UK Law and Practice Contributed by: Paolo Palmigiano, Rachael Roberts, Helen Farr, Debbie Heywood and Louise Popple, Taylor Wessing LLP
5.7 Anti-Evasion Rules The UK has numerous anti-avoidance rules, many of which operate to disregard or re-char - acterise arrangements whose main purpose, or one of whose main purposes, is the obtain - ing of a tax advantage. Since 2013, the UK has also had a general anti-abuse rule, which can counteract arrangements giving rise to a tax advantage where they are “abusive” – defined as arrangements that cannot reasonably be regarded as a reasonable course of action in relation to the relevant legislative provisions. The courts have also established that legisla - tion must be read purposively and applied to the facts as viewed realistically – principles that have frequently been applied to counteract perceived Since the end of the Brexit transition period on 31 December 2020, the tariff regime in the UK has been governed by the UK Global Tariff (UKGT). The UKGT applies to all countries and all goods imported into the UK, unless the UK has a free trade agreement (FTA) with the country of origin or an exception applies (eg, the goods are imported from certain developing countries). Broadly, the tariff rates under the UKGT follow the EU tariffs, with some exceptions for goods where the UK has no domestic production. Examples of notable FTAs include: • The Trade and Cooperation Agreement with the EU – this came into force on 1 May 2021 and removed tariffs from goods traded between the UK and the EU, provided that traders had “self-certified” their compliance with agreed rules of origin (ie, that the goods have originated in either the UK or the EU according to specific criteria). avoidance. 5.8 Tariffs
• The Comprehensive and Progressive Agree - ment for Trans-Pacific Partnership – an FTA between the UK and nine countries in the Asia-Pacific region that allows for tariff elimi - nation and reduction on key sectors, such as food and agricultural products and goods in digital trade. Some goods are covered by a tariff-rate quota (TRQ). A TRQ allows a limited amount of a prod - uct to be imported at a lower or zero tariff rate, subject to certain qualifying criteria. TRQs pri - marily cover agricultural and fishery products, as well as processed foods and industrial goods. Following the invasion of Ukraine, the UK has removed Russia’s Most Favoured Nation sta - tus, effectively imposing significantly higher tar - iffs on Russian goods. Additional duties of 35% are currently imposed on a wide range of goods originating from Russia and Belarus, above any existing tariff rates. On 24 April 2025, the UK introduced new restric - tions such as a complete prohibition on the importation of Russian diamonds and prohibi - tions on the export to Russia of energy-relat - ed goods and security technology. In previous years, various other sanctions had been imple - mented to introduce restrictions on trade for goods such as oil, gold, iron and steel products, which continue to be in force. The recent trade deal with the USA has also led to various tariff adjustments. Under the deal, the USA will continue to impose a new 10% tariff on imports for most British goods but higher tariffs on the imports of British cars, steel and aluminium will be reduced.
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