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Deemed registration meaning

What does Deemed registration mean?
Deemed registration describes the automatic treatment, on 6 April 2006 (A‑Day), of pension schemes that were Inland Revenue “approved schemes” as HMRC-registered pension schemes, without any fresh application by the trustees or scheme administrator. The expression is a practitioner term used in HMRC guidance and practice, reflecting transitional provisions introduced by the Finance Act 2004 as part of pensions tax simplification. Key features and effects: - Continuity of tax status: members’ tax reliefs and authorised payment rules applied from A‑Day without interruption. - Administrative shift: the scheme acquired a registered status and scheme administrator obligations under the registered pension scheme regime (for example, event reporting, information returns and compliance with authorised payments rules), with potential deregistration or tax charges for non-compliance thereafter. - Scope: it applied to schemes that held “approved” status immediately before A‑Day; new schemes after A‑Day required formal HMRC registration. Usage is consistent across England & Wales, Scotland and Northern Ireland, as UK pensions tax is reserved to the UK Parliament. The concept does not have a direct equivalent in Ireland, where Revenue approval and Pensions Authority oversight operate under separate Irish legislation and procedures.
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NEWS
Autumn Budget 2024: UK Private Client Tax—CGT increases; APR/BPR capped at £1m; pensions within IHT; remittance basis abolished; higher SDLT surcharge; VAT on private schools; carried interest reform

The Chancellor of the Exchequer, Rachel Reeves, delivered the government’s Autumn Budget on 30 October 2024 Keenly awaited and watched, this was the first Budget from a Labour administration in fourteen years, and the first ever presented by a woman Chancellor. Many headline measures for Private Clients had been trailed in one form or another, and several of the changes—such as the Capital Gains Tax reforms—were not as draconian as many had feared, proving less severe than anticipated. It was definitely a Labour Budget, unmistakably Labour in flavour, with the Chancellor honouring election pledges not to raise income tax or National Insurance for ‘working people’, and instead securing the £40bn of tax rises by lifting employers’ National Insurance, narrowing the scope of IHT agricultural and business property reliefs, increasing CGT rates, reforming the taxation of carried interest, changing the rules for non‑UK domiciled individuals, bringing inherited pensions into the IHT net, confirming VAT on private school fees, increasing the SDLT surcharge for second homes, and even a hike in...

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NEWS
FTT (Tax): Exempt care supplies do not disapply UK VAT reverse charge on overseas staff; deemed supplies under VATA 1994 s 8; registration liability; no reasonable excuse

Genuine Care Homecare Services Ltd v HMRC [2026] UKFTT 235 (TC) It was common ground that the appellant was a UK state‑regulated provider of domiciliary care services exempt from VAT (see Item 9, Group 7, Schedule 9 to the Value Added Tax Act 1994 (VATA 1994) and VAT Notice 701/2). It was likewise accepted that the appellant had told HMRC of its obligation to register for VAT regarding its actual taxable consultancy and training supplies in the care sector, made in the ordinary course of business. The key questions were whether it had made deemed taxable supplies under VATA 1994, s 8, and whether its late appreciation of the implications of making those supplies amounted to a reasonable excuse for failing to notify HMRC in time of its duty to register for VAT...

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NEWS
UK Private Client weekly update: probate and LPA fee rises, ECCTA ID verification rollout, HMRC manuals (CARF), SDLT adviser warning, contentious estates rulings, and Welsh tax reforms—6 November 2025

In this issue: Probate UK taxation for private clients Budget and Finance Bill developments HMRC Manual updates Tax avoidance, evasion and non-compliance Private client regulatory compliance Charity and philanthropy Disputed trusts and estates Pensions, insurance and tax-efficient investments Scotland, Wales and Northern Ireland Question of the week Daily and weekly alerts LexTalk® Private Client: a Lexis+® community Fresh and revised content Dates for your diary Trackers Latest Q&As Useful information Probate Court and Public Guardian Fees (Miscellaneous Amendments) Order 2025 SI 2025/1126: This Order raises the fees for applications to register Lasting Powers of Attorney (LPA) and Enduring Powers of Attorney (EPA), together with the reduced charge for repeat LPA registration at the Office of the Public Guardian (OPG), and also the fees for obtaining copies of probate grants. The increases are intended to align the charges more closely with their estimated cost. It comes into...

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PRACTICE NOTES
Conservation covenants in England: creation, responsible bodies, obligations, enforcement, modification and discharge, and registration under the Environment Act 2021

What are conservation covenants? In essence, conservation covenants are voluntary, private undertakings between a landholder and a responsible organisation or body, for example a conservation charity or a public authority. Their purpose is to safeguard the natural environment and heritage assets for the benefit of the public at large. They stipulate duties tied to the land itself and bind present and future owners, offering the prospect of enduring conservation outcomes and benefits. A common illustration is a farmer committing to manage a woodland and permit public access, with oversight by a local woodland charity or similar body. They are viewed as complementing statutory or policy-led designations—such as Sites of Special Scientific Interest or National Parks—by enabling the private protection of land with conservation merit that sits outside the public designation regime. Part 7 of the Environment Act 2021 (EA 2021) addresses conservation covenants directly. The Department for Environment, Food & Rural Affairs (Defra) has issued guidance on obtaining and using a conservation covenant agreement (the Defra Guidance). Conservation...

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PRACTICE NOTES
Comprehensive property law Q&As for practitioners: Building Safety Act, conveyancing, land registration, leases, trusts of land, easements, restrictive covenants, adverse possession, enfranchisement—England and Wales

This Practice Note provides links to Q&As covering many of the most common property enquiries. The answers are not updated and therefore reflect the law as at the date they were issued. For the latest guidance and additional detail, follow the links in each answer. Building Safety Act 2022 For practical guidance on the Building Safety Act 2022, see: Building Safety Act 2022 property and property disputes collection. Under the Building Safety Act 2022 (BSA 2022), leases completed before 14 February 2022 are qualifying leases (subject to all other criteria), so a leaseholder/landlord certificate is required. For relevant buildings constructed or converted after 1 October 2023, the new Building Regulations apply; a final BR certificate would evidence compliance with the BSA 2022. What documents should a buyer expect in relation to the BSA 2022 where a developer acquired a building after 14 February 2022 and converted it to residential use before 1 October 2023? How do the conditions for a ‘qualifying lease’...

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PRACTICE NOTES
US Regulation S explained for UK capital markets lawyers: safe harbours, offshore transactions, directed selling efforts, resale rules and LSE settlement practice

This Practice Note offers a concise overview of the principal features of Regulation S and the practical considerations of relying on Regulation S for English and other non‑US lawyers; it is not intended as an exhaustive discussion of Regulation S. Background and scope of Regulation S Adopted in 1990, Regulation S was introduced to clarify the extraterritorial reach of the registration and prospectus delivery obligations under the US Securities Act of 1933, as amended (the Securities Act). The rule rests on a straightforward principle: any offer or sale of securities conducted within the United States of America (United States) is potentially subject to the registration and prospectus delivery requirements of Section 5 of the Securities Act (Section 5), while any offer or sale made outside the United States is not. Putting that premise into practice for international offerings is more complex. Regulation S sets out two non‑exclusive safe harbours for particular transactions: one primarily for issuers and distributors of securities, and another for resales of...

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PRECEDENTS
Precedent sale contract for freehold property subject to occupational leases: arrears, rent reviews, service charges, rent deposits, TOGC/VAT, TUPE, capital allowances, overseas entities, environmental liability (England and Wales)

date [ date ] Parties [ name of Seller ] [ of OR incorporated in England and Wales (company registration number [ number ]) with registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] ( Seller ) [ name of Buyer ] [ of OR incorporated in England and Wales (company registration number [ number ]) with registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] ( Buyer ) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] ( Guarantor ) ] 1 Definitions In this Agreement, the terms set out below shall have the meanings given: ...

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PRECEDENTS
Precedent sale contract for leasehold reversion subject to occupational leases, incorporating Standard Commercial Property Conditions, covering arrears, rent deposits, TUPE, VAT and consent to assign — England and Wales

Date [ date ] Parties [ name of Seller ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Seller) [ name of Buyer ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Buyer) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Guarantor) ] 1 Definitions In this Agreement, the terms set out below shall have the following meanings: Actual Completion...

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PRECEDENTS
Precedent: Agreement for Sale and Purchase of Property Portfolio (England and Wales): occupational leases, TOGC/VAT, arrears, rent reviews, capital allowances, TUPE, environmental liabilities, overseas entities, completion and apportionments

date [ date ] Parties [ name of Seller ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Seller) [ name of Buyer ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Buyer) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] [ and whose address for service in England and Wales is [ address ] ] (Guarantor) ] 1 Definitions For the purposes of this Agreement, the terms below carry these meanings: Actual Completion Date –...

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