt from VAT as “the management of credit by the person granting it”. This case may have implications for securitisation

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]]> The European General Court has handed down a significant decision in A Oy (Case T-184/25), in which it found that debt servicing provided by an original lender, to a different owner of the loan, was not exempt from VAT as “the management of credit by the person granting it”. This case may have implications for securitisation

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]]> The new carried interest regime: implications for non-residents working in the UK https://tax.weil.com/uk-tax/the-new-carried-interest-regime-implications-for-non-residents-working-in-the-uk/ Fri, 26 Jun 2026 12:45:41 +0000 Aron Joy Alex Ereira https://tax.weil.com/?p=2664 The UK’s new carried interest regime, now in force, raises the effective tax rate on qualifying carried interest to c.34.1% and, as significantly, extends UK taxation to non-UK residents who perform investment management services in the UK. Carried interest is now treated as trading income, with non-qualifying carried interest remaining subject to rates of up

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]]> The UK’s new carried interest regime, now in force, raises the effective tax rate on qualifying carried interest to c.34.1% and, as significantly, extends UK taxation to non-UK residents who perform investment management services in the UK. Carried interest is now treated as trading income, with non-qualifying carried interest remaining subject to rates of up

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]]> Use, Still Not Abuse: Burlington and Treaty Benefits https://tax.weil.com/insights/use-still-not-abuse-burlington-and-treaty-benefits/ Fri, 29 May 2026 16:24:15 +0000 Oliver Walker Enda Kerin Ross Power Molly Syme https://tax.weil.com/?p=2661 The Court of Appeal’s decision in The Commissioners for HMRC v Burlington Loan Management DAC [2026] EWCA Civ 461 marks the latest stage in a significant treaty tax dispute that has now been decided in favour of the taxpayer at three successive levels. It provides important reassurance for secondary debt market participants and other taxpayers

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]]> The Court of Appeal’s decision in The Commissioners for HMRC v Burlington Loan Management DAC [2026] EWCA Civ 461 marks the latest stage in a significant treaty tax dispute that has now been decided in favour of the taxpayer at three successive levels. It provides important reassurance for secondary debt market participants and other taxpayers

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]]> UK Tax Digest https://tax.weil.com/insights/uk-tax-digest-5/ Fri, 24 Apr 2026 11:53:33 +0000 Oliver Walker Aron Joy Alex Ereira Erica Rees https://tax.weil.com/?p=2645 Welcome to the latest edition of the Weil UK Tax Digest, featuring a round-up of tax news over recent months and what to look out for in the coming months. There were no headline tax rate changes or policy announcements at the Spring Statement delivered by Rachel Reeves on 3 March. However, the first half

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]]> Welcome to the latest edition of the Weil UK Tax Digest, featuring a round-up of tax news over recent months and what to look out for in the coming months. There were no headline tax rate changes or policy announcements at the Spring Statement delivered by Rachel Reeves on 3 March. However, the first half

The post UK Tax Digest appeared first on Weil Tax BLOG.

]]> Tax in Distressed Situations https://tax.weil.com/insights/tax-in-distressed-situations-2/ Fri, 20 Mar 2026 15:41:37 +0000 Devon Bodoh Joseph Pari Edouard de Lamy Oliver Walker Stuart Pibworth https://tax.weil.com/?p=2632 Following the launch of the Tax in Distressed Situations microsite, created in collaboration with Loyens & Loeff, in 2025, our global Tax teams and Loyens have published seven updated jurisdictional guides on the topic. The updated guides reflect market trends over the last year as well as a new section addressing Pillar 2 considerations in

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]]> Following the launch of the Tax in Distressed Situations microsite, created in collaboration with Loyens & Loeff, in 2025, our global Tax teams and Loyens have published seven updated jurisdictional guides on the topic. The updated guides reflect market trends over the last year as well as a new section addressing Pillar 2 considerations in

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