FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Stamp duty and SDRT will, in 2027, be replaced with a single, self-assessed tax on transfers of securities, the securities transfer tax (STT) (formerly referred to as the securities transfer charge or STC), that will be paid (and reported) through electronic transfer systems such as CREST or, where appropriate, a new online portal. Draft legislation for the STT was published on 13 July 2026, along with explanatory notes, a policy paper and the outcome of the higher rate 1.5% stamp tax consultation. Subject to exemptions, the STT draft legislation includes a main charge of 0.5% for agreements to transfer chargeable securities to another person for consideration in money or money’s worth and, for transfers to a clearance service (CS) or depositary receipt issuer (DRI), a higher-rate charge of 1.5%. The main charge arises when an agreement is made or, in the case of a conditional agreement, when the conditions are satisfied, although, where the agreement is not electronic, the STT

It is natural that spouses or civil partners may want to make gifts to each other since it is fairly typical for couples to share their property. The term ‘spouses’ is used in this Practice Note to refer to both married couples and parties to a registered civil partnership, in each case of any gender. It may be sensible to even up the couple’s assets so that they each have their own financial security and this also provides the greatest scope for tax planning. For example, if one spouse pays income tax at a higher rate than the other, it makes sense for them to allocate more of their income-producing assets to the spouse who pays income tax at lower rates. The same principle applies for capital gains tax (CGT) where it makes sense to ensure that each spouse uses their annual exemption if they make chargeable disposals and that they pay tax at the lowest possible rates. Given that spouses can pass assets between each

This Practice Note considers the UK tax aspects of the establishment, operation and termination of contractual joint ventures, and also considers how the joint venture parties may distinguish such an arrangement from a partnership. It is assumed for the purpose of this Practice Note that the joint venture parties are UK tax resident corporate entities and that the business of the joint venture is located in the UK (for information on joint ventures with a non-UK element, see Practice Note: Tax implications of international joint ventures). What is a contractual joint venture? A joint venture is a commercial arrangement entered into by two or more independent parties. There are no specific laws, including tax laws, applicable to joint ventures and no technical legal meaning of the term. A joint venture can take many forms. For example, it may be operated through a separate joint venture vehicle, commonly a limited liability company or a partnership. Alternatively, and at its

This Practice Note sets out the tax implications of entering into marriage and civil partnership, including in relation to income tax, capital gains tax and inheritance tax. Specialist advice should be sought as necessary. The tax consequences of civil partnership are identical to those of marriage. A party is treated as married or as a civil partner for UK tax purposes, if they have been through a formal marriage or civil partnership ceremony, or, from 10 December 2014, converted their civil partnership into a marriage by formal declaration. Living together or common law arrangements do not count as a marriage/civil partnership. The income tax and capital gains tax (CGT) legislation refers to spouses/civil partners who are 'living together'. This does not necessarily mean in the same house or even the same country: it includes all spouses/civil partners, unless they are separated under an order of a court or a formal deed of separation executed under seal (except in Scotland where the deed should be witnessed and registered), or they are in fact

This Practice Note considers the UK tax aspects of the establishment of a joint venture operated through a limited liability company (JVCo), a separate legal entity from the joint venture parties. More specifically, it discusses: • why a corporate joint venture vehicle is commonly used • the tax charges that arise for a joint venture party on a transfer of assets to a JVCo • the tax charges that arise for the JVCo on the transfer of assets to it • additional considerations where the JVCo is or becomes part of a group with one joint venture party, and • merger relief where subsidiaries are transferred to the JVCo For information on the tax aspects of the operation and termination of joint ventures using a JVCo, see Practice Note: Tax implications of operating and terminating a joint venture company. It is assumed for the purpose of this Practice Note that the joint venture

This Practice Note considers the UK tax aspects of the establishment of a joint venture operated through a partnership. It is assumed for the purposes of this Practice Note that: • the joint venture parties are UK tax resident corporate entities • the joint venture partnership vehicle is also UK tax resident, and • the venture’s operations are carried out in the UK For information on: • operating and terminating a joint venture partnership, see Practice Note: Tax implications of operating and terminating a joint venture partnership, and • joint ventures with a non-UK element, see Practice Note: Tax implications of international joint ventures This Practice Note does not deal with certain types of investment partnership constituting unit trust schemes that may not be treated as transparent for tax purposes. What types of partnership may be used for a joint venture? A joint venture may use one of the following three main types of

This Practice Note looks at examples of orders in financial proceedings and the range of tax issues that may arise where periodical payments orders, lump sum orders or property adjustment orders are made or where there are business assets. The Finance (No 2) Act 2023 received Royal Assent on 11 July 2023. Section 41 of the Finance (No 2) Act 2023 amended the Taxation of Chargeable Gains Act 1992 (TCGA 1992) so that where a disposal occurs on or after 6 April 2023, changes were made to the capital gains tax (CGT) rules that apply to transfers of assets between spouses and civil partners who are in the process of separating, ie: • separating spouses or civil partners are given up to three years after the end of the tax year in which they cease to live together or up to (if earlier) the date of the final divorce/dissolution or annulment order or (judicial) separation in which to make no gain/no loss transfers • no gain/no loss treatment will also applies to assets that separating spouses

This Practice Note considers the key tax issues arising when structuring, operating and terminating an international joint venture, over and above those raised by a domestic UK joint venture. For information on the UK tax aspects of domestic joint ventures see Practice Notes: • Tax implications of contractual joint ventures • Tax implications of establishing a joint venture partnership • Tax implications of operating and terminating a joint venture partnership • Tax implications of establishing a joint venture company • Tax implications of operating and terminating a joint venture company For the purposes of this Practice Note, an international joint venture is considered to be an arrangement where either the joint venture vehicle (if one exists) or at least one of the joint venture parties is non-UK tax resident. It is assumed for the purposes of this note that the joint venture parties are corporate entities. For information on the corporate aspects of international joint ventures, see Practice Note: Cross-border joint ventures—overview. Tax

This Practice Note considers the UK tax aspects of the operation and termination of a joint venture operated through a limited liability company (JVCo), a separate legal entity from the joint venture parties. For information on the tax aspects of the establishment of a JVCo, see Practice Note: Tax implications of establishing a joint venture company. It is assumed for the purposes of this Practice Note that the joint venture parties are UK tax resident corporate entities and that the JVCo is UK tax resident (for information on joint ventures with a non-UK element, see Practice Note: Tax implications of international joint ventures). Operation of the JVCo Extraction and taxation of the JVCo’s profits As the JVCo is a separate legal entity, profits from its operation will accrue to the company itself rather than directly to the joint venture parties (as they would, for example, in a contractual joint venture or a joint venture partnership).

This Practice Note considers the UK tax aspects of the operation and termination of a joint venture operated through a partnership. It is assumed for the purposes of this note that: • the joint venture parties are UK tax resident corporate entities • the joint venture partnership vehicle is also UK tax resident, and • the venture’s operations are carried out in the UK For information on: • the establishment of a joint venture partnership, see Practice Note: Tax implications of establishing a joint venture partnership, and • joint ventures with a non-UK element, see Practice Note: Tax implications of international joint ventures This Practice Note does not deal with certain types of investment partnership constituting unit trust schemes that may not be treated as transparent for tax purposes. Tax implications of operating a joint venture partnership Broadly a joint venture partnership operates no differently from any other partnership, since partnerships are, by

ARCHIVED: This Practice Note has been archived and is not maintained. Until 5 April 2013, ordinary residence remains one of three key factors you should consider when deciding whether, or to what extent, an individual is liable to tax in the UK. The others are residence and domicile. Residence refers to the individual's tax status on a year by year basis, ordinary residence looks at the position over the longer term, and domicile is the place which a person regards as his true home. See the Residence before 6 April 2013 [Archived] and Domicile for UK tax purposes before 6 April 2025 [Archived] Practice Notes for more detail. The concept of ordinary residence is explained in the Ordinary residence before 6 April 2013 [Archived] Practice Note. This Note explains why ordinary residence is important and also looks at the application of the ordinary residence rules before 6 April 2013 to people coming to the UK and leaving the UK. For the application of the ordinary residence rules to visitors, see

This Practice Note sets out the tax implications to be considered on relationship breakdown, ie separation, divorce or dissolution, including income tax, capital gains tax, stamp duty land tax and inheritance tax. Specialist advice should be sought where necessary. As there are no specific tax consequences to the relationship between unmarried couples or those who have not formed a civil partnership, so there are no special tax rules relating to their relationship breaking down. There is, however, a general rule for capital gains tax (CGT) that transactions not at arm's length must be recalculated as having been at market value—a transaction between an unmarried/non-civil partnership couple living together may well be treated as not having been at arm's length. For married couples and civil partners, the main tax provisions relating to spouses/civil partners cease to apply when the relationship has broken down, rather than by reference to the date of the conditional order or final order. For inheritance tax (IHT) purposes, the date of the final order is relevant. Note that divorce, dissolution or separation