Market Intelligence

Since 1 September 2025, a large organisation is criminally liable under section 199 ECCTA 2023 where an associated person commits a fraud intended to benefit it. The only defence is reasonable fraud prevention procedures. For a UK-UAE-Ireland corridor group, the UK nexus reaches conduct abroad.

From 1 January 2026, UK reporting cryptoasset service providers must run due diligence on every user under the Cryptoasset Reporting Framework. The first report is due by 31 May 2027. For a family office holding crypto through trusts, FICs, or holding companies, the look-through to controlling persons is the exposure.

From 6 April 2027, most unused pension funds and death benefits fall within the IHT estate under Finance Act 2026. For a UAE-resident former UK resident, scheme situs is decisive: a UK-established pension stays in the IHT net even after long-term resident status lapses.

The UK Senior Accounting Officer regime under Schedule 46 Finance Act 2009 applies to UK-incorporated companies whose turnover exceeds £200 million or whose balance sheet exceeds £2 billion, aggregated across the UK 51% group. The duty is not a certificate. It is the architecture of tax accounting controls.

The UAE Domestic Minimum Top-up Tax under Cabinet Decision No. 142 of 2024 applies to financial years starting on or after 1 January 2025. First filings are due within 15 months of fiscal year-end, extended to 18 months for the transitional year. For a calendar-year MNE group, the first return is due 30 June 2027.

Ireland completed its territorial corporate tax framework on 1 January 2025 with the dividend participation exemption under section 831B TCA 1997 alongside the capital gains exemption under section 626B. Combined with the Ireland-UAE DTA 2010 and the 12.5% trading rate, Ireland is now a third corridor leg.

On 10 May 2026 the UAE Ministry of Finance moved the Phase 1 ASP appointment deadline from 31 July 2026 to 30 October 2026 by amending Ministerial Decision No. 244 of 2025. The 1 January 2027 go-live did not move. For AED 50 million+ entities the runway between ASP appointment and live filing is now nine weeks.

The UAE Domestic Minimum Top-up Tax under Cabinet Decision No. 142 of 2024 is not a separate tax. It is a recomputation of every other UAE tax outcome against a 15% floor for in-scope MNE groups (consolidated revenue EUR 750m or more in two of the preceding four fiscal years), effective 1 January 2025.