Weil Tax BLOG - Feed https://tax.weil.com/contributor/oliver-walker/ Views and developments from the Tax Department at Weil Tue, 21 Jul 2026 15:11:01 +0000 hourly 1 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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]]> 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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]]> You’re welcome to join but you can’t leave: The UK’s Proposed Re-domiciliation Regime https://tax.weil.com/insights/youre-welcome-to-join-but-you-cant-leave-the-uks-proposed-re-domiciliation-regime/ Fri, 15 May 2026 16:13:51 +0000 Oliver Walker Ellie Marques Molly Syme https://tax.weil.com/?p=2655 On 25 March 2026, the Department for Business and Trade published its consultation on implementing a UK corporate re-domiciliation regime, a mechanism that would, for the first time, allow a foreign-incorporated company to change its place of incorporation to the UK whilst preserving the company’s existing legal identity. This consultation is the next step in

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]]> On 25 March 2026, the Department for Business and Trade published its consultation on implementing a UK corporate re-domiciliation regime, a mechanism that would, for the first time, allow a foreign-incorporated company to change its place of incorporation to the UK whilst preserving the company’s existing legal identity. This consultation is the next step in

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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

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]]> 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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]]> Ideas of Exchange: tightened anti-avoidance tests on share-for-share exchanges https://tax.weil.com/whats-new-on-the-blog/ideas-of-exchange-tightened-anti-avoidance-tests-on-share-for-share-exchanges/ Thu, 12 Feb 2026 12:15:11 +0000 Oliver Walker Akash Mehta Enda Kerin https://tax.weil.com/?p=2611 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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]]> 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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]]> EMI Option Regime: Autumn Budget Changes https://tax.weil.com/insights/emi-option-regime-autumn-budget-changes/ Mon, 01 Dec 2025 13:03:25 +0000 Oliver Walker Kevin Donegan Barbora Lhotáková https://tax.weil.com/?p=2587 Among other changes announced as part of the UK Autumn Budget 2025, Rachel Reeves, the Chancellor of the Exchequer, announced that some of the limits that restrict the availability of the Enterprise Management Incentive (“EMI”) share option regime will be relaxed from 6 April 2026: In addition, from 6 April 2027, failure to notify HMRC

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]]> Among other changes announced as part of the UK Autumn Budget 2025, Rachel Reeves, the Chancellor of the Exchequer, announced that some of the limits that restrict the availability of the Enterprise Management Incentive (“EMI”) share option regime will be relaxed from 6 April 2026: In addition, from 6 April 2027, failure to notify HMRC

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]]> UK Autumn Budget 2025: Tax Update https://tax.weil.com/insights/uk-autumn-budget-2025-tax-update/ Wed, 26 Nov 2025 19:15:13 +0000 Oliver Walker Aron Joy Kevin Donegan Erica Rees Sean Wright Barbora Lhotáková Joseph Nixon https://tax.weil.com/?p=2580 On 26 November 2025, Chancellor Rachel Reeves delivered her Autumn Budget, following an intense period of speculation. Although personal tax measures took centre stage, key business tax announcements included the introduction of UK stamp duty reserve tax relief for UK-listed companies and an extension of the Enterprise Management Incentive share option scheme. Below is a

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]]> On 26 November 2025, Chancellor Rachel Reeves delivered her Autumn Budget, following an intense period of speculation. Although personal tax measures took centre stage, key business tax announcements included the introduction of UK stamp duty reserve tax relief for UK-listed companies and an extension of the Enterprise Management Incentive share option scheme. Below is a

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]]> UK Tax Digest https://tax.weil.com/insights/uk-tax-digest-4/ Wed, 10 Sep 2025 11:33:15 +0000 Oliver Walker Aron Joy Akash Mehta Erica Rees https://tax.weil.com/?p=2563 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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]]> 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

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

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