Emma C. McDonnell, Richard Miller and Daniella Abel
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HMRC guidance provides welcome comfort for private equity management rollovers
HMRC has published updated guidance on the revised share reorganisation anti-avoidance rules following the changes introduced by Finance Act 2026. The guidance provides welcome confirmation that standard private equity management rollover arrangements should continue to benefit from share-for-share exchange relief despite concerns raised by the widening of t
HMRC consults on aligning the taxation of distributions from non-UK resident companies
HMRC has published a consultation on proposals to modernise the UK tax framework for distributions and repayments of capital made by companies to individual and trust shareholders. A key feature of the consultation is a proposal to align the income tax treatment of distributions made by UK and non-UK resident companies by bringing distributions from non-UK r