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Articles by Tom Margesson
Q&A: Private capital and mandatory tax adviser registration: widening of exclusions for in-house tax teams
Private capital and mandatory tax adviser registration: widening of exclusions for in-house tax teams. If you or your firm subscribes to Taxation.co.uk, please click the login box below: If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes: Username * Password * Once you have registered, you will receive an email directing you back to read this item in full.
One minute with... Tom Margesson
I focus on advising private capital managers and their investment funds. Recently that’s resulted in lots of work on evergreen fund structures (open-ended fund structures designed to attract non-professional investors), investments into fund managers (as managers look to scale and realise their own value) and secondaries transactions (as funds hunt for alternative ways to realise their investments).
Private Capital And Mandatory Tax Adviser Registration: Widening Of Exclusions For In-house Tax Teams
The UK tax authority (HMRC) has recently announced that it will expand the exclusions from its new mandatory tax adviser registration requirement. Under this expansion, an exclusion will apply to a wider range of circumstances where advice is provided outside of a traditional tax adviser - third party commercial relationship.
UK: HMRC Eases Tax Adviser Rules
An analysis from Travers Smith, Taxand UK The UK tax authority (HMRC) has recently expanded the exclusions to its new Mandatory Tax Adviser Registration regime, providing welcome clarity for businesses with in-house tax functions. The updated guidance confirms that registration is generally not required where there is no genuine third-party commercial advisory relationship, addressing concerns that the original rules could have captured routine support provided by internal tax teams.
M Elborne and others v HMRC
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Legislation Day 2026: The Foreign Branch Exemption reforms
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HMRC manual changes: 10 July 2026
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When Ramsay does not rescue HMRC
The Upper Tribunal (UT) decision in HMRC v GCH Corporation Ltd and others [2026] UKUT 219 (TCC) contains insights in relation to procedural grounds and permissions for appeal, and the difference between a ‘trade’ and a ‘business’ and why those are not the same thing, which is of wider interest than just partnership tax law. But this comment focuses on another aspect: the Ramsay principle.
Horizon family payments to be exempt from tax
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BlueCrest: the impact for asset managers
The Supreme Court has released its long-awaited judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal: an important decision for asset managers operating through LLP structures. The decision is likely to lead to increased HMRC scrutiny of both profit-sharing arrangements under Condition A and ‘significant influence’ positions under Condition B.
Directors’ liability: tax schemes
The recent decision in Barriball & Whitehouse v Jackson & Hughes [2026] EWHC 1135 explained that the consequences of a tax scheme which does not work can be visited on the directors. This may cause alarm in some quarters. What happened is that HSJ Consultancy Ltd entered into a tax scheme which in due course was successfully challenged by HMRC. It involved substantial payments to an EFRBS and an Employee Benefit Trust for the benefit of the directors.
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
Whilst many in the private capital industry will be disappointed by the Supreme Court's decision, the judgment provides some much needed clarity on the application of the significant influence condition. The Supreme Court decision confirms the importance of rights and duties under the LLP agreement when assessing whether a member fails Condition B. If they have not already done so, we are likely to see firms revisiting their LLP agreements to ensure influence is properly embedded in them.
HMRC confirm transitional approach to Pillar Two filing penalties
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Tax Update day: a flexible friend?
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UK Government Consults On Plans To Bring Forward Income Tax Payment Dates
Tom Margesson’s articles from Travers Smith LLP are most popular: in European Union in European Union in European Union in European Union The UK government has launched a consultation on plans to reform the income tax payment regime. The key plank of the proposals is that, from April 2029, tax payments for self-assessment income taxpayers will be due in-year, so significantly earlier than under the current rules.
UK Government Proposes Reform Of Taxation Of LLC Members
HMRC has framed the consultation as a pro-growth measure, with the proposals designed to enhance the UK's attractiveness to talented globally mobile individuals. The UK's appeal to that community has been dented, in particular, with last year's removal of the non-dom regime and, for private capital managers, the recent reform of carried interest taxation, so the consultation is potentially a welcome change of direction from the government.
Finalised Guidance On Reformed Investment Manager Exemption Published
Elena Rowlands’s articles from Travers Smith LLP are most popular: with readers working within the Aerospace & Defence industries The IME is a longstanding plank of the UK's tax regime. It is designed to support the UK investment management sector by giving comfort to non-resident investors that they will not be subject to UK tax on transactions, simply because they are conducted on their behalf by UK managers.
Court Applies Mixed Member Partnership Anti-avoidance Tax Rules To LLP Member Remuneration
Elena Rowlands’s articles from Travers Smith LLP are most popular: with readers working within the Law Firm industries Travers Smith LLP are most popular: within Environment topic(s) HMRC has become increasingly assertive in seeking to apply income tax charges to returns that LLP members have viewed as capital or non-taxable in nature.
Tax and the private capital sector in 2026: three key issues
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Travers Smith's Venture Insights: Behind The UK Budget Headlines - Impacts On Venture
Travers Smith LLP are most popular: in United Kingdom It's been a long time since a UK Budget and especially its behind-the-scenes mechanics (leaks, briefings and uploads) caused such a row. Looking behind those headlines, there was lots in the Budget of potential value to venture capital, but with a tax raising sting in the tail which we'll come to at the end. First, no news was good news for private capital generally.
Welcome Changes Made To New UK Carried Interest Tax Regime
TS Travers Smith LLP More It’s not just law at Travers Smith. Our clients’ business is our business. Independent and bound only by our clients’ ambitions, we are wherever they need us to be. We focus on key areas of work where we are genuinely market leading. If it’s hard – ask Travers Smith. The government yesterday, 4 December 2025, published an updated draft of the legislation implementing the UK's new carried interest tax regime coming into force from 6 April next year. United Kingdom Tax
Travers Smith's Alternative Insights: Does The UK Have A Coherent Strategy For Private Capital? (Podcast)
Simon Witney’s articles from Travers Smith LLP are most popular: with readers working within the Securities & Investment industries Travers Smith LLP are most popular: in United Kingdom KEY INSIGHTS Limited new tax burdens: The UK Budget did not introduce significant additional taxes on private capital executives or wealthy individuals, offering some relief for the sector following unhelpful speculation in the run-up.
HMRC change of policy: VAT on insurance intermediary services
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Meet in the middle: HMRC’s transfer pricing settlement policy
HMRC have issued new advice to their compliance teams and governance boards on settling transfer pricing (TP) enquiries where HMRC consider that a taxpayer’s filed position is outside the arm’s length range and relief from double taxation is available by treaty under the Mutual Agreement Procedure (MAP). In such cases, the default position will be for HMRC to adjust to a central point in the range (for example, the median in the set of comparables used to establish the arm’s length range).
Uber London Ltd v HMRC
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The new non-dom rules
The new rules for non-doms have a surprisingly advantageous effect for some people. There are a significant number of people who were born in the UK with a UK domicile of origin and who later acquired a foreign domicile of choice. Under the old rules, if they become UK resident they were immediately deemed domiciled in the UK – although there was a one-year period of grace for IHT.
Fiscal drag and the additional rate of income tax
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Seven tax proposals for growth
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J Boulting v HMRC
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Exclusive purposes
The recent decision of the Upper Tribunal in Investment and Securities Trust Ltd v HMRC [2025] UKUT 331 (TCC) (reported in Tax Journal, 24 October 2025) may have a wider significance than the SDLT and ATED issues which were the particular subject matter of the case. It is all about the meaning of ‘exclusively’ – a term with which we are all extremely familiar. But there is more. Brief context.
The VAT review for November 2025
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HMRC v Ducas Ltd
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Close encounters with close companies (part 2): common issues in practice
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Northumbria Healthcare NHS Foundation Trust v HMRC
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