Hello,
This week, we are pleased to publish a new suite of subscriber guides focusing on globally mobile employees. We also have the latest statistics on Inheritance Tax, estimates of the number of taxpayers that will be impacted by Making Tax Digital for Income Tax, as well as more decisions from the tax tribunals.
In an increasingly international business world, accountants and tax advisers regularly encounter clients with globally mobile employees.
This is a complicated area of UK tax and our new set of guides in Editor’s Choice will help navigate the rules which apply in different circumstances. Our ‘Globally mobile employees: PAYE reporting obligations toolkit’ is the recommended place to start when examining the position of employees sent to work overseas or employees coming to work in the UK.
In other news, HMRC’s latest statistics reveal that Inheritance Tax (IHT) receipts reached record levels in 2022-23 despite significantly increased claim values for both Agricultural Property Relief (APR) and Business Property Relief (BPR). With the Nil Rate Band and Residence Nil Rate Band both frozen until 5 April 2030, this trend seems likely to continue, underlining the importance of planning, where possible.
Turning to the tax tribunals, it is well known that reliance on an adviser cannot often constitute a reasonable excuse for a taxpayer’s failure. As with many general rules, there are exceptions, and this is seen in the First Tier Tribunal’s (FTT) decision in Parwinder Gill v HMRC, featured below. This case is well worth reviewing to examine the circumstances which led the FTT to its conclusion.
More news, cases and updates below.
The Ross Martin Tax Team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
IHT liabilities reach record levels
HMRC have published their latest statistics on Inheritance Tax (IHT), showing that receipts reached record levels in 2022-23. This was despite less than 5% of estates paying IHT, and the value of Agricultural Property Relief (APR) and Business Property Relief (BPR) claims increasing by 24% and 17% respectively.
Court tells HMRC to disclose AI use in R&D claims
HMRC have been given until 18 September to comply with a Freedom of Information (FOI) request and reveal whether it used artificial intelligence when making judgments on Research & Development (R&D) tax credits.
Over 850k taxpayers to sign up to MTD by April next year
HMRC have published the statistical report, 'Official Statistics 'Making Tax Digital for Income Tax business population statistics: commentary', which indicates that 864,000 individuals will have to sign up by April 2026.
Further decrease in HMRC's interest rate
HMRC's interest rates are decreasing by 0.25%, to 8.00% for late payment interest and 3.00% for repayment interest, from 27 August 2025.
Tax Cases
Taxpayer's reliance on adviser valid reason for delay
In Parwinder Gill v HMRC [2025] TC09602, the First Tier Tribunal (FTT) allowed an application to reinstate an appeal previously struck out due to the taxpayer's failure to comply with directions. The taxpayer had a reasonable excuse, as his adviser did not inform him of his responsibilities.
HMRC able to force VAT deregistration
In Elphysic Limited & Ors v HMRC [2025] UKUT0236, the Upper Tribunal (UT) found that HMRC had the power to deregister a company for VAT, where the VAT registration number was used for fraudulent purposes.
EIS appeal denied on trading requirements failure
In York SD Limited and Ors v HMRC [2025] TC09589, the First Tier Tribunal (FTT) denied the taxpayers’ Enterprise Investment Scheme (EIS) relief claim, ruling that preliminary work without a profit motive was not genuine trading. Main projects which were still incomplete at the two-year deadline could not be treated as qualifying business activities.
Editor's Choice (Global Mobility Special)
Globally mobile employees: PAYE reporting obligations toolkit
NEW: This toolkit helps determine what your PAYE reporting requirements are when sending an employee to work overseas or having an employee come to work in the UK from overseas.
Globally mobile employees: Travel expenses for employees performing duties overseas
NEW: What travel expenses can an employee claim when they are working overseas? Is there any relief for travel expenses for visiting family members?
Globally mobile employees: Pension contributions relief for overseas employees
NEW: Can non-UK resident employees contribute to a UK pension scheme? Can UK resident employees contribute to an overseas pension scheme? What UK tax relief is available? Can pension funds be transferred from a UK pension scheme to an overseas pension scheme? How are payments from non-UK pension schemes taxed?
Globally mobile employees: Short-Term Business Visitors
NEW: What is a Short-Term Business Visitor? What is an Appendix 4 agreement? What is an Appendix 8 agreement?
Globally mobile employees: Section 690 directions
NEW: What is a Section 690 direction? Who is eligible for a Section 690 direction? How do you apply for a Section 690 direction?
Globally mobile employees: Appendix 5 agreement
NEW: What is an Appendix 5 agreement? Who is eligible for an Appendix 5 agreement? How do I apply for an Appendix 5 agreement? How do you operate an Appendix 5 modified PAYE arrangement?
Globally mobile employees: National Insurance
NEW: What are my employer National Insurance obligations when hiring an employee from overseas? What are my employer Social Security obligations when sending an employee to work overseas? Do I have any PAYE reporting requirements in relation to National Insurance?
Guides & Updates
Self-employed
Farming: Tax Overview
What is farming? What are the tax consequences and tax considerations of farming? What are the features of agricultural tenancies? What expenses can farmers claim for tax purposes? Are there special tax and accounting rules for farmers? What are the VAT rules for farmers?
Partnerships
Carried interest
UPDATE: What is carried interest? When does carried interest arise? How is carried interest taxed?
Directors & Companies
Losses: Carried forward loss relief restriction
When are claims for carried forward (c/fwd) loss relief restricted? Who is impacted by these restrictions? What are the compliance obligations associated with these restrictions?
Groups
What qualifies as a group for tax? How do you form a group? Which definition of a group applies for different types of tax? What are the benefits of being in a group?
Private Client & Estate Planning
Business Asset Disposal Relief (Entrepreneurs' Relief): Disposal of trust business assets
When can trustees claim Business Asset Disposal Relief (BADR)? Which types of trust is BADR available to? Who can claim BADR for a trust disposal of business assets?
Investors' Relief
What is Investors' Relief? How does it differ from Business Asset Disposal Relief? Which disposals qualify? What are the conditions?
Trusts & Estates: What's new? 2025-26
UPDATE: HMRC's latest Trusts and Estates newsletters contain some useful information. This is our enhanced version for subscribers, including reminders of recent and upcoming changes.
Penalties & Compliance
DOTAS: Disclosure of Tax Avoidance Schemes
UPDATE: What are the Disclosure of Tax Avoidance Schemes (DOTAS) rules? When should you disclose your use of a tax avoidance scheme? What are the consequences of non-disclosure? How are penalties calculated?
More Tax Guides
Pensions: What happens when you die?
What happens to your pension when you die? What tax is due by your estate? Will your family have to pay Income Tax if they receive your pension going forward? What can you do to mitigate any tax charges?
VAT
Partial exemption & input VAT
How do you calculate the amount of input tax you can recover under the VAT partial exemption rules? What are the de minimis rules?
Energy-Saving Materials
The supply and fitting of energy-saving materials in residential accommodation attracts the zero rate of VAT. What does it apply to? What are the qualifying conditions? What case law is there on this topic?
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, reorganisations and much more.
Missed the Last Tax Update?
Ross Martin Tax: SME Tax News 7 August 2025
- HMRC campaign to correct reporting of 'private use' adjustments
- HMRC issue warning on SDLT claims
- One-to-many letters: Tracker
- VAT assessments brushed under the carpet
- Bonds paid by cadet pilots were a consideration for VATable supply
- Mandatory tax adviser registration with HMRC
- Wholly and exclusively…toolkit
- Motor expenses (self-employed)
- Associated companies & tests for control
- Calculating Corporation Tax & Checklist
- Subsistence (employer's guide)
- CGT: How to calculate a capital gain or loss ...More
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