Energy analysis: At the UK-EU summit on 19 May 2025, the UK government entered into the UK-EU Common Understanding which made particular provision in relation to energy matters. Part 4 of the Common Understanding is entitled ‘strengthening our economies while protecting our planet and its resources’ which covered three areas relating to energy: (1) energy co-operation, specifically participation in the EU internal electricity market; (2) technical regulatory engagement on new technologies, and, (3) linking the UK and EU emissions trading schemes (ETS). The Common Understanding does not fix the future legislative and regulatory framework, but it does set out the conclusions of exploratory talks on future co-operation, and provides a roadmap for the areas for future negotiation. Written by Richard Turney KC, barrister at Landmark Chambers.

The Specialised Committee on Intellectual Property under the EU-UK Trade and Cooperation Agreement has published the minutes from its fourth meeting, held on 13 November 2024. This joint UK-EU forum oversees the implementation of the Intellectual Property title (Title V) of the Trade and Cooperation Agreement. The committee serves to monitor and review the title's implementation, ensure its proper functioning, and facilitate technical discussions and information exchange between the parties. This latest update provides insight into the ongoing collaborative efforts between the UK and EU in managing intellectual property matters post-Brexit.

Information Law analysis: The EU-UK Trade and Cooperation Agreement (TCA) includes a chapter on data flows and personal data protection, providing good news for data protection practitioners preparing for the end of the Brexit transition period at 11 pm on 31 December 2020 (IP completion day). Eleonor Duhs, director and barrister at Fieldfisher discusses the implications of this deal and the next steps regarding data adequacy.

Tax domicile (domicile fiscal) Individuals are subject to French tax on a worldwide basis where their domicile fiscal is situated in France. Domicile is to be considered here in the civil law sense of the term and generally corresponds to the individual's habitual residence. Tax household (Foyer fiscal) The Foyer fiscal (tax household) includes spouses/civil partners and their dependent children and will be taxed as a unit unless the individuals live separately. Statutory domicile test Article 4 B of the Code général des impôts (CGI) contains a statutory domicile test. Individuals are regarded as having their domicile in France for tax purposes wherever: • their foyer (family home) or their lieu de séjour principal (principal abode) is situated in France • they exercise a professional activity in France (employed or self-employed, unless they can justify the ancillary character of said activity) • the centre of their economic interest is situated in France The notion of foyer enables taxing individuals working abroad while their family lives in France. The lieu de séjour principal focusses

The government has announced that it has reached an agreement with Mauritius in relation to the British Indian Ocean Territory and the UK-US military base on Diego Garcia. The UK will agree that Mauritius is sovereign over the Chagos Archipelago, including Diego Garcia. For an initial period of 99 years, the UK will be authorised to exercise the sovereign rights and authorities of Mauritius required to ensure the continued operation of the base. The deal has the support of the United States. The agreement comes after years of negotiation. The government says that, as a result of this agreement, the base at Diego Garcia will be undisputed and legally secure. The agreement is subject to a treaty being finalized, and both parties have committed to expedite the process.

The Home Office has announced the ratification of the UK-Rwanda Treaty, and that the Safety of Rwanda (Asylum and Immigration) Bill has received Royal Assent (making it the Safety of Rwanda (Asylum and Immigration) Act 2024). These measures have been taken to address the Supreme Court's findings in relation to the Rwanda plan, such as the risk of refoulement. The Home Office has also published a statutory statement on the agreement between the UK and Rwanda in line with section 20(8) of the Constitutional Reform and Governance Act 2010, which allows a minister of the Crown to ratify a treaty despite the House of Lords resolving not to do so.

HM Treasury (HMT) and the Monetary Authority of Singapore have issued a joint statement following their ninth Financial Dialogue meeting. Attendees discussed collaboration opportunities in priority areas such as sustainable finance and fintech and innovation, and exchanged views on recent developments in non-bank financial intermediation (NBFI) as well as efforts to improve cross-border payment connectivity.

ARCHIVED: This Practice Note has been archived and is not maintained. On 6 October 2011, the governments of Switzerland and the UK signed an agreement to co-operate on tax matters entitled the UK-Swiss Confederation Taxation Cooperation Agreement (the 'Agreement'). The Agreement is not a disclosure facility but it did give UK taxpayers an opportunity to bring their tax affairs up to date if they had not declared to HMRC income and gains arising on accounts in Switzerland. The agreement only covers assets held in Switzerland. The Agreement provides for: • an anonymous one-off payment, in lieu of historic liabilities to income tax, capital gains tax, inheritance tax and VAT to be applied to relevant assets held in Switzerland by or for relevant persons (unless the taxpayer decides to give up their anonymity and authorise disclosure of those assets) • a withholding tax to be applied to income and gains arising on relevant assets from 1 January 2013 (again, unless the taxpayer chooses to give up their anonymity and authorise disclosure instead); and • enhanced

This tracker covers the development of the UK Extension to the EU-US Data Privacy Framework (also known as the UK-US Data Bridge) following the invalidation of the Safe Harbor and Privacy Shield frameworks. The UK-US Data Bridge facilitates international transfers of personal data to the US by way of an adequacy regulation (the Data Protection (Adequacy) (United States of America) Regulations 2023, SI 2023/1028) where such transfers would otherwise be prohibited by the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR). The UK-US Data Bridge builds upon a separate adequacy decision which applies under the EU’s General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR) and which was adopted by the European Commission in July 2023, implementing the EU-US Data Privacy Framework. For further information on this separate adequacy decision which applies under the EU GDPR, see Practice Note: EU-US Data Privacy Framework (DPF)—tracker. For more general information about the UK GDPR, see Practice Note: The UK General Data Protection Regulation (UK GDPR). For more information on the concept of assimilated law,

UK practitioners will come across situations whereby complex US and UK tax issues arise for estates of decedents who were domiciled in the UK at death and estates subject to US estate tax through citizenship or domicile status. Complications also exist with estates of decedents who have property situated in the US or the UK at the time of death. From 6 April 2025, UK inheritance tax (IHT) will apply based on a new long-term residency concept rather than on domicile or deemed domicile status. Under this rule, an individual who has been UK resident for 10 out of the previous 20 tax years will be treated as a long-term UK resident (LTR) and subject to IHT on worldwide assets — see Practice Notes: A new residence-based regime for IHT from 2025–26 and New IHT regime from 6 April 2025—FAQs. Prior to this change, domicile (or deemed domicile) determined IHT exposure — see Practice Notes: Deemed domicile for tax before 6 April 2017 [Archived] and Deemed domicile for tax from 6 April 2017 to 5 April 2025 [Archived].

The government announced that the UK and US have agreed a new pharmaceutical deal that establishes a preferential tariff framework for medicinal products, making the UK the only country to secure a 0% tariff on pharmaceutical exports to the US. Under the terms of the agreement, this preferential 0% tariff rate will apply for at least three years. The deal will also secure preferential terms for the UK’s medtech exports, meaning no additional new tariffs on medtech, which the government states is intended to unlock further investment and support additional growth. The Department of Health and Social Care (DHSC) has stated that the UK-US pharmaceuticals deal will help secure access to medicines for NHS patients and accelerate the arrival of new therapies. The government also intends to raise the thresholds used by NICE (from £20,000–£30,000 to £25,000–£35,000 per quality-adjusted life year (QALY)), aligning with commitments linked to the deal.

HM Treasury (HMT) has announced that together with the US Treasury, it has established the Transatlantic Taskforce for Markets of the Future.  The Taskforce aims to enhance collaboration on capital markets and digital assets and other innovative financial activities, particularly whilst legislation and regulatory frameworks are still developing.