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Aspiring Lawyers - Applications & General Advice
Applications Discussion
TCLA Vacation Scheme Applications Discussion Thread 2025-26
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<blockquote data-quote="LauraWhite0502" data-source="post: 229267" data-attributes="member: 43445"><p>You've definitely identified all the main points! One additional thing worth noting (although this might be what you mean by compliance requirements) is in the budget the rules which decide when a global company has to pay tax in the UK has changed. </p><p></p><p>The 'permanent establishment' rules which decide when a foreign company is regarded as doing business in the UK have changed, so that if a company based abroad has someone who habitually concludes contracts or plays a principal role in leading contract negotiations, HMRC can regard the company as really operating in the UK and so tax some of the company's profits. </p><p></p><p>Similarly, historically multinational groups have been able to shift their profits out of the UK, which the UK tried to combat in 2015 by introducing a piece of legislation called the Diverted Profits Tax , although this was widely regarded as too complex and procedurally messy. The budget has reformed the Diverted Profits Tax, so that HMRC can now re-characterise and tax those profits directly under normal corporation tax rules. This reduces compliance costs and administrative burdens for both businesses and HMRC. </p><p></p><p>Rather than focusing on the specifics of these policies though, I'd instead think about what broader shift they represent. Essentially they reduce practical loopholes which some companies were relying on to reduce their UK tax liability and suggest an area of focus for the government is ensuring companies can't rely on technicalities to pay less tax. </p><p></p><p>This creates an opportunity for law firms to shift the focus of their tax advice to clients: rather than advising clients on what technical loopholes might be available, tax teams might instead benefit from focusing on helping clients structure their business model (particularly where decision-making and key negotiators are based) to avoid falling within the scope of the permanent establishment rules.</p></blockquote><p></p>
[QUOTE="LauraWhite0502, post: 229267, member: 43445"] You've definitely identified all the main points! One additional thing worth noting (although this might be what you mean by compliance requirements) is in the budget the rules which decide when a global company has to pay tax in the UK has changed. The 'permanent establishment' rules which decide when a foreign company is regarded as doing business in the UK have changed, so that if a company based abroad has someone who habitually concludes contracts or plays a principal role in leading contract negotiations, HMRC can regard the company as really operating in the UK and so tax some of the company's profits. Similarly, historically multinational groups have been able to shift their profits out of the UK, which the UK tried to combat in 2015 by introducing a piece of legislation called the Diverted Profits Tax , although this was widely regarded as too complex and procedurally messy. The budget has reformed the Diverted Profits Tax, so that HMRC can now re-characterise and tax those profits directly under normal corporation tax rules. This reduces compliance costs and administrative burdens for both businesses and HMRC. Rather than focusing on the specifics of these policies though, I'd instead think about what broader shift they represent. Essentially they reduce practical loopholes which some companies were relying on to reduce their UK tax liability and suggest an area of focus for the government is ensuring companies can't rely on technicalities to pay less tax. This creates an opportunity for law firms to shift the focus of their tax advice to clients: rather than advising clients on what technical loopholes might be available, tax teams might instead benefit from focusing on helping clients structure their business model (particularly where decision-making and key negotiators are based) to avoid falling within the scope of the permanent establishment rules. [/QUOTE]
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Applications Discussion
TCLA Vacation Scheme Applications Discussion Thread 2025-26
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