Authors: Clare Bouwer, Sahana Keshav

UK Tax Alert - Sovereign Immunity Consultation

On 4 July 2022, the UK government launched a consultation which proposes to codify and formalise the concept of sovereign immunity from taxation in UK law. More fundamentally, it also proposes significantly limiting the scope of the sovereign immunity exemption to an exemption on UK source interest income that is not derived from trading activities. This would mean that sovereign investors’ income and gains from UK real estate and UK trading activities would be brought within the scope of UK tax. If implemented, the changes would take effect from April 2024 onwards.