Weil Tax BLOG - Feed https://tax.weil.com/tag/uk-tax/ Views and developments from the Tax Department at Weil Fri, 29 May 2026 16:24:17 +0000 hourly 1 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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]]> 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 Listing Relief: changes to stamp duty reserve tax in the Autumn Budget https://tax.weil.com/insights/uk-listing-relief-changes-to-stamp-duty-reserve-tax-in-the-autumn-budget/ Wed, 26 Nov 2025 21:08:00 +0000 Kevin Donegan Sarah Flaherty Barbora Lhotáková https://tax.weil.com/?p=2585 Rachel Reeves, the Chancellor of the Exchequer, delivered the 2025 Autumn Budget, the Labour government’s second following their election to office in 2024. Among other changes, Ms Reeves announced a stamp duty reserve tax (“SDRT“) break for newly listed companies. Currently, when investors buy shares listed on a UK regulated market electronically, they pay SDRT

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]]> Rachel Reeves, the Chancellor of the Exchequer, delivered the 2025 Autumn Budget, the Labour government’s second following their election to office in 2024. Among other changes, Ms Reeves announced a stamp duty reserve tax (“SDRT“) break for newly listed companies. Currently, when investors buy shares listed on a UK regulated market electronically, they pay SDRT

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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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]]> Consultation on Energy Profits Levy replacement https://tax.weil.com/insights/consultation-on-energy-profits-levy-replacement/ Mon, 17 Mar 2025 16:22:48 +0000 Sean Wright Josh Hammond https://tax.weil.com/?p=2463 On 5 March 2025, the Government launched a consultation regarding the potential form of a new tax mechanism in times of “unusually high” oil and gas prices entitled Oil and Gas Price Mechanism (the “New Mechanism”). This New Mechanism is framed as a replacement for the Energy Profits Levy (“EPL”). The EPL was introduced in

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]]> On 5 March 2025, the Government launched a consultation regarding the potential form of a new tax mechanism in times of “unusually high” oil and gas prices entitled Oil and Gas Price Mechanism (the “New Mechanism”). This New Mechanism is framed as a replacement for the Energy Profits Levy (“EPL”). The EPL was introduced in

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]]> UK Autumn Budget 2024: Tax Update https://tax.weil.com/insights/uk-autumn-budget-2024-tax-update/ Wed, 30 Oct 2024 19:16:39 +0000 Aron Joy Oliver Walker Erica Rees Ellie Marques Kevin Donegan Lizl Loubser Jack O’Donohue Anna Ritchie Sean Wright https://tax.weil.com/?p=2357 On 30 October 2024, Chancellor Rachel Reeves delivered her highly anticipated Autumn Budget, marking not only the Chancellor’s first budget (and indeed the first budget ever delivered by a female Chancellor) but also the first Labour budget in 14 years. It is fair to say that the past few weeks and months have been full

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]]> On 30 October 2024, Chancellor Rachel Reeves delivered her highly anticipated Autumn Budget, marking not only the Chancellor’s first budget (and indeed the first budget ever delivered by a female Chancellor) but also the first Labour budget in 14 years. It is fair to say that the past few weeks and months have been full

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]]> Location, Location, Location: the Latest on Corporate Re-domiciliation https://tax.weil.com/latest-thinking/location-location-location-the-latest-on-corporate-re-domiciliation/ Mon, 28 Oct 2024 11:28:25 +0000 Erica Rees https://tax.weil.com/?p=2341 On 14 October 2024, a UK independent expert panel (the “Panel”) published its Report on Corporate Re-domiciliation. The Panel was convened in December 2023 to provide advice to the (then) government on how best to establish a UK corporate re-domiciliation framework, and its report follows a consultation launched in October 2021 and concluded in 2022

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]]> On 14 October 2024, a UK independent expert panel (the “Panel”) published its Report on Corporate Re-domiciliation. The Panel was convened in December 2023 to provide advice to the (then) government on how best to establish a UK corporate re-domiciliation framework, and its report follows a consultation launched in October 2021 and concluded in 2022

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]]> No double tax relief for “stapled” company https://tax.weil.com/insights/no-double-tax-relief-for-stapled-company/ Fri, 18 Oct 2024 09:59:11 +0000 Ellie Marques Weil Tax Blog https://tax.weil.com/?p=2337 In The Commissioners for His Majesty’s Revenue and Customs (“HMRC”) v GE Financial Investments (“GEFI”) [2024] EWCA Civ 797, the Court of Appeal was asked to determine whether GEFI was a resident of the United States for the purposes of the UK-US double tax treaty (the “Treaty”) and thus entitled to double tax relief (“Issue

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]]> In The Commissioners for His Majesty’s Revenue and Customs (“HMRC”) v GE Financial Investments (“GEFI”) [2024] EWCA Civ 797, the Court of Appeal was asked to determine whether GEFI was a resident of the United States for the purposes of the UK-US double tax treaty (the “Treaty”) and thus entitled to double tax relief (“Issue

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