Hello,
This week brings a run of interesting decisions from the tribunals, with an overdrawn director’s loan account, corporate residence, and the Disclosure of Tax Avoidance Scheme (DOTAS) rules being examined in our case summaries.
SME Tax News
HMRC have issued a press release confirming that 436,000 taxpayers have filed their first quarterly tax update under Making Tax Digital (MTD) for Income Tax, reminding those who have not yet submitted their returns to do so now.
HMRC have introduced a new online service which allows taxpayers and their appointed agents to upload documents to HMRC electronically as part of a compliance check.
In Property 118 Ltd & Anor v HMRC [2026] TC09971, the First Tier Tribunal (FTT) cancelled Disclosure of Tax Avoidance Scheme (DOTAS) reference numbers issued by HMRC for two property incorporation schemes. They were not notifiable arrangements as their main purpose was not to obtain a tax advantage.
In HMRC v Gary Quillan [2026] UKUT00300, the Upper Tribunal (UT) confirmed that for the purposes of s.415 ITTOIA 2005, an overdrawn director's loan account can be treated as 'written off' during the liquidation process without the need for a formal release or express write-off. 
HMRC have released Employment-Related Securities (ERS) Bulletin 68, which focuses on changes to ERS net settlement reporting requirements, Save As You Earn (SAYE) guidance and Enterprise Management Incentives (EMI).
An independent report has been published by the University of London, 'Tax complexity: impact on UK competitiveness and growth'. It revisits the Office of Tax Simplification (OTS) 2014 review of the competitiveness of the UK’s tax administration, seeking to assess progress made since that date.
In Cogefin (Bermuda) Limited & Anor v HMRC [2026] TC09969, the First Tier Tribunal (FTT) found that a Bermudian incorporated company owned by a trust was UK tax resident. Central management and control was exercised by a UK resident beneficiary despite the company directors all being resident in Bermuda.
Hello,
One of this week's major announcements is confirmation that, on 28 October, the Chancellor will present the 2026 Budget. When John Healey rises to deliver his first Budget speech since taking office, just a few months into Andy Burnham's time as Prime Minister, it will be a significant moment for UK fiscal policy, as the new leadership team sets out its economic priorities in full.
In Lexgreen Services Limited v HMRC [2026] UKUT 00289, the Upper Tribunal (UT) upheld the decision of the First Tier Tribunal (FTT) finding that a company had a ‘life’ for Inheritance Tax (IHT) purposes. This meant that a corporate settlor was liable to IHT arising on a non-resident trust’s ten-year anniversary.
