Hello,
This week, we bring news of HMRC examining loans to participators where tax may not have been properly accounted for, the November 2025 Employment-Related Securities (ERS) Bulletin, and an important Upper Tribunal (UT) decision in the context of employee incentivisation arrangements.
The National Audit Office (NAO) has published its departmental overview, 'HM Revenue & Customs 2024-25'. While there are signs of performance improvement, the Comptroller and Auditor General (C&AG) once again issued a qualified audit opinion on HMRC’s accounts due to material levels of error and fraud in Child Benefit, Corporation Tax research and development reliefs, and personal tax credits expenditure.
HMRC have identified companies that may have underpaid s.455 tax in respect of loans made to participators. The agents of affected companies are being contacted by email, asking them to check whether relief has been correctly claimed in Corporation Tax returns that were filed before April 2025.
HMRC have released the November 2025 edition of the Employment-Related Securities (ERS) Bulletin. It contains some useful information and important reminders around the ERS reporting process. Here is our enhanced version.
In Michael Saunders v HMRC [2025] UKUT 00374, the Upper Tribunal (UT) found that a payment made to an individual under their employer's Long-Term Incentive Plan after becoming non-UK resident was taxable as employment income. The payment was earned during his UK-based employment and was not attributable to the overseas part of the split tax year.
Hello,
On 4 November, the Chancellor gave an unprecedented pre-Budget ‘Scene Setter’ speech. This felt somewhat like the typical preamble we are accustomed to on Budget Day itself, immediately before announcements are made.
The Administrative Burdens Advisory Board (ABAB) has released its 'Tell ABAB report 2024 to 2025'. This demonstrates increasing levels of awareness around Making Tax Digital (MTD) for Income Tax, poor channels of communication with HMRC and a slight improvement in 'customer experience'.
Missed our SME Tax Updates in October? Here is a summary of the month.
The Welsh Revenue Authority has launched a consultation on legislative proposals relating to the Welsh Tax Acts. Views are being sought on proposals aimed at clarifying the application of tax in specific areas.
With the introduction of Making Tax Digital (MTD) for Income Tax (IT) less than six months away, HMRC have begun writing to taxpayers who will be mandated into the regime from 6 April 2026.
