Hello,
This week we cover a variety of topics including an increase in HMRC’s late payment interest rates and the launch of the Personal Tax Query Resolution Service for Agents. We also have more toolkits and guides to help navigate the 2025-26 tax year.
April is a significant month for the Annual Tax on Enveloped Dwellings (ATED) regime; returns for the 2025-26 chargeable period are due by the end of the month for relevant property interests held on 1 April.
HMRC recently published statistics showing that while the number of liable ATED declarations only increased by 10 in the 2023-24 financial year, to 5,170, a total of 28,510 relief declarations were made in the same period. This was an increase of 11% compared to 2022-23.
This is a timely reminder to ensure that any UK residential properties held by non-natural persons potentially within the ATED regime are identified, and returns submitted by the deadline, claiming any appropriate relief.
Continuing with a property theme, we have published our Land & Property Adviser’s Tax Update for 2025-26 and our latest Property Profits and Losses Toolkit.
As we move into the 2025-26 tax year, the concept of ‘domicile’ will become far less important from a tax perspective. This does not mean, however, that disputes over historic domicile status will immediately disappear. In that vein, we cover a decision of the First Tier Tribunal which examined an individual’s domicile of origin and whether that was subsequently displaced by a domicile of choice.
More news, cases and updates are below, including HMRC’s latest Employment-Related Securities Bulletin.
The Ross Martin Tax Team
Your Virtual Tax Partner®: online PRACTICAL support for accountants, tax advisers BY accountants and tax advisers.
Quick News
Personal Tax Query Resolution Service for Agents goes live
HMRC's Personal Tax Query Resolution Service for Agents is now live. It is intended to provide an escalation route for Self Assessment and PAYE queries for individuals that HMRC’s Agent Dedicated Line or Agent Webchat have not resolved.
HMRC's late payment interest rate increases
From 6 April 2025, HMRC's interest rate charged on the late payment of tax will increase by 1.5%. This follows an announcement made at Autumn Budget 2024.
Anti-money laundering supervision report 2023-24
HM Treasury has published their ‘Anti-money laundering and counter-terrorist financing supervision report 2023-24’ which details supervisory and enforcement data for 2023-24, including the number and value of fines issued.
Employment-Related Securities (ERS) What's new? March 2025
HMRC have released the March 2025 edition of the Employment-Related Securities (ERS) Bulletin. It contains some useful information and provides a reminder about this year's filing deadline. Here is our enhanced version.
Spotlight 68: Prepaid cards used for profit extraction
HMRC have published Tax Avoidance Spotlight 68 'Using prepaid debit cards for profit extraction to reduce profits and disguise income', highlighting a scheme that uses purported advertising and marketing expenditure to reduce profitability and disguise income through redeemable loyalty points.
Tax Cases
UK-born Rabbi deemed UK domiciled
In Aubrey Weis v HMRC [2025] TC09463, the First Tier Tribunal (FTT) found that a UK-born Rabbi, who resided in the UK for the majority of his life, raised a family in the UK and developed a business in the UK, was UK-domiciled for tax purposes.
Property being converted was residential for SDLT
In Bemal Patel v HMRC [2025] TC09467, the First Tier Tribunal (FTT) found that a property undergoing conversion work at the date of completion was residential for Stamp Duty Land Tax (SDLT) purposes.
Editor's Choice
Annual Tax on Enveloped Dwellings (ATED)
What is the Annual Tax on Enveloped Dwellings (ATED)? Who does ATED apply to? What relief is available and how is it claimed? What are the ATED return filing dates?
Purchase (repurchase) of Own Shares
How can a company repurchase its share capital? What are the Companies Act requirements? What are the tax consequences for the company and shareholders?
Tax Data Card 2025-26
A summary of key tax rates and allowances for 2025-26 and 2024-25.
Guides & Updates
Self-employed
Compare software for Making Tax Digital for Income Tax
UPDATE: What software is available for MTD for Income Tax? What's the most suitable software I can use? Which software does HMRC list as working for MTD for Income Tax? What to consider before choosing software?
Allowances: Trading and Property
What are the trading and property allowances? Who can claim them? What are the restrictions?
Directors & Companies
Interest relief: Making a loan to a close company
Individuals can claim tax relief for interest paid on a loan where the funds are used by a close company or used to buy an interest in a close company. Which loans qualify? What is a business purpose?
Loss relief (Income Tax) disposal of shares
Share Loss relief allows you to offset a loss made on the disposal of shares against income instead of following normal capital loss treatment.
Employers
National Living Wage rates/National Minimum Wage rates
The National Living Wage rates/National Minimum Wage rates all change annually on the 1st April. Employers need to ensure that they make the necessary adjustments.
HMRC-recognised payroll software
UPDATE: HMRC have updated their list of free and paid-for recognised payroll software used to report PAYE online. HMRC emphasise that they do not recommend one product or service over another and are not responsible for any problems with the software you’ve bought.
Private Client & Estate Planning
IHT: Loans and restrictions on liabilities against the estate
When are loans deductible from the estate on death? What restrictions are there? What anti-avoidance rules do I need to consider?
Tax Return questionnaire
What information is needed to complete a Self Assessment Tax Return? This questionnaire will help you gather the documents and information required.
Land & Property
Property profits and losses: Toolkit 2025-26
NEW: Our Property Profits & Losses toolkit takes HMRC's version as its starting point and adds a great deal more information about what you can claim as an individual landlord.
Land & Property: an Adviser's Tax Update 2025-26
NEW: Land and Property taxes: a comprehensive review of the sector offering a topical CPD update. Hot topics for advisers include issues concerning the abolition of the Furnished Holiday Let (FHL) regime and the recent Spring Statement announcement that MTD for landlords with income above £20,000 will be brought forward to April 2028.
Overseas & Residence
Non-Domicile: Rules from 6 April 2025
UPDATE: What are the changes to the 'non-dom' regime? What does this mean for non-doms currently using the remittance basis? How will Income Tax, Capital Gains Tax and Inheritance Tax be affected by the changes?
Disguised Remuneration
Loan Charge Review: At a glance (Terms of Reference)
UPDATE: The Exchequer Secretary to the Treasury, James Murray, has announced an independent review of the loan charge to bring matters to a close for taxpayers affected by the legislation. A call for evidence has now been launched: the deadline to submit evidence is 12 noon, 30 May 2025.
Penalties & Compliance
Setting up as a tax agent
What do you need to consider when setting up as a tax agent? What are the steps? How do you register with HMRC?
Named tax avoidance schemes, promoters, enablers
UPDATE: HMRC publishes a list of named tax avoidance schemes, promoters, enablers and suppliers. It is not recommended that taxpayers use any of these schemes, as HMRC does not consider that they work and you may end up with a significant tax liability if you engage with the scheme suppliers.
VAT
Capital Goods Scheme
What is the VAT Capital Goods Scheme (CGS)? When do I use it? How does it work?
Flat rate scheme: Farmers
What is the agricultural flat rate scheme? Who can use it? What are the conditions? What is the benefit? What about non-farming income?
Tax Tools & Calculators
Tax tools & calculators
We have a suite of useful tax tools that help agents, business owners and sole traders calculate their taxes.
Calendar of tax deadlines and new tax measures
UPDATE: This is a freeview 'At a glance' rolling calendar of common recurring tax deadlines, new tax measures and other tax-significant events.
CPD
CPD for lunch: Byte-sized chunks of lunchtime CPD (free for our Subscribers)
- How to run the most tax-efficient business 2024/25.
- Purchase of Own Shares: all the details.
- Anti-money Laundering Update and Firm-Wide Risk Assessment ...More...
Tax Queries?
UK Agent for registration of Overseas Entities
Do you require assistance in the registration and verification of an overseas entity that owns UK land or property?
Virtual Tax Partner© Support
Have a tax query? Need a second option? Open a ticket and ask a question. A team of tax experts with a wide range of expertise: covering direct and indirect tax, as well as accounting, R&D claims, reorganisations and much more.
Missed the Last Tax Update?
Ross Martin Tax: SME Tax News 27 March 2025
- Spring Statement 2025: At a glance
- More taxpayers into MTD by 2028
- R&D consultation on advance clearance procedure
- Better use of new and improved third-party data
- Finance Act 2025 receives Royal Assent
- Agent Update: March 2025
- Capital loss denied on loan converted to shares
- Personal Liability Notice validly issued
- HMRC delay to VAT registration causes confusion ...More
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