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Ideas of Exchange: tightened anti-avoidance tests on share-for-share exchanges

Oliver Walker — Thu, 12 Feb 2026 12:15:11 +0000

Amendments included in the Finance Bill 2025-26, which is currently proceeding through Parliament, expand the anti-avoidance rules relating to share-for-share exchanges and other corporate reorganisations. The government is seeking to tighten the availability of tax-neutral treatment of transactions in which shares are issued as consideration or as part of certain reorganisations. The changes have been introduced

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UK Tax Digest

Oliver Walker — Wed, 10 Sep 2025 11:33:15 +0000

Welcome to this edition of Weil’s UK Tax Digest, featuring a roundup of key tax developments. The past six months have seen significant policy announcements and consultations across a number of areas of UK taxation, draft legislation for the next Finance Bill, and speculation about tax increases in the upcoming Budget to be delivered on

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Responses Published on UK Transfer Pricing, Permanent Establishments and Diverted Profits Tax Consultation

Akash Mehta — Thu, 18 Jan 2024 20:06:29 +0000

Earlier this week, the UK government published a summary of responses to the consultation on reforms to the UK transfer pricing, permanent establishments and the diverted profits tax (DPT) rules. The consultation was launched in June 2023, as discussed in our blog post. The transfer pricing proposals included aligning terminology between the UK rules and

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Court of Appeal upholds Euromoney share for share exchange

Oliver Walker — Mon, 20 Nov 2023 16:07:50 +0000

On Friday 3 November 2023, the Court of Appeal dealt a further blow to HMRC in the appeal of the Euromoney decision. HMRC had appealed from the Upper Tribunal, which found that an anti-avoidance rule did not preclude the deferral of corporation tax on a share for share exchange where consideration received for the sale of shares consisted of new shares (including a choice of preference shares specifically for tax avoidance reasons). The Court of Appeal dismissed HMRC’s appeal against the Upper Tribunal decision, and found that the taxpayer was entitled to the tax deferral because the exchange of shares (i) was entered into for bona fide commercial reasons, and (ii) as a whole did not have as a main purpose the avoidance of tax.

UK Government Launches Consultation on Transfer Pricing, PEs and DPT

Akash Mehta — Mon, 19 Jun 2023 17:40:08 +0000

As foreshadowed in April’s Tax Administration and Maintenance Day, HMRC has today (19 June 2023) launched a consultation on reforms to the UK tax rules on transfer pricing, permanent establishments and the Diverted Profits Tax. The proposals include more closely aligning transfer pricing and permanent establishment rules with OECD principles (and, in the case of

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Spring Budget 2023: Tax Update

Aron Joy — Wed, 15 Mar 2023 19:55:43 +0000

On 15 March 2023, Chancellor Jeremy Hunt delivered his Spring Budget, declaring that this would be a budget focussed on growth. In keeping with predictions, there were no major tax cuts announced in today’s Budget. However, there are still some significant changes for business, including immediate deductions for certain capital expenditure, and in relation to

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CJEU confirms that sub-participations are exempt from EU VAT

Erica Rees — Mon, 07 Nov 2022 14:56:33 +0000

In its October 2022 decision in O. Fundusz Inwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21), the Court of Justice of the European Union (CJEU) confirmed that a sub-participation falls within the exemption from VAT for granting credit. The decision will be a relief for banks and other lending institutions, after Advocate General Medina’s opinion

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Repeal of IR35 Reforms

Oliver Walker — Tue, 27 Sep 2022 17:43:59 +0000

UPDATE: On Monday 17 October, the Chancellor, Jeremy Hunt, announced that the Government was not proceeding with the measures described below. The “IR35” off-payroll working rules remain relatively controversial due to their relative complexity and the administrative burden they create. Many commentators continue to call for both future reform of the rules and further consideration of

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MDR/DAC 6 Update

Akash Mehta — Wed, 05 Jan 2022 18:56:48 +0000

On 30 November 2021, the U.K. government published a draft of new disclosable arrangements regulations, setting out the U.K.’s post-Brexit mandatory disclosure regime based on the framework established by the Organisation for Economic Co-operation and Development (the OECD) (the MDR Regulations). As we reported in December 2020, the scope of reporting in the U.K. under

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DAC6: Significantly Limited Scope in the UK post-Brexit

Oliver Walker — Thu, 31 Dec 2020 18:29:14 +0000

A piece of good news on which to end the year and start the next – the UK Government has published regulations dramatically reducing the scope of DAC6 (the EU Mandatory Disclosure Regime) in the UK as part of the Brexit deal package/post transition arrangements. In short, the effect seems to be that DAC6 will,

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