Hello,
We cover a vast array of topics this week, hopefully meaning there is something for everyone! Between them, our mix of cases explore the gift with reservation rules for Inheritance Tax, the UK tax treatment of distributions by a Jersey company from its share premium and the VAT treatment of providing and fitting telematics devices.
Last week, the Government published its response to the 2023 stamp taxes on shares consultation. This confirms the intention to introduce, in 2027, a single tax on securities to replace both Stamp Duty and Stamp Duty Reserve Tax.
In Editor’s Choice, we feature two new guides. One looks at what’s new in the world of capital allowances for 2025-26 and the second examines what we know so far about mandatory payrolling of Benefits In Kind from 6 April 2027. This briefing will continue to be updated over the coming months, as the policy evolves.
From 6 May 2025, to keep taxpayer data secure, HMRC will no longer provide Unique Taxpayer Reference (UTR) numbers over the phone. Taxpayers are reminded that they can find their UTR on their Personal Tax Account or any self-assessment letter from HMRC. If a UTR cannot be found by these methods, HMRC will send it by post after a series of security questions are answered. This may take up to two weeks to arrive.
More news and updates below, including HMRC's April 2025 Employment-Related Securities Bulletin and the Public Accounts Committee's latest report on 'The cost of the tax system'.
The Ross Martin Tax Team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
Spotlight 69: Liquidation of an LLP used to avoid CGT
HMRC have published Tax Avoidance Spotlight 69 'Liquidation of a Limited Liability Partnership used to avoid Capital Gains Tax', highlighting a scheme used by landlords to reduce their tax liability.
Employment-Related Securities Bulletin April 2025
HMRC have released the April 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.
Changes to share stamp taxes planned
The Government has published a response to its consultation, ‘Modernisation of the Stamp Taxes on Shares Framework’. Draft legislation for a new single tax on securities to replace Stamp Duty and Stamp Duty Reserve Tax (SDRT) will be published in due course. The new single tax and an online portal to handle reporting transactions are expected to be in place in 2027.
HMRC's productivity down, costs up and businesses hurt, say MPs
Parliament's Public Accounts Committee's (PAC) latest report, 'The cost of the tax system', again criticises HMRC's performance, warning that as tax collection costs rise, HMRC needs to put the customer first and be ready to adopt new technologies, including Artificial Intelligence (AI).
HMRC's £1bn, 15-year tech tender
HMRC have announced a £1 billion tech procurement contract for "a strategic Core SaaS CRM Platform, along with core and additional supplementary products to meet the full range of eCRM capability". The contract comes after continued criticism of HMRC's systems from the Parliamentary Public Accounts Committee.
Tax Cases
Distribution of share premium was subject to Income Tax
In Alexander Beard v HMRC [2025] EWCA Civ 385, the Court of Appeal (CoA) found that distributions made by a company incorporated in Jersey and debited to its share premium account were subject to UK Income Tax, not Capital Gains Tax.
IHT chargeable on gifts made with reservation
In Afsha Chugtai v HMRC [2025] TC09495, the First Tier Tribunal (FTT) found that a transfer of value made over seven years before death could not be excluded from the estate for IHT purposes as the donor had reserved benefit in the assets gifted.
Supply of telematics devices for insurance VAT-exempt
In WTGIL Ltd v HMRC [2025] EWCA Civ 399, the Court of Appeal (CoA) found that an insurance intermediary providing and fitting driving-monitoring devices was making an exempt supply for VAT purposes.
Editor's Choice
Capital Allowances: What's new 2025-26
NEW: What's new in Capital Allowances for 2025-26? A summary of the main different types of capital allowances currently available to UK businesses.
Mandatory payrolling of benefits from 2027: Briefing
NEW: The Government has announced that the mandatory payrolling of benefits in kind and taxable employment expenses will not be brought into force until 6 April 2027. This replaces the earlier date of 6 April 2026, allowing employers more time to prepare for the changes.
Guides & Updates
Self-employed
Tradespeople: Tax Overview
What expenses can Tradespeople claim for tax purposes? How is their income taxed? What are the VAT rules? What are the rules for subcontractors?
Incorporation
Sale of occupational income: Anti-avoidance
What are the tax effects of the anti-avoidance sale of occupational income provisions? How do you tax a capital sum received on the sale of an individual's earnings?
Directors & Companies
EIS: Enterprise Investment Scheme (Subscriber guide)
When can EIS relief be claimed? What are the conditions for EIS relief? What are the benefits of EIS relief?
Settlement anti-avoidance rules
What are the settlement anti-avoidance rules? How do these rules catch some common family tax planning? What are the rules for spouses and other family members?
Employers
Travel (employer's guide)
How do employers apply the tax rules to travel costs? What is available for subsistence costs? What are the rules on home-to-work travel?
Private Client & Estate Planning
Gift Aid
How is tax relief for Gift Aid donations received by individuals? How do donations impact the personal allowance? When can Gift Aid donations be carried back to an earlier tax year?
Trusts & Estates: What’s New 2025/26
HMRC's latest Trusts and Estates newsletter contains some useful information. This is our enhanced version for subscribers, including reminders of recent and upcoming changes.
Land & Property
Profits from dealing in or developing UK land
These rules apply UK Income Tax or Corporation tax to all profits from trading in and developing UK land, regardless of your country of residence.
VAT
Flat rate scheme
What is the VAT Flat Rate Scheme (FRS)? Who can apply? How do you apply? What are the rules? What are the rules for capital expenditure and pre-registration VAT?
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
Recent webinars include:
- Practice Insight - May 2025 (free)
- Monthly Tax Update - April 2025
- Disincorporation - I'm an OMB Company, Get Me Out of Here!
- Practice Insight - April 2025 (free)
- Making Tax Digital for Income Tax - Roadmap to April 2026
- Monthly Tax Update - Spring Statement Special
Need Tax Support?
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 1 May 2025
- HMRC's Spring 2025 tax update
- Agent Update: April 2025
- HMRC to close agent and customer online forums
- Valuation Office subsumed by HMRC
- Revenue and Customs Brief 2 (2025): Use of VAT grouping within the care industry
- Consultation: VAT treatment of business donations to charity
- Consultation responses to tackling non-compliance
- Consultation on improving HMRC's approach to dispute resolution
- Separate annexe granted MDR ...More
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