On 18 March 2025, HM Treasury issued the Annual Tax on Enveloped Dwellings (Indexation of Annual Chargeable Amounts) Order 2025 (SI 2025/364). This order sets the ATED annual chargeable amounts for chargeable periods starting on or after 1 April 2025. The annual chargeable amounts are determined in accordance with the following table Annual chargeable amount […]
The UK government has announced the suspension of the 1994 UK-Russia Double Taxation Convention, following Russia’s unilateral decision to halt key provisions of the treaty in August 2023. Despite the UK’s request for Russia to reinstate its treaty commitments, no action has been taken. As a result, the UK will revoke the legislation implementing the […]
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 […]
