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UK tax weekly update: case law (Mainpay, Hippodrome, SKAT), HMRC guidance, cryptoasset ETNs in pensions/ISAs, Pillar Two territories, Welsh Budget LTT changes, ATED/SDLT option – 16 October 2025

Published on: 16 October 2025

Published by a LexisNexis Tax expert
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Employment taxes

Court of Appeal dismisses ‘discontinuous contract of employment’ while confirming need for causal link to carelessness for extension of assessment timeframe (Mainpay Ltd v HMRC)

In Mainpay Ltd v HMRC [2025] EWCA Civ 1290, the Court of Appeal confirmed that extended assessment time limits apply where there is carelessness, and held that sporadic work under one contract is not continuous employment. HMRC was required to demonstrate a sufficient causal connection between taxpayer carelessness and the tax lost to justify using the longer time limits, and in this instance it satisfied that requirement. See News Analysis: Court of Appeal dismisses ‘discontinuous contract of employment’ while confirming need for causal link to carelessness for extension of assessment timeframe (Mainpay Ltd v HMRC).

HMRC publishes Employer Bulletin: October 2025

HMRC has issued the October 2025 edition of the Employer Bulletin...

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