On 23 June 2026, HMRC published a consultation titled Modernising the taxation of distributions and repayments of capital from companies.

The consultation proposes fundamental reform to the rules governing how payments from companies to their shareholders are taxed. Although the primary focus is on individual shareholders and trusts, the consultation will also impact corporates. It has the potential to be one of the more consequential consultations on UK tax law in decades.

In this episode of our Tax Focus podcast, the second in a mini-series, Maddy Gowlett and Hannah Manning  discuss the proposals to reform demergers and the loans to participators regime.

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On 23 June 2026, HMRC published a consultation titled Modernising the taxation of distributions and repayments of capital from companies.

The consultation proposes fundamental reform to the rules governing how payments from companies to their shareholders are taxed. Although the primary focus is on individual shareholders and trusts, the consultation will also impact corporates. It has the potential to be one of the more consequential consultations on UK tax law in decades.

In this episode of our Tax Focus podcast, the first of a mini-series, Maddy Gowlett and Hannah Manning  discuss the background to the consultation, the principles involved, and some of the possible practical implications.

During 2025, HMRC paused their concessionary treatment for administrative errors relating to withholding tax on cross-border interest payments. The concession is paused while HMRC review the UK's procedures for claiming relief under a double tax treaty.

In this podcast, we discuss the background, the principles involved, and the practical implications of HMRC's decision to pause the concession and conduct the review.

For more, see our Briefing: Withholding the withholding tax concession HMRC pauses concession for errors when withholding tax on interest | Travers Smith