Administration (HMRC) meaning

FORTHCOMING CHANGE related to Making Tax Digital Under the government’s wider MTD programme, and subject to limited exceptions and deferrals, sole traders and landlords will need to provide quarterly digital updates to HMRC using compatible software. Phased entry depends on income: Above £50,000 from April 2026 Above £30,000 from April 2027 Above £20,000 from April 2028 At Budget 2025, the government confirmed legislation in Finance Bill 2026 to take effect from 1 April 2026, clarifying scope and introducing powers to regulate end‑of‑year returns. A consultation from 12 November 2020 to 5 March 2021 considered extending MTD to corporation tax—voluntary from 2024 and mandatory not before 2026—but this did not proceed. In its 21 July 2025 Transformation Roadmap, HMRC stated it will not introduce MTD for corporation tax. The 2020 ten‑year roadmap for digitalising tax administration provides further background. MTD for VAT has applied to all VAT‑registered businesses since April 2022, affecting how records are kept and returns submitted,...

HMRC may issue a revenue determination in relation to direct taxes when a taxpayer fails to submit a return in response to a notice requiring a return to be filed. Unless the determination was raised by HMRC in error, receiving one indicates a significant lapse in attending to tax affairs and compliance obligations. It should be addressed promptly as a matter of priority, and a taxpayer may wish to instruct an adviser to provide assistance. For detailed guidance on the consequences of a revenue determination for direct taxes and the options available to displace it, see Practice Note: What is a revenue determination for direct tax purposes? This Checklist sets out key practical considerations and the procedural steps to take once a taxpayer has been issued with a revenue determination by HMRC. Determinations concerning stamp duty land tax (SDLT) fall outside the scope of this Checklist. In contrast to revenue determinations relating to direct tax—where there is no right of appeal—there is a limited right of appeal against SDLT...

In this issue: Budgets and Finance Bills Companies and corporation tax Brexit and tax Real estate tax Individuals and income tax Stamp and transfer taxes VAT Daily and weekly news alerts New and updated content Dates for your diary Trackers New Q&As Useful information Budgets and Finance Bills King’s Speech 2024 His Majesty the King outlined the government’s priorities, agenda and intended measures for the forthcoming parliamentary session during the State Opening of Parliament on 17 July 2024. Initial reactions from the Private Client community to the announcements have been collated. See: LNB News 17/07/2024 92. CIOT letter to the new Exchequer Secretary to the Treasury The CIOT has written to the incoming Exchequer Secretary to the Treasury, James Murray MP, setting out tax matters for the new administration. See: LNB News 17/07/2024 22. Companies and corporation tax Supreme Court finds advisers’ fees were capital in...

In this issue: Companies and corporation tax Stamp taxes VAT Individuals and income tax Taxes management and litigation Employment taxes Budget and Finance Bills Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax Court of Appeal decides interest on intra-group loans not restricted under transfer pricing rules but debits disallowed under unallowable purpose rule (BlackRock Holdco 5, LLC v HMRC) BlackRock Holdco 5, LLC v HMRC [2024] EWCA Civ 330 considers whether, for UK tax purposes, interest on intra‑group borrowing put in place to help fund a commercial acquisition is deductible. Two principal points were before the Court of Appeal: the transfer pricing analysis and the loan relationships unallowable purpose question. On the transfer pricing limb, the Court of Appeal allowed the taxpayer’s appeal. As a result, deductions for interest on the intra‑group loans were not curtailed by the transfer...

In this issue: Budgets and Finance Bills UK taxes for Private Client HMRC Manuals updates Tax avoidance, evasion and non-compliance Family businesses and ownership structures Contentious trusts and estates Pensions, insurance and tax efficient investments International Question of the week Daily and weekly news alerts LexTalk®Private Client: a Lexis+® community New and updated content Trackers Latest Q&As Useful information Budgets and Finance Bills Finance Bill 2026 published Finance (No 2) Bill 2024–26 was released on 4 December 2025 with explanatory notes. Also known as Finance Bill 2026 (FB 2026), it was presented in the House of Commons and received its first reading on 2 December 2025. For insights into the principal Private Client measures in FB 2026, see News Analysis: Private Client—publication of Finance Bill 2026. For commentary on the key Tax provisions, see News Analysis: Tax—publication of Finance Bill 2026. For comprehensive tracking of FB 2026—covering a...

This Practice Note compiles material on fiscal events across the 2025–26 tax year, beginning with the Spring Statement 2025 on 26 March 2025. For further detail on the Budget and Finance Bill procedures, as well as the broader fiscal timetable, see Practice Note: The Budget and Finance Bill process. Spring Statement 2025 On 26 March 2025, the Chancellor of the Exchequer, Rachel Reeves, delivered the Spring Statement 2025 to Parliament. The government outlined consultations and policy papers on substantive and administrative tax measures and other prospective developments. For more on the announcements, see News Analyses: Video analysis—Spring Statement 2025: Private Client perspective Spring Statement 2025—Tax analysis Tax update spring 2025: simplification, administration and reform On 28 April 2025, the Exchequer Secretary to the Treasury, James Murray, issued a written ministerial statement setting out a package of measures to simplify and reform the tax system and improve tax administration. HMRC and HM Treasury released a complementary set of documents comprising a...

Deal Debrief The Great Annual Savings Company Ltd sought approval for a Part 26A restructuring plan (RP), reaching a convening hearing in February 2023 and progressing to a sanction hearing in April 2023. Sanction was declined owing to significant objections from HMRC and other creditor groups. Core terms for this SME RP are set out below (all capitalised expressions not otherwise explained take the meanings given in the convening and sanction judgments). This Deal Debrief sits within our Restructuring plans collection. For a detailed review of metrics from RPs filed in 2023 and insights from restructuring practitioners, consult Practice Note: Market Insights Trend Report—trends in Part 26A restructuring plans in 2023 [Archived]...

This note sets out how a Limited Liability Partnership (LLP) may enter creditors’ voluntary liquidation (CVL), describes the scope of the liquidator’s authority, and explains the duties of the members. It does not extend to Limited Partnerships; for guidance on those, see Practice Note: Limited partnerships and insolvency—key principles. Applicable legislation The Limited Liability Partnerships Act 2000 (LLPA 2000) introduced LLPs and should be read together with the Limited Liability Partnerships Regulations 2001 (LLPR 2001), SI 2001/1090. Under the LLPR 2001, the Insolvency Act 1986 (IA 1986) and the Insolvency (England and Wales) Rules 2016 (IR 2016), SI 2016/1024, are applied to LLPs. The IA 1986 applies solely to LLPs registered in Great Britain...

FORTHCOMING CHANGE: The government has set out its proposals to apply inheritance tax to unspent pension pots on death, effective from 6 April 2027. For further details, please see News Analysis: HMRC confirms new IHT rules on unused pension funds to apply from 6 April 2027...

FORTHCOMING CHANGE: The government intends to levy inheritance tax on unspent pension pots upon death, effective from 6 April 2027. For further details, please see the News Analysis item: HMRC confirms new IHT rules on unused pension funds to apply from 6 April 2027...

Rules of the [ insert name of company granting EMI options ] enterprise management incentives Scheme FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, it was confirmed that from 6 April 2026 a number of EMI limits will be uplifted: The gross assets threshold will rise from £30 million to £120 million. The cap on full-time equivalent employees will increase from 250 to 500. The overall limit on the value of unexercised EMI options that a company or group can have at any time will go from £3 million to £6 million. The permitted exercise period will also extend from 10 to 15 years. Existing EMI options can be varied to adopt this longer exercise window without forfeiting tax advantages, so long as the changes comply with legislation to be included in Finance Bill 2025-26. In addition, from April 2027 the requirement to notify HMRC of EMI option grants for them to qualify will be abolished, with this measure to...