Hello,

We have updates this week on the deductibility of pension contributions, tax fraud in the temporary employment agency and recruitment sector, import VAT recovery, and the application of the welfare VAT exemption for supplies made in Wales.

SME tax news 14

The Scottish Building Safety Levy was originally intended to be introduced from April 2027, but it was announced this week that it would be delayed by a year, to April 2028. This announcement is an opportune time to remind subscribers of our Rolling Tax Planner, which can be found in Editor’s Choice below.

This planner tracks key tax consultations and announcements across the UK, making it an invaluable point of reference when advising on tax matters. It shows, at a glance, the development of tax policy through to the point measures come into force.  

With less than a week to go until the Budget, speculation on what changes will be made is growing by the day. After the Chancellor has presented her Budget statement on Wednesday, we will publish exclusive subscriber-only guides covering the details of the announcements in every major tax area. You’ll find all the essential information you need to be up-to-date and analyse the impacts on your clients, in short, clear summaries. Our team will be working around the clock, so you can look forward to reading our guides with your morning coffee on Thursday.

In the period that follows, we will continue to provide more exclusive subscriber-only resources and expert analysis on the Budget changes, providing you with the toolkit needed to help your clients plan effectively. For anyone not currently a paid subscriber to rossmartin.co.uk, there’s never been a better time to join.

More news, cases and updates below, including our new guide for subscribers on the deductibility of fines and penalties. This brings together a wealth of case law in one place.

The rossmartin.co.uk tax team

Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.


Autumn Budget Analysis, Client Newsletter & Webinar

The 2025 Autumn Budget is shaping up to be one of the most consequential in recent memory, making it more important than ever for you and your clients to stay ahead of the field.

Our Budget resources will provide you with the tools you need to communicate with your clients and advise on the planning steps and opportunities available. 

  • Budget analysis: Sign up to rossmartin.co.uk now for access to our full Budget 2025 subscriber guides. 
    • Be kept up to date over the coming days and weeks as Budget announcements take shape, the Finance Bill is published, and planning opportunities arise.
  • Comprehensive client newsletter: a branded Budget newsletter for your firm to send to clients. Delivered in PDF format by 7am on 27 November (when ordered by 5pm on 24 November). 
    • Order now at £260+VAT with additional discounts available for rossmartin.co.uk subscribers and 20:20 Innovation Platinum and Premier Plus members. 
  • Budget Update webinar: the accountants’ guide and insights – planning strategies and more. Live at 10am on 28 November and on demand thereafter. 
  • Combination deal (save £99+): Budget client newsletter + firm-wide access to the Budget Update webinar (book as many of your team as you wish).
    • Order now at £260+VAT with additional discounts available for rossmartin.co.uk subscribers and 20:20 Innovation Platinum and Premier Plus members.

Quick News 

Tax fraud warning for employment agencies and employers
HMRC have published an issue briefing to raise awareness of tax fraud for employment agencies and employers. HMRC warn that new fraudulent models, offering cheaper payroll services, are currently being marketed to employers and recruitment agencies. 

One-to-many letters: Tracker
HMRC's latest one-to-many 'nudge' letters target wealthy individuals who claimed foreign tax credit relief in 2023-24, holding companies with overseas subsidiaries where a deduction for management expenses is claimed, and taxpayers who should have paid the remittance basis charge in 2023-24.

HMRC warns 'Christmas crafters' to check tax rules
HMRC are urging 'Christmas crafters' who earn income from selling festive items to check if they need to declare their earnings. Side hustlers who earn seasonal income during the festive period may need to declare earnings if they exceed £1,000.  


Tax Cases

Welsh welfare services were ‘state-regulated’ for VAT
In Cascade Care Limited v HMRC [2025] TC09680, the First Tier Tribunal (FTT) found a drafting error in the law relating to the welfare services VAT exemption. By reading words into legislation to correct the error, the FTT found that supplies made by a company in Wales were exempt from VAT and not standard-rated.  

Tax-driven pension provisions failed 'wholly and exclusively' test
In A D Bly Groundworks and Civil Engineering Limited and CHR Travel Limited v HMRC [2025] EWCA Civ 1443, the Court of Appeal (CoA) found that deductions for unfunded pension provisions were disallowable because the arrangements were primarily tax-driven rather than a genuine pension scheme. 

£8.5m of input VAT not recoverable
In TSI Instruments Ltd v HMRC [2025] TC09676, the First Tier Tribunal (FTT) found that import VAT charged on goods entering the UK could not be recovered as the goods were not owned by the importer. 


Editor's Choice

Finance Acts 2025-26: tax update and Rolling Tax Planner
This rolling planner tracks the key tax announcements that impact the 2025-26 tax year and beyond. This planner is updated on an ongoing basis.

IHT: Agricultural and Business Property Reliefs, April 2026 changes
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?


Guides & Updates 

Self-employed  

Fines and penalties
NEW: How are fines, penalties and payments for damages treated for tax purposes? What determines whether a fine or penalty is allowable or disallowable?

Losses, trade losses and sideways relief
How can trade losses be utilised? What are the restrictions?

Partnerships

Salaried members: When is a partner taxed as an employee?
In some circumstances, Limited Liability Partnership (LLP) members are taxed as employees under PAYE. What are the Salaried Member rules? When do they apply? What are the conditions?

Directors & Companies

Directors: Tax planning toolkit for 2025/26
What tax planning opportunities and strategies are available to directors? What's the optimum way to extract profits in 2025-26? What tax reliefs and tax deductions are handy to consider? This planner looks at a range of director tax issues.

Unlawful, illegal or ultra vires dividends
Is there a tax charge on an unlawful/illegal or ultra vires dividend?

Associated companies & tests for control
What is an associated company? What are the tax effects of associated companies? How do the control tests work? Examples of associated companies. What are the rules for indirect control?

Employers

Apprenticeship levy (employers' briefing)
What is the apprenticeship levy? Who pays it? How much is it?

Cycles & cyclists' safety equipment
What is the Cycle to Work scheme? What are the conditions? Is cycle equipment included in these provisions? What tax relief is available? What happens if the cycle is transferred to the employee?

Private Client & Estate Planning

Negligible value claims
What is a negligible value claim? When and how can a claim be made? 

IHT: Gifts with reservation
What are the Gift With Reservation (GWR) rules? When do they apply?

IHT: Transfers of value
What is a transfer of value for Inheritance Tax (IHT) purposes?

Capital Allowances

Annual Investment Allowance (AIA): Related companies
What restrictions to AIA apply to companies? What does common control mean? When are companies related?

Penalties & Compliance

Overpayment Relief
UPDATE: What is Overpayment Relief? When can you claim Overpayment Relief? What are the conditions for a claim for Overpayment Relief? What are the time limits for a claim for Overpayment Relief?

Professional Conduct in Relation to Taxation
UPDATE: The Professional Conduct in Relation to Taxation (PCRT), adopted by the main professional accounting and tax bodies, sets out the professional standards expected of a member when undertaking tax work.

Mandatory tax adviser registration with HMRC
From 1 April 2026, 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?

VAT

Capital Goods Scheme
What is the VAT Capital Goods Scheme (CGS)? When do I use it? How does it work?


Continuing Professional Development (CPD)

Recent and upcoming webinars include: 

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 13 November 2025

  • HMRC contacting agents over participator loans
  • Employment-Related Securities Bulletin November 2025
  • R&C Brief 6 (2025): VAT deduction on insurance intermediary services supplied outside the UK
  • NAO flags fraud and error at HMRC
  • Employment incentive plan payment taxable on non-resident
  • Employment costs for medical staff not exempt for VAT
  • Trust Registration Service
  • MTD: Toolkit for accountants
  • Travel rules for owner-managers
  • Interest: Peer-to-peer lending
  • Investment Zones
  • Soft Drinks Industry Levy  ...More  

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