The First-tier Tribunal (Tax Chamber) recently delivered its decision in Louwman v Revenue and Customs Commissioners ([2025] UKFTT 00295 (TC)), a case that examined the taxation of offshore income gains (OIGs) and accrued income profits (AIPs) in the hands of a UK-resident individual deemed domiciled in the UK. The case provides important insights into statutory […]
On 21 February 2025, the UK and Andorra formalized their first double tax treaty, aimed at preventing double taxation and fostering economic cooperation between the two nations. The agreement applies to the following taxes: The treaty will come into effect once both countries have completed their respective legal processes and officially notified each other through […]
A Significant Ruling on the Interpretation of Exceptional Circumstances In A Taxpayer v Revenue and Customs Commissioners [2025] EWCA Civ 106, the Court of Appeal has provided key clarification on the interpretation of “exceptional circumstances” under the Statutory Residence Test (SRT). The ruling overturns the Upper Tribunal's (UT) restrictive approach and restores the original decision […]
Today, Rachel Reeves, the UK Chancellor has delivered the first Labour's Budget in 14 years. The Chancellor had widely anticipated that this would have involved making "difficult decisions” with tax rises and spending cuts in the value of £40bn. However, the Office for Budget Responsibility has published a detailed assessment of Labour's policies for the next […]
In GCH Corp Ltd v Revenue and Customs Commissioners, the tribunal assessed whether GCH Corp’s LLP was "carrying on a business with a view to profit" as required under Section 59A(1) of the Taxation of Chargeable Gains Act 1992 (TCGA). This decision was pivotal in determining if the LLP could be treated as tax-transparent, which […]
