Hello,
In 2022, the ‘Digitisation Taskforce’ was launched to drive forward the modernisation of the UK’s shareholding framework. It has now published its final report, in which it recommends a staged approach to removing paper share certificates and ultimately moving to a fully intermediated system of shareholding in the UK.
The Government has accepted the Taskforce’s recommendations and set out how it intends to take them forward. It is worth noting that the final report focuses only on companies with publicly traded securities; it does not cover private unlisted companies.
Earlier this year, we covered the Court of Appeal’s (CoA) decision in Orsted West of Duddon Sands (UK) Limited. This dispute largely focused on the term ‘on the provision of plant’ in a capital allowance context, and its application to expenditure incurred on studies.
The CoA’s decision sided with the taxpayers, but we now know that there will be another chapter to this story, as HMRC have been granted permission to appeal to the Supreme Court. It is likely to be several months before we know the outcome.
We explore three First Tier Tribunal (FTT) decisions this week, which cover a late appeal, corporate degrouping charges, and ‘reasonable excuse’. We also feature three new ‘annuals’ for 2025-26. These look at what’s new for partnerships, employers, and capital taxes for individuals.
More news and updates below, including some recent statistics from HMRC revealing interesting trends in non-domiciled taxpayers, company car benefits, employee share schemes, and charity tax reliefs.
The Ross Martin Tax Team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
HMRC annual statistics round-up
HMRC have recently released several sets of statistics. We summarise some of the key points relating to non-doms, company cars, employee share schemes and charity tax reliefs.
HMRC ignorant of billionaires' contribution to tax take
The Public Accounts Committee (PAC) has published 'Collecting the right tax from wealthy individuals', revealing that HMRC cannot identify how much tax is paid by UK billionaires. The PAC was also sceptical of HMRC's estimate that the wealthy tax gap was only £1.9 billion.
Plans for share digitisation outlined
The Digitisation Taskforce has published its final report recommending a staged approach to removing paper share certificates for publicly traded companies and eventually moving to a fully intermediated system of shareholding in the UK. The government has accepted the recommendations.
Fourteen arrested for phishing attack
HMRC have reported that Romania's Police’s Economic Crimes Investigation Directorate have arrested thirteen people in connection with phishing attacks on its systems, with British police arresting one more in Preston. They have been detained on suspicion of computer fraud, money laundering and illegal access to a computer system.
Tax Cases
Application to make a late appeal granted
In Daine Stoney v HMRC [2025] TC09572, the First Tier Tribunal (FTT) allowed an application for a late appeal against HMRC assessments and closure notices.
Currys Retail Ltd liable for £30m degrouping charge
In Currys Retail Ltd v HMRC [2025] TC09562, the First Tier Tribunal (FTT) found that a degrouping charge arose on a company exiting a chargeable gains group.
Mistaken taxpayer had reasonable excuse
In Sayrun Lamuth v HMRC [2025] TC09578, the First Tier Tribunal (FTT) found that a taxpayer who did not understand the reporting requirements for her share of rental income had a reasonable excuse for the late payment of tax.
Editor's Choice
What expenditure qualifies for plant & machinery allowances?
What is plant and machinery? What expenditure qualifies as plant and machinery? What is treated as part of a building?
CGT Rollover Relief: Exchanges of joint interests in land
This guide outlines the form of Capital Gains Tax (CGT) Rollover Relief available for exchanges of joint interests in land.
Guides & Updates
Self-employed
Sole trader v. limited company: Tax differences & savings (2025/26)
Is it better from both a tax and legal point of view to run your business as a sole trader or as a company? Are there tax advantages in running a business as a company? What legal protections apply?
Is it a trade, a business, or an investment activity?
Starting in business or running one? Is your new or existing business a trade, a business or an investment activity? The distinction is very important for tax purposes. This guide runs through key issues for tax purposes.
Compare software for Making Tax Digital for Income Tax
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?
Partnerships
Partnerships: What's new 2025-26?
NEW: What's new for partnerships in 2025-26? How are they taxed? What reliefs are available?
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?
Employers
Employer's What's On: 2025-26
NEW: This employer update is for advisers and their clients for 2025-26 and covers measures from the 2025 Finance Act and the October 2024 budget. It also considers other topical issues for employers and employees.
Payrolling of benefits
The value of certain taxable Benefits In Kind can be included in taxable pay when calculating the PAYE deducted from payments of wages and salaries to employees.
Private Client & Estate Planning
Capital taxes round-up: 2025-26
NEW: A round-up of developments in capital taxes for individuals for 2025-26, including the new rates for Capital Gains Tax (CGT) announced in the Autumn Budget, as well as some topical CGT and Inheritance Tax (IHT) cases.
Online filing exclusions for 2024-25 tax returns
Some taxpayers will be unable to file their Self Assessment returns online for the year ended 5 April 2025, due to software specification issues from HMRC. Lists of filing exclusions for individuals, partnerships, trusts and estates have recently been published by HMRC.
Cryptoassets: How are Bitcoin, cryptocurrencies or cryptoassets taxed in the UK?
How do you tax Bitcoin? Are cryptocurrency or cryptoasset gains or profits taxable? Can you obtain tax relief if you make losses on Bitcoin? Gains on transactions in cryptoassets are potentially taxable in the same way as other investments.
Land & Property
Adviser's Guide: Property Business, profits and losses
What is property income? How is it taxed? How are profits calculated? How are losses relieved? Is National Insurance paid on property income? Is property income classed as a business activity?
Penalties & Compliance
Materiality and tax
What is materiality and how does it apply to tax?
Penalties: P11Ds
What are the deadlines for P11D returns? What penalties are due for late or incorrect returns?
VAT
Groups (VAT)
What are the conditions for forming a VAT group? What rules apply once a VAT group is in place?
Reverse charge: Domestic
Domestic reverse charge VAT is a mechanism designed to prevent VAT fraud. When does it apply? How does it operate?
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
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:
- Monthly Tax Update - July 2025
- Practice Insight - July 2025 (free)
- Monthly Tax Update - June 2025
- Practice Insight - June 2025 (free)
- Making Tax Digital for Income Tax - Roadmap to April 2026
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 10 July 2025
- Legislation Day set for 21 July 2025
- Tourism tax approved for Wales
- One-to-many letters: Tracker
- Non-UK resident partner's profits taxable in UK
- Director's loan prevented Business Investment Relief
- Remuneration trust contributions not deductible for CT purposes
- CoA rules 'place of effective management' not jurisdiction where trustees appointed
- Partnerships: Capital Gains Tax
- Non-Domicile: Rules from 6 April 2025 UPDATE
- Cryptoasset Reporting Framework (CARF) UPDATE ...More
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