Hello,
We have previously highlighted that some individuals due to receive Winter Fuel Payments (WFPs) this year may wish to opt out if their 2025-26 income will exceed £35,000, to avoid the administration and complexity of WFP clawback through the tax system.
Given how close we are to the 15 September opt-out deadline for WFPs, early communication with clients is crucial. To help agents, we have our guide on the clawback of WFPs, which includes suggested wording that can be used in client communications.
Last week, we noted that Inheritance Tax (IHT) receipts reached record levels in 2022-23 despite significantly increased Agricultural Property Relief (APR) and Business Property Relief (BPR) claim values.
As is well known, the Government intends to reform APR and BPR from April 2026, something which will increase potential IHT exposure for many individuals. In Editor’s Choice, you can find our new guide exploring the upcoming changes, as we take a detailed look at the draft legislation that was recently published.
Among our case summaries this week, you will find the First Tier Tribunal’s (FTT’s) decision in Trevor John Masters v HMRC. Here, accrued final salary pension rights were transferred to a Self-Invested Personal Pension (SIPP) before being withdrawn by a non-UK resident.
The FTT was asked to consider whether the sums withdrawn from the SIPP were paid ‘in consideration of past employment’ in terms of the Double Tax Treaty, or whether the link with employment had been broken when the transfer to the SIPP was made.
For advisers dealing with the taxation of pensions in an international context, this decision makes for interesting reading.
More news, cases and updates below, including HMRC’s new Making Tax Digital for Income Tax support service for agents.
The Ross Martin Tax Team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
New MTD support service for agents
HMRC have launched a new online form for agents, allowing them to register for access to support while preparing for Making Tax Digital for Income Tax.
JP Morgan finds VAT 'disregard' does not apply to intra-group services
In JPMorgan Chase Bank NA v HMRC [2025] UKUT 188, the Upper Tribunal (UT) found that the First Tier Tribunal (FTT) had not erred in law when it found that the disregard for intra-group supplies did not apply to services supplied between group members.
SIPP withdrawals by non-resident found to be not taxable in the UK
In Trevor John Masters v HMRC [2025] TC09607, the First Tier Tribunal (FTT) found that withdrawals from a Self-Invested Personal Pension (SIPP) by a non-UK resident were not taxable in the UK, under the terms of the Double Tax Treaty (DTT).
Input VAT on property costs irrecoverable
In Brian David Webb v HMRC [2025] TC09611, the First Tier Tribunal (FTT) found that a former builder was not carrying on an economic activity for VAT purposes and was therefore unable to recover VAT attributable to his properties.
Editor's Choice
IHT: Agricultural and Business Property Reliefs, April 2026 changes
NEW: Significant changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) were announced in the 2024 Autumn Budget. What is changing? What planning could be considered?
Winter Fuel Payment recovery
UPDATE: It was previously announced that eligible individuals would automatically receive the Winter Fuel Payment (WFP) for 2025-26, but it would be recovered by HMRC when a person's income exceeded £35,000. HMRC have published updates on how WFP recovery will work in practice: we take a closer look.
Guides & Updates
Self-employed
Woodlands: Overview
Woodlands and forestry ownership carry significant tax reliefs, including Income Tax, Capital Gains Tax (CGT) and Inheritance Tax (IHT).
Partnerships
Partnerships: Capital Gains Tax
How does Capital Gains Tax (CGT) work for partners and partnerships? What is HMRC’s Statement of Practice D12? How are transactions between partners treated? What if the partners are connected persons for CGT?
Directors & Companies
Reorganisations & Reconstructions
What is a company reorganisation or reconstruction? What tax reliefs apply to a company reorganisation, a share for share exchange or a reconstruction?
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?
Globally mobile employees: PAYE reporting obligations toolkit
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.
Private Client & Estate Planning
Self Assessment Tax Return: What goes where?
NEW: The Self Assessment Tax Return for individuals is made up of a set of core pages and a number of supplementary pages. This guide explores what goes where on the tax return.
Divorce & Separation: Toolkit
A summary of the tax implications which can arise on divorce and separation.
Penalties & Compliance
Mandatory tax adviser registration with HMRC
UPDATE: From 1 April 2026, it is proposed that all tax advisers who interact with HMRC on behalf of clients will be required to register with HMRC. Who will be required to register? What conditions must be met? What are the consequences of non-compliance?
Special Relief
What is Special Relief? When does it apply? Does Special Relief have a time limit to claim?
More Tax Guides
Private Intermittent Securities and Capital Exchange System (PISCES)
UPDATE: What is the Private Intermittent Securities and Capital Exchange System (PISCES)? What are the tax implications of trading shares on PISCES? What impact will there be for share schemes?
Named tax avoidance schemes, promoters, enablers
UPDATE: HMRC publish a list of named tax avoidance schemes, promoters, enablers and suppliers. It is not recommended that taxpayers use any of these schemes, as HMRC do not consider that they work and you may end up with a significant tax liability if you engage with the scheme suppliers.
VAT
Deposit Return Scheme: Drink containers
UPDATE: The Deposit Return Scheme (DRS) is an environmentally ambitious scheme for single-use drink containers. It will now not be introduced until October 2027. How will it operate for VAT purposes?
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 14 August 2025
- IHT liabilities reach record levels
- Court tells HMRC to disclose AI use in R&D claims
- Over 850k taxpayers to sign up to MTD by April next year
- Further decrease in HMRC's interest rate
- Taxpayer's reliance on adviser valid reason for delay
- HMRC able to force VAT deregistration
- EIS appeal denied on trading requirements failure
- Globally mobile employees: PAYE reporting obligations toolkit NEW
- Globally mobile employees: Travel expenses for employees performing duties overseas
- Partial exemption & input VAT
- Carried interest UPDATE
- DOTAS: Disclosure of Tax Avoidance Schemes UPDATE ...More
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