Insights

Where property values have reduced and traditional funding terms are harder to achieve, structured debt can be an effective way to support transactions. Structured debt arrangements bridge valuation gaps or lender risk appetite by combining a conventional coupon with equity‑like economics, such as profit participation, IRR hurdles, contingent returns, or exit‑linked fees.

When someone who was not a long-term UK resident dies – or, for deaths before 6 April 2025, was non-UK domiciled – while holding UK assets, the UK IHT reporting requirements can be difficult to understand. We’ve outlined these requirements in this article, including why reporting may still be required even when no IHT is due. In particular, we focus on how the reporting rules apply to “excepted estates” in these circumstances.

Within the financial services sector, innovation is rarely superficial. It often involves deep technical and mathematical problem‑solving, delivered within highly constrained environments whilst achieving low latency, high throughput and regulatory compliance. All of this must be delivered whilst facing increasingly tight cost controls.

In June 2019, the UK became the first major economy to legislate a legally binding greenhouse gas emissions target for 2050, shifting the statutory ambition from an 80% reduction to net zero. Critically, delivery at the pace and scale required is increasingly becoming a capital mobilisation challenge, not just a policy design one.

HMRC is using AI and data analytics to identify discrepancies faster and more accurately than ever before. Tax investigations are no longer driven by random checks alone, with enquiries now increasingly triggered by digital records, online activity, and automated risk analysis.

If your company operates a share or share option plan for employees or office holders (including directors and company secretaries), or if individuals have acquired shares or other securities in the company, you are required to report the relevant transactions to HMRC on an annual basis.

The OECD Pillar Two framework establishes a global minimum tax regime which applies to multinational groups with consolidated revenue over €750 million. For those that exceed this threshold, the rules aim to ensure income is taxed at a global minimum effective tax rate of 15% on a jurisdiction-by-jurisdiction basis. The 30 June 2026 Pillar Two information return deadline is now imminent for large groups, and those impacted need to urgently ensure they are ready for reporting.

Following the Court of Appeal decision which determined that certain grant funding provided to Colchester Institute Corporation (‘CIC’) constituted third party consideration for the provision of educational services, HMRC has now published Revenue and Customs Brief 3 (2026).