Commercial property landlords have been in limbo for over five years as to whether and when the current MEES requirement of an EPC E rating would be increased.  Meanwhile, they learnt from the Warm Homes Plan that residential properties in the PRS must have an EPC C rating by October 2030.

The Upper Tribunal (Tax and Chancery Chamber) (UT) has dismissed Barclays' appeal against the decision of the First-tier Tribunal (Tax Chamber) (FTT) upholding HMRC's refusal to allow a US company, Barclays Services Corporation (BSC), a member of Barclays' corporate group, to join Barclay's UK value added tax (VAT) group. The main reason for refusing the application was that the US company's registered branch in the UK was not a 'fixed establishment'.

Since 6 April 2026, the UK has had a new regime under which all carried interest is taxed as trading income, regardless of the underlying nature of the return. As it is trading income, the starting position is that it is taxed at rates of up to 47% (45% income tax plus 2% national insurance contributions). However, provided the carried interest is "qualifying", a bespoke effective rate of around 34.1% applies.

A regular briefing for the alternative asset management industry. 

The US LLC is a popular business vehicle, particularly in the private capital sector. However, its current UK tax treatment can give rise to effective double taxation for members who are UK resident individuals.

Geopolitical pressures, technological disruption and shifting energy markets are reshaping what it means to transition to a more sustainable economy. This edition examines how three sectors, energy, defence and digital, are navigating the transition and reviews the regulatory and financial framework that will determine whether the transition succeeds.

The London Stock Exchange ("LSE") has just published a consultation paper, AIM Notice 62 (the "Consultation Paper"), setting out its reforms to the AIM Rules for Companies (the "AIM Rules").

The UK Government has announced that the implementation date for the UK's new subscription contracts regime has been pushed back to "Spring 2027". Whilst this gives businesses more time to prepare, there is a great deal to consider – and as we explain below, the sooner you start that process, the better.

In this edition, we look at infrastructure and energy measures in the King's Speech, how the UK is proposing to decouple gas and electricity prices, the latest state of play on data centres and the impact of conflict in the Middle East.  We also discuss whether pre-development costs should get preferential tax treatment and VAT on electric vehicle charging, together with a range of other regulatory issues affecting the infrastructure and energy sectors. 

HMRC has published the final version of its updated guidance on the application of the UK's investment manager exemption (IME). The IME is important because it helps prevent domestic managers constituting a UK taxable presence of their non-resident clients. As well as reflecting changes made to the legislation underpinning the IME, the final guidance contains important clarifications in relation to how HMRC will apply the exemption in practice.

The new Future Homes Standard (the "FHS") and Future Buildings Standard (the "FBS") published in late March 2026 represent, by any measure, an incredibly significant change to energy efficiency requirements for new homes and commercial buildings in England. The impact within the industry will be profound.

The UK government has announced it intends to make profits and losses attributable to a foreign permanent establishment (PE) of a UK resident company mandatorily exempt from UK tax.

A regular briefing for the alternative asset management industry 

The UK hosts a significant number of data centres, with concentrations in several key areas including London and the Home Counties (particularly Slough, which is home to one of Europe's largest data centre clusters), the London Docklands, Hayes, Uxbridge and Park Royal.

The EU AI Act is one of the most significant pieces of technology regulation to emerge in recent years and it is still taking shape. In May 2026 alone, the EU provisionally agreed material changes through the Digital Omnibus on AI (see our previous briefing on the "AI Omnibus"), postponing key compliance deadlines, and published draft guidance on high-risk system classification and transparency requirements.

Many businesses make loans as part of their employee incentive arrangements typically to fund the purchase of shares in the company by employees or the trustees of an employee benefit trust.  These loans are often on relatively "soft" terms which can give rise to corresponding benefit in kind tax charges where the recipient is an employee or director.  If the company making the loan is a "close" company for tax purposes and the recipient is a "participator" (which includes shareholders and those entitled to acquire shares) an additional tax charge can arise for the company.  Under proposals set out in a current government consultation, on top of these considerations, close companies will have to comply with additional reporting obligations in respect of transactions with participators to avoid penalties.

At the beginning of this year, the Government published draft legislation to reform leasehold and to mandate the use of the commonhold tenure for new flats, as explored in an earlier briefing.  It also asked the Housing, Communities and Local Government Committee to interrogate its proposals in order to suggest some improvements. The Committee published its report on 27 May 2026.  This proposes some changes to the leasehold reform provisions in the draft Commonhold and Leasehold Reform Bill, and also puts forward several recommendations about reinvigorating commonhold, which are discussed below:

Whatever the strategy, the judgement and experience of your investment team is the key to success. And, in launching the sovereign AI fund – a £500m venture capital fund – the UK government seems to have got that right.

This article was first published in the May 2026 issue of Butterworths Journal of International Banking and Financial Law.

By James Bell and Sarah Lauder