Insights & Tax Updates
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HMRC’s renewed focus on interest deductions
Over the past several months, HMRC has been writing to a number of companies — typically those with open enquiries into the deductibility of interest on acquisition or group financing arrangements — referencing the so-called “unallowable purpose rule” under sections 441–442 of the Corporation Tax Act 2009.
March 18, 2026
The “insurance” letter that ruins a Saturday
Alex is 46, UK-resident, busy, and financially organised (or so he thinks). One Saturday morning he opens a thick envelope from an insurer. The headline is bland:
March 18, 2026
Moving abroad – ISA and pension
Moving abroad, ISA and pension: what to check before you leave, what you can keep, what changes, and when it makes sense to get professional advice.
March 18, 2026
Can Last-Minute Inheritance Tax Hacks Really Work? Lessons from t
The recent case of Carvajal v HMRC has put a spotlight on the risks and complexities of last-minute inheritance tax (IHT) planning. This case involved Mrs. Fleet, a UK taxpayer who sought to reduce the tax bill on her estate shortly before her passing.
March 18, 2026
Making Tax Digital for income tax: preparing for the 2026 rollout
From April 2026, if you earn income from property or self-employment and your total gross income is more than £10,000 a year, you'll have to start reporting your taxes to HMRC in a very different way.
March 18, 2026
Inheritance Tax and Excluded Property
From April 2025 the UK’s inheritance tax (IHT) system moved from a domicile‑based framework to a residence‑based regime. This shift means that individuals who meet the definition of a long‑term UK resident will be exposed to IHT on worldwide assets sooner than before. Understanding when assets are treated as excluded property—and therefore outside the scope of IHT—is now critical for families and trustees with cross‑border connections.
March 18, 2026
Long-term residence: the new key inheritance tax status
He built an international career in finance, bought a flat in Zone 2, kept the family holiday home in Abruzzo, and – on the advice of a banker friend – settled some investments into a trust in Jersey “for succession planning”. His wife, Francesca, preferred to stay mainly outside the UK, coming over only for short periods.
March 18, 2026
Quando la pensione diventa “eredità”
Laura ha 58 anni, vive in UK da tempo e ha fatto le cose per bene: casa, qualche investimento, e soprattutto un pension pot cresciuto anno dopo anno.
Nella sua testa la pensione aveva un ruolo preciso: “Quella la lascio ai figli. È il pezzo più efficiente da trasferire.”
March 18, 2026
Hybrid Mismatch arrangements in the UK
We are pleased to announce that our CEO, Angelo Chirulli (ACA, ADIT, BFP, IFA, Dottore Commercialista), will be speaking at an upcoming MBL Seminars webinar on:
Hybrid Mismatch Arrangements in the UK – Practical Implications for Cross-Border Structures
March 18, 2026
Roberto sold his Puglia villa? and now?
Roberto moved from Bari to London in 2015. Like many Italians abroad, he kept a strong connection to his home country. Every summer, he and his family returned to Puglia, where they enjoyed long weeks in a small villa near the coast.
March 18, 2026
Transfer pricing part two: the costs and the benefits
Cost Analysis
Direct costs include consulting fees, technology investments, and training expenses.
These are the upfront costs associated with implementing a transfer pricing strategy.
Indirect costs, such as temporary...
March 18, 2026
Is that HMRC Letter genuine? know how to check
In today’s digital age, more businesses and individuals are receiving communications claiming to be from HMRC.
March 18, 2026
BEYOND THE COMMENTARY
Proactive Tax Strategy Starts with a Conversation.
Don’t navigate complex cross-border regulations or HMRC compliance alone. Angelo provides technically grounded commentary and actionable advice tailored to specific corporate or private needs.