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On 13 July 2026, HMRC published a consultation on simplifying the process for obtaining treaty relief from UK withholding tax on interest paid overseas. The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this could reduce delays, administrative burden and cash-flow issues under the current regime.
On 13 July 2026, HMRC published a consultation on simplifying the process for obtaining treaty relief from UK withholding tax on interest paid overseas. The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this could reduce delays, administrative burden and cash-flow issues under the current regime.
The Supreme Court has handed down its judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal and providing important clarification on the application of the salaried members rules to investment management LLPs. The decision is particularly significant for asset managers, hedge fund managers and other investment management businesses operating through LLPs. Many such businesses have members who are economically important to the firm, make substantial investment...
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