Conversion into sterling It is a basic rule that, in order to calculate the UK tax, all income and gains must be expressed in sterling. Where income is received or assets are bought or sold in a foreign currency, there is a need to translate the foreign currency amounts into sterling. It is therefore necessary to identify a currency conversion date and ascertain the exchange rate for that date. The general rule is that trustees of UK resident trusts are subject to tax on the arising basis on foreign income. It is accepted that, where foreign income is taxed on the arising basis, the applicable foreign exchange rate will be that on the date the income arises. Where the income arises regularly throughout the year, it is acceptable to use an average rate for the year. Where a life tenant of a trust makes a claim for relief under the foreign income and gains (FIG) regime, foreign income which is ‘qualifying foreign income’ is not taxed even if remitted for the first four years that the life

This flowchart illustrates the main taxes applicable to different UK residential property ownership structures

There are a number of relevant taxes which need to be considered when an individual seeks to acquire a residential property. Frequently, there is also consideration given as to whether or not it may be preferable to acquire the residential property in some form of structure or entity as opposed to acquiring it in an individual’s personal name. Aside from any other relevant factors, such as for instance the need for flexibility or confidentiality, a common driving factor is often the differing tax treatment. The aim of this Practice Note is to set out by way of a summary the relevant UK taxes which need to be considered as part of any analysis and to cross-refer to more detailed content on the various taxes. This Practice Note focuses on property held by or for an individual for personal use or investment purposes and does not cover property trading. Practice Note: Dealing in property or property investment? highlights the key considerations in distinguishing between a trading or investment

Ofcom has announced that the new UK roaming rules, intended to protect customers who are using their phone abroad, have entered into force on 1 October 2024. These rules require providers to notify customers when they begin roaming and provide clear information on roaming charges, fair use limits and spend caps. Providers must also alert customers to inadvertent roaming, particularly in border regions, and assist them in managing their mobile costs.

Law360: A UK judge ruled 23 April 2024 that a Sri Lankan shipping company cannot bring a claim against a London-based insurer in its home country over liability for a sunken container ship because the insurance contract is governed by English law.

This table provides an overview of the conditions that must be met before counteraction is required under the various chapters of the UK hybrid rules. For more detailed information on the hybrid rules that have been in effect since 1 January 2017, and the numerous changes made to them since then, see Practice Note: Hybrid mismatches—introduction to the rules. Relevant chapter of the hybrid rules Individual condition(s) Payment/quasi-payment is made Payer or payee within charge to corporation tax (CT) Hybrid deduction/non-inclusion (D/NI) mismatch or double deduction (DD) Relevance of connection/structured arrangement Ch 3: Financial instruments Financial instrument (section 259CA(2) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010)) Yes, under, or in connection with, a financial instrument (Condition A) (TIOPA 2010, s 259CA(2)) Yes, Condition B (TIOPA 2010, s 259CA(3)) Reasonable to suppose that, but for these provisions and any foreign equivalent provisions, there would (applying the 'relevant assumptions') be a D/NI mismatch in relation to the payment or quasi-payment (Condition C for Chapter 3 and Condition D for Chapters 4, 5 and 7) (TIOPA 2010,

Law360: HM Treasury has said it has blacklisted Moscow insurance giant Ingosstrakh in a move to curb the growth of a 'shadow fleet' of vessels carrying Russian oil at a price above an internationally agreed cap.

MLex: UK sanctions imposed in the aftermath of Russia’s invasion of Ukraine have been ‘broadly effective’ and well-coordinated with the EU and the US, but there are open questions about the efficacy of enforcement, the House of Lords European Affairs Committee (EAC) said today.

MLex: UK sanctions enforcers opened 29 criminal cases into possible sanctions offences last year, the majority of which are related to Russia, the head of the country’s tax authority has told lawmakers. One case has been sent to prosecutors with a view to bringing criminal charges, the tax chief said.

MLex: UK government plans to consolidate sanctions lists and speed up enforcement of civil-law breaches will be welcomed as aims, but the new plan fails to grasp the nettle of patchy enforcement. The latest look at the sanctions regime appears largely silent on how to improve matters: The government said it would look to increase the deterrent effect of enforcement, but appeared not to mention any new resources for investigators.

This Practice Note provides information on UK sanctions regimes currently in force, including regimes under the Sanctions and Anti-Money Laundering Act 2018, the Anti-Terrorism, Crime and Security Act 2001 (ACSA 2001) and the Export Control Order 2008, SI 2008/3231. It also identifies the equivalent EU sanctions regime, where applicable, and provides useful further reading resources for each UK regime. This Practice Note does not include details of the designations made under individual sanctions regimes. If an individual, organisation or other legal entity is designated under (ie is subject to) a particular UK sanctions regime (known as a designated person), their name will be recorded on the UK Sanctions List (UKSL). The UKSL helps businesses and individuals comply with their responsibilities under the various sanctions regimes. Regular screening of the UKSL should form part of an internal sanctions compliance programme. A sanctions regime is a collection of sanctions measures put in place for a particular set of purposes. Regimes can be either: • geographic—relating to a particular country or region, or • thematic—relating

Banking & Finance analysis: The Supreme Court held that regulation 28(3)(c) of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855 (the Regulations) prohibited a bank from making payments under standby letters of credit connected with aircraft leases to Russian airlines until appropriate licences were obtained, thereby suspending the bank’s payment obligations and preventing the accrual of interest. The court adopted a broad interpretation of ‘in connection with’, emphasising the primacy of sanctions policy over private contractual rights. It further confirmed, obiter, that section 44(2) of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) affords wide protection against civil liability where a party reasonably believes it is complying with sanctions. The decision provides important clarification for financial institutions navigating sanctions risk. Produced in partnership with Iain Sharp, partner and Reema Shour, professional support lawyer at Hill Dickinson.