Hello,
In our last update of 2025, we report on an important but little-known 31 December 2025 registration deadline for some trusts and other entities, the December Employer Bulletin, VAT in the context of rotisserie chickens, and Inheritance Tax on Income Tax repayments due to an estate.
Some trusts and other entities face an imminent registration deadline of 31 December 2025; this requirement to register with HMRC under the Automatic Exchange of Information (AEOI) rules has largely gone under the radar. In the case of trusts, registration may be necessary where the majority of income is from investments and they either have a corporate trustee or discretionary fund management agreement in place. Urgent action is advised to identify entities affected and undertake registration, where needed, as soon as possible.
HMRC’s use of one-to-many ‘nudge’ letters continues unabated, with one recent letter targeting agents with at least two overdue VAT returns. Recipients are given until 7 February 2026 to file their outstanding returns and pay any VAT due, or potentially face their agent codes being suspended, and a public interest disclosure being made to their professional body.
Moving away from compliance, our featured guides this week make for something of a seasonal special, many having a theme around gifting. We have also included a small selection of our resources which will be useful to subscribers approaching self-assessment tax return season in January.
As this will be the final SME Tax News of 2025, the rossmartin.co.uk team would like to wish all of our readers and subscribers a happy and healthy festive season, and a prosperous New Year. Our next SME Tax News will be published on Thursday 8 January 2026.
More news, cases and updates below, including the answer to the question: why did the chicken go to the VAT tribunal?
The rossmartin.co.uk tax team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
New trust registration deadline 31 December 2025
Changes made to the Automatic Exchange of Information (AEOI) regulations earlier this year mean that trusts and other entities considered to be a reporting Financial Institution or a Trustee Documented Trust are required to register with HMRC by 31 December 2025, even if they have no non-UK connections to report.
Employer Bulletin: December 2025
HMRC have published their Employer Bulletin for December 2025. We have summarised the key content for you, which links to our detailed guidance on the topics covered.
One-to-many letters: Tracker
HMRC's latest one-to-many 'nudge' letters target individuals who may have made an invalid Investors' Relief claim in 2024-25, and agents with at least two overdue VAT returns.
Tax Cases
Why did the chicken go to the VAT tribunal?
In WM Morrison Supermarkets Ltd v HMRC [2025] TC09722, the First Tier Tribunal (FTT) found that rotisserie chickens were a supply in the course of catering, and therefore subject to VAT at 20%, as they were provided to customers in packaging that retained heat.
Income Tax repayment due was subject to IHT
In Richard Thomas (as executor) v HMRC [2025] TC09716, the First Tier Tribunal (FTT) found that an Income Tax repayment formed part of a deceased taxpayer’s estate for Inheritance Tax (IHT) purposes.
Flat maintenance trust services not VAT exempt
In Places for People Homes Ltd v HMRC [2025] TC09695, the First Tier Tribunal (FTT) found that supplies of premises maintenance services made by flat maintenance trust companies were not exempt supplies of land.
Editor's Choice
Notice to file a tax return: section 8(1) TMA 1970
A guide to explain the implications of a notice sent to an individual under s.8(1) TMA 1970 to file a tax return.
Tax Return questionnaire
What information is needed to complete a Self Assessment Tax Return? This questionnaire will help you gather the documents and information required.
Provisional and estimated figures in tax returns
What is the difference between a provisional and an estimated figure in a tax return? When should provisional figures be used? What are the reporting requirements? When can HMRC charge a penalty?
Guides & Updates
Self-employed
Entertaining
Are the costs of business entertainment allowable for tax purposes? What is disallowed? What is allowed?
Business Gifts
What are business gifts? Are business gifts allowable for tax? What needs to be disallowed?
Directors & Companies
Family Investment Companies
What is a Family Investment Company? Why use a Family Investment Company? What is the tax treatment of a Family Investment Company?
Issuing different classes of share: Family companies
This guide examines the tax consequences of creating new share classes in a family company in order to split income with a spouse or close family members.
Shifting your income to save tax
This guide explains the planning points and pitfalls of sharing or splitting your income with your spouse or other family members.
Employers
Trivial benefits
What are trivial benefits? What is included? What are the caps?
Private Client & Estate Planning
Client Briefing: Making gifts & IHT
What gifts can you make without triggering Inheritance Tax (IHT)? What are the rules on making tax-effective gifts for IHT purposes?
CGT: Holdover/Gift Relief (s.165/s.260)
Holdover Relief may be available when an individual makes a gift to another person (individual or company). When is the relief available? What are the conditions that apply? What restrictions are there?
Overseas & Residence
Foreign income and residency pages: FAQs
How do you complete the foreign and residency pages of the Self Assessment return?
Penalties & Compliance
Failure to notify chargeability to tax
What is the failure to notify chargeability to tax? What happens if you fail to notify HMRC about your taxes? What penalties apply for failing to notify HMRC that you have a tax liability?
More Tax Guides
Gift Aid: How it works
What is Gift Aid? How does it work? What are the rules?
VAT
Discounts, Reward Schemes & Vouchers: VAT
Loyalty and reward schemes and vouchers come in various shapes and sizes and the VAT implications may vary depending on the type of scheme offered. This guide reviews the treatment of some typical schemes and case law.
Continuing Professional Development (CPD)
Recent and upcoming webinars include:
- Monthly Tax Update - December 2025
- Budget Update
- Practice Insight - December 2025 (free)
- Monthly Tax Update - November 2025
- Practice Insight - November 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 11 December 2025
- Finance (No. 2) Bill 2025-26: Contents
- Employment-Related Securities Bulletin 62 November 2025
- Response to electronic invoicing consultation
- Consultation outcome on taxation of decentralised finance, lending and staking of cryptoassets
- Business rates and investment call for evidence
- Relief for goodwill amortisation disallowed after incorporation
- Tax Data Card 2026-27
- Partnerships: Losses
- Creating an office at home or converting part of a home into an office
- Staff parties and annual functions ...More
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