HMRC have published their Agent Update for December 2025. We have summarised the key content, including an update on the mandatory payrolling of Benefits In Kind (BIKs), important reporting requirements for some trusts under the Automatic Exchange Of Information (AEOI) rules, the key changes agents should be aware of in relation to Making Tax Digital (MTD) for Income Tax and important considerations with regard to filing your clients' Self Assessment tax returns for the 2024-25 tax year.
Guidelines for Compliance (GfC): Help with Investment Zones GfC15
HMRC have recently published new compliance guidelines, 'Help with Investment Zones GfC15'.
Investment Zones are areas across the UK where central and local government will work with business and local partners to create the conditions for investment and innovation.
- Businesses operating in Investment Zones can access a variety of incentives, including tax advantages.
- These include reduced National Insurance Contributions (NICs), relief from Stamp Duty Land Tax (SDLT) and enhanced capital allowances for eligible investments.
These guidelines are primarily for taxpayers who have business premises in an Investment Zone or are considering doing business with one.
- They will also be useful to Investment Zones governing bodies and professional bodies that advise clients on Investment Zones.
The guidelines provide support by:
- Explaining the tax reliefs available within Investment Zones.
- Highlighting areas where HMRC is identifying errors.
- Encouraging compliance by clarifying areas of uncertainty,
- Helping taxpayers reduce the risk of incorrectly claiming tax reliefs.
- Advising on what records and evidence should be retained.
- Explaining what to do if a mistake is made.
See Investment Zones
Student and postgraduate loans thresholds and rates for 2026-27
The new student loan plan type and postgraduate loan thresholds and rates have been announced by the Department for Education.
The thresholds from 6 April 2026 are:
- Plan 1: £26,900.
- Plan 2: £29,385.
- Plan 4: £33,795.
- Plan 5: £25,000.
- Postgraduate loan: £21,000.
Deduction rates from 6 April 2026 for:
- Plan types 1, 2, 4 and 5 remain at 9% for any earnings above the respective thresholds.
- Postgraduate loans remain at 6% for any earnings above the threshold.
HMRC are updating the starter checklist ahead of the new tax year for 6 April 2026 to:
- Add a new student loan plan type 5 checkbox to the checklist.
- Clarify options for taxpayers with multiple loan types.
- Employees will now only be able to select one plan type loan, i.e. 1, 2, 4 or 5, on the online version, but can still select the postgraduate loan at the same time as plan type loans.
- Additional guidance has been added in the forms to support taxpayers with multiple loans and to help employees identify their repayment loan type.
See Student Loans
Operational activity following the new independent review of the loan charge
The final report of the Independent Loan Charge Review 2025 was published at Budget 2025.
- Alongside this report, the government published its response.
The government has accepted all but one of the recommendations, and in some areas has gone further.
- Legislation will be brought forward immediately in the Finance Bill to provide for a new settlement offer that the government hopes will maximise the opportunity for individuals to come forward and settle.
For people who have yet to settle with HMRC, a new settlement opportunity will be introduced that will substantially reduce the amount that they must pay, particularly those with the lowest liabilities (typically those on the lowest incomes).
- If they decide to settle, most individuals could see reductions of at least 50% in what they have to pay to settle their loan charge liabilities.
- About 30% of individuals affected may, depending on their individual circumstances, be able to settle without paying anything.
- The new settlement opportunity is open to anyone with outstanding loan charge liabilities, including employers.
HMRC will begin contacting taxpayers to notify them of eligibility from January 2026.
HMRC have published an update to the loan charge operational activity, giving further details on the settlement opportunity and what you can do as you wait for them to review your clients' arrangements.
See Independent Loan Charge review government response
Spotlight update: Disguised remuneration, tax avoidance using unfunded pension arrangements (Spotlight 58)
This spotlight has been updated following two General Anti-Abuse Rule (GAAR) advisory panel opinions on:
- Reward through the creation and sale of a pension obligation, with consideration paid to the owner of the pension obligation.
- Reward through the creation of an obligation to make pension payments to employees and the transfer of that obligation to another employee in exchange for payment.
The GAAR advisory panel determined that the arrangements did not constitute a reasonable course of action or legal implementation.
Spotlight 58 will help you understand the GAAR advisory panel opinions and what they mean for clients using tax avoidance schemes involving unfunded pension arrangements.
- If any of your clients are using these or similar schemes or arrangements, HMRC strongly advises them to withdraw from them and settle their tax affairs.
- If any of your clients are using the tax avoidance schemes outlined in these spotlights, you should contact HMRC before you take action to withdraw your clients from the specific scheme arrangements contained in this spotlight.
- If you are already in contact with someone in HMRC about your client's use of an avoidance scheme, you should contact them to discuss this further.
- If you do not have an HMRC contact and want to help your clients leave this or similar arrangements, you can Contact HMRC to discuss getting out of an avoidance scheme.
See Spotlight 58: Unfunded pension arrangements
Payrolling of Benefits In Kind (BIKs) update
On 26 November 2025, HMRC published Draft guidance and legislation to help taxpayers prepare for reporting BIKs in real-time, building on the previous April 2025 release.
This interim BIK guidance and legislation:
- Explains what agents need to consider when advising clients on preparing their employees and payroll functions for real-time reporting from April 2027.
- Includes worked examples of how the taxable values of specific BIKs can be calculated.
- Provides draft legislation to aid understanding of the changes to reporting BIKs to HMRC from April 2027.
- Confirms a registration service for the voluntary payrolling of employer-provided loans and accommodation, the most complex BIKs to report, will go live from November 2026.
HMRC encourage agents to review the latest interim guidance and discuss with clients what they need to understand and do, to prepare for the upcoming changes, such as making a list of all BIKs they provide and usually report to HMRC using the online P11D form.
To assist software providers, HMRC sent technical documentation to developers in November 2025, detailing planned changes to Real-Time Information (RTI) required for the upcoming payrolling of BIKs.
- Agents should be aware of these changes when advising clients on payroll processes and compliance with HMRC's requirements.
Final guidance will be published ahead of the mandatory payrolling of BIKs, which comes into effect in April 2027.
See Mandatory payrolling of benefits from 2027: Briefing
Research and Development (R&D) tax reliefs
Pre-1 April 2024 relevant R&D expenditure:
- HMRC have updated their R&D manual to remove a paragraph in relation to pre-1 April 2024 relevant R&D expenditure.
- The update to the manual reflects a legislative amendment made in Finance Act 2025.
From Spring 2026, HMRC will pilot a targeted R&D advance assurance service for all Small and Medium-sized Enterprises (SMEs) planning to claim R&D relief.
- The service will enable SMEs to gain clarity on key aspects of their R&D tax relief claims before submitting to HMRC.
- Applicants will be able to seek assurance on one of four issues during the pilot.
- These issues have been chosen from stakeholder feedback as the most complex or high-risk aspects of an R&D claim:
- Whether the project meets the definition of R&D for tax purposes.
- Whether overseas expenditure qualifies for relief.
- Which party can claim relief for contracted-out expenditure.
- Whether the company qualifies for exemption from the PAYE or NIC contribution cap.
HMRC will set out further details in due course.
A Summary of responses to the advance clearances consultation has also been published.
Important changes to Automatic Exchange Of Information (AEOI): action required
Significant updates to the OECD Common Reporting Standard (CRS) will expand coverage to include more financial institutions and products.
- Amendments have been made to strengthen the due diligence and reporting requirements.
- HMRC have also introduced a new mandatory requirement for Reporting Financial Institutions and Trustee Documented Trusts to register for the AEOI service.
- These changes may affect any financial institutions you represent.
Mandatory registration has been introduced to gain a full understanding of the whole reporting population.
- This is a one-off rather than an annual requirement.
- All Reporting Financial Institutions and Trustee Documented Trusts should register for the AEOI service by 31 December 2025 or 31 January following the calendar year in which they become a Reporting Financial Institution or Trustee Documented Trust.
- This includes those who have no reportable accounts.
- If you represent Financial Institutions or Trustee Documented Trusts, make sure they are registered by this deadline, or as soon as possible afterwards.
- Late registration penalties will not apply if you have a reasonable excuse for any delay in registering.
See New trust registration deadline: 31 December 2025
From 1 January 2026, the following changes will be introduced as part of CRS 2.0 Compliance:
- The CRS will include specific electronic money products, central bank digital currencies and direct investments in cryptoassets through derivatives and investment vehicles.
- Enhanced due diligence requirements will apply.
- Additional data fields must be reported.
- Charities that are financial institutions may be classified as Non-Reporting Financial Institutions, provided certain conditions are met.
These changes first apply to the reporting period ending 31 December 2026, which will need to be reported to HMRC by 31 May 2027.
To make sure financial institutions are ready to meet these new reporting requirements, it is important that they act now to:
- Review products and accounts to see if they are in scope.
- Update onboarding and due diligence processes.
- Review reporting systems to ensure they can produce the new CRS 2.0 data fields.
If you represent clients who will be affected by these changes, make sure they are ready to fulfil the new requirements.
Transferring a business out of a company: guidance publication
HMRC have published new guidance on transferring a business out of a company.
- They have also provided more information about disincorporation.
The guidance sets out the tax implications that should be considered when a company's business and assets are moved to its shareholders, who then operate as sole traders or a partnership.
The guidance on transferring a business out of a company covers:
- Tax considerations for the company, including Corporation Tax, PAYE and VAT.
- Tax considerations for shareholders, including Income Tax, Capital Gains Tax and Stamp Duty.
Improving the Making Tax Digital (MTD) experience: key changes agents should know
As we move closer to April 2026, HMRC say they have taken further steps to strengthen confidence in MTD for Income Tax by making key improvements. This comes from the announcements made at the Autumn Budget, including:
- Updates to the penalty regime for taxpayers that need to use MTD for Income Tax.
- Updates to exemptions and to check for MTD eligibility.
Additionally, HMRC are removing most restrictions that previously prevented certain taxpayers from signing up for the year 2026-27.
- Signing up now for MTD for Income Tax is the best way for agents and taxpayers to get ahead.
Staying ahead: MTD support and resources for agents
- Register for specialist MTD support: these sessions will give agents direct access to HMRC specialists for tailored MTD readiness support.
- Share HMRC's communications resources: align your MTD messaging with what your clients may see from HMRC and share ready-made products.
- Sign up for a webinar: get ready for MTD by joining one of HMRC's webinars. These cover planning steps, actions to take now, how to sign up clients for April 2026 and Q&A.
See Making Tax Digital for more guidance on how to prepare for and use MTD for Income Tax.
Adding your existing Self Assessment authorisations to your agent services account
If you currently represent Self Assessment clients, you may add these authorisations to your agent services account.
- This will enable you to act on behalf of your client for MTD for Income Tax purposes without requiring additional authorisation.
- HMRC have updated the screens, so you now see the Self Assessment codes connected to your agent services account instead of your government gateway ID.
- These changes have been made in response to agent feedback.
- If you previously linked your government gateway ID, you do not need to repeat this process; HMRC will add the Self Assessment agent code for you.
Help your clients steer clear of tax avoidance
If you have clients working as contractors through umbrella companies, you can share HMRC's don't get caught out campaign with them.
- This will help your clients be more informed about tax avoidance.
- HMRC's campaign provides online guides that explain how to spot tax avoidance, with interactive tools to check payslips and contracts to confirm the correct amount of tax is being paid. Doing this avoids getting unexpected tax bills later.
- Personal stories of people who have been caught up in tax avoidance are available to view in a YouTube video that explains how umbrella companies work.
- Support is also available to contractors who need to leave and report a tax avoidance scheme, helping them to get back on track and settle their tax affairs quickly to prevent bigger tax bills.
HMRC never approve tax avoidance schemes, no matter what some promoters claim.
- HMRC publish a list of named tax avoidance schemes and their promoters. It is important to note that this is not an exhaustive list.
Encourage your clients to use HMRC's ready-to-go Campaign resources on tax avoidance.
- You can help equip them with the knowledge they need to make informed and compliant decisions by using HMRC's ready-to-go campaign resources in your newsletters, on your website and across your social media channels.
See: Named tax avoidance schemes, promoters, enablers
Changes to HMRC's sign-in screen
From 10 November 2025, taxpayers signing into HMRC may have noticed a new sign-in screen.
- This new screen introduces an additional option: GOV.UK One Login, alongside the existing government gateway option.
- Users should continue using their government gateway sign-in details as usual.
This change is part of HMRC's preparation for moving to GOV.UK One Login, a secure, modern sign-in system that will eventually replace the government gateway.
- Users on the HMRC sign-in screen will not be able to create a GOV.UK One Login or sign into HMRC with a GOV.UK One Login at this point.
- Instead, they will be redirected to the government gateway.
Some users may already have a GOV.UK One Login credentials from another government department.
- Currently, they cannot use their GOV.UK One Login to sign into HMRC services.
- They must continue to use their government gateway details to sign in.
Agents trying to access HMRC online services since 19 November 2025 will also see the new sign-in screen, which will include the GOV.UK One Login option.
- Agents cannot access HMRC with GOV.UK One Login at this time and should continue to sign in through the government gateway, entering their details as normal.
- Once signed in, agents will not see any changes and can continue to act on behalf of their authorised clients.
- The login flow, client list and available services will look the same.
Important points to note:
- You do not need to do anything; you can continue using your normal agent sign-in details as usual.
- Users cannot create a GOV.UK One Login to access HMRC online services, yet.
- If users select GOV.UK One Login, it will redirect them back to the government gateway for now.
Self Assessment: trading losses and carry back claims
If your client is self-employed or in a partnership and making a trading loss, you may be able to make a claim to carry that loss back to the previous year, or in certain circumstances, earlier years.
To claim for losses, you need to:
- Complete all relevant boxes on the tax return.
- Include details in the 'any other information' section.
- If you are not filing online and are using the self-employment (short) (SA103S) supplementary page, use the 'any other information' section of the main tax return (SA100).
Important points about carry back of losses to be aware of:
- Carrying back a loss does not change the Self Assessment or tax liability for the earlier year.
- Relief is calculated as if the loss were carried back, but it is given as a credit on the client's Self Assessment account.
To make sure credit is given on a successful claim, either:
- Enter the relief amount, as a decrease in tax due, in Box 15 on the tax calculation summary (SA110) page.
- Use the 'decrease in tax due because of an adjustment to an earlier year' box when filing online.
See Losses, trade losses and sideways relief
Get ready to file Self Assessment tax returns
It is time to make sure you and your clients are ready to file their Self Assessment tax returns and pay their tax by 31 January 2026.
- Getting ahead now gives you time to resolve any issues and helps you and your clients avoid any last-minute stress.
HMRC digital services can make your tax administration simpler and faster. HMRC digital services include:
- Agent services account: this is your gateway to HMRC online services for agents, including Self Assessment.
- Income record viewer: this provides access to your client's PAYE details, employment records, student loan repayments and more.
- Check when you can expect a reply from HMRC tool: helps to find out when you can expect a response to your queries or requests.
Self Assessment income thresholds
If your client's income is over £150,000 but taxed entirely through PAYE, you do not need to file a Self Assessment tax return for the 2024-25 tax year.
- The income threshold for PAYE-only taxpayers has been removed.
- Previously, it was £100,000, then it was raised to £150,000 for the 2023-24 tax year.
- It has now been removed entirely for PAYE-only income.
Your client will still have to file a tax return if they:
- Have other untaxed income, such as dividends or rental income.
- Need to pay the High-Income Child Benefit Charge and are not using the new PAYE service.
- Have capital gains, foreign income, or are a business partner.
- Want to claim tax reliefs on personal pension contributions or gift aid donations that cannot be handled through the PAYE coding.
You can check if your client needs to send a tax return using the checker at GOV.UK.
Remember to reactivate your client's account before submitting their tax return if they have registered before but did not submit a tax return last year.
See Do I have to file a tax return?
Providing feedback on HMRC manuals
HMRC manuals contain technical guidance for HMRC staff and tax professionals.
- Their primary purpose is to explain HMRC's interpretation of relevant legislation, on which the department makes its decisions.
All pages on GOV.UK contain feedback routes in the footer of each page as well as the contact GOV.UK form that allows you to tell HMRC whether a page is useful, suggest improvements or report a problem with a page.
- The HMRC manuals team review all items of feedback on their manuals from internal and external users.
Live webinar: Foreign Income and Gains (FIG) regime
From 6 April 2025, the rules for non-domiciled individuals ended and were replaced by a system based on tax residence.
- Qualifying new residents will get 100% tax relief on eligible FIG during their first four years of being resident. This is known as the 'FIG regime'.
Tax agents can now Register for HMRC's live webinar on 13 January 2026 or 10 February 2026.
- A recording will be posted on GOV.UK for anyone who cannot attend.
The webinar will help agents understand the main changes, including:
- Qualifying new residents.
- Claims for relief and making a claim.
- Time limits.
- Qualifying foreign income and disqualified income.
- Foreign capital gains.
See Non-Domicile: Rules from 6 April 2025
Mandatory tax adviser registration: policy paper published, guidance coming soon
From May 2026, all tax advisers who interact with HMRC on behalf of clients must register and meet minimum standards, an important step towards creating a fairer market for taxpayers and advisers.
- Most tax advisers will already meet the minimum standards, which include the basic legal requirements, such as having Anti-Money Laundering Supervision.
- This change will ensure that tax advisers who are not fit to act are not able to access taxpayer data and use HMRC systems.
HMRC are committed to supporting good tax advisers through strong safeguards.
- No tax adviser will be suspended automatically. HMRC will always work with tax advisers who are trying to comply in a timely way, even if their case is complex.
- For example, suspending registration will only occur after clear warnings and a fair chance to comply, including providing a reasonable excuse.
The new system will replace existing HMRC registration routes with one streamlined digital process, making registration simpler and more consistent.
- HMRC will continue to work with professional bodies and tax advisers to get the new system right.
HMRC have published a Policy paper setting out the details of this change to registration and meeting minimum standards.
In early 2026, HMRC will publish further guidance on GOV.UK explaining who needs to register, what they will need to do and how to get in touch if something goes wrong.
- This will include step-by-step instructions and support to help tax advisers prepare ahead of May 2026.
- All tax advisers will have at least three months to register from May and most tax advisers will have longer.
New tool for finding HMRC manuals guidance
HMRC have published a 'Find HMRC manuals' page which allows you to search across all HMRC manuals, filter by manuals or manual pages and sort the results, enabling you to see the latest page updates more easily.
- HMRC have also updated information on the guidance manuals tool in the GOV.UK resources for agents section of the tax agent's handbook.
September Wealthy External Forum minutes
On 11 September 2025, the Wealthy External Forum was held online, hosted by Danielle Simmons, Deputy Director (Wealthy Team).
- The session brought together representatives from professional bodies, key agent firms and members of the wealthy team to collaborate on current priorities.
Key topics discussed at the forum included:
- Updates on Capital Gains Tax rate changes, effective October 2024.
- Developments on crypto.
- Legal interpretation.
- Agent standards.
- An overview of HMRC's accelerated response team.
The Wealthy External Forum minutes are now published and available.
- As part of these discussions, the forum highlighted ongoing work on changes to the taxation of non-UK domiciled individuals.
- This initiative is overseen by a joint sub-group comprising representative bodies from HMRC's Wealthy External Forum and the capital taxes liaison group, ensuring alignment between policy development and stakeholder engagement.
Digital signatures
HMRC currently accepts digital signatures in limited circumstances.
- The use of advanced electronic signatures has been developed.
- Tax advisers submitting repayment claims on behalf of taxpayers using nominations for P87, R40 or the marriage allowance tax form must use an advanced electronic signature when filing these forms.
HMRC recognises the benefits of digital solutions and continues to consider opportunities to improve efficiency while maintaining robust safeguards.
- Wet signatures will remain available for those who are digitally excluded.
If additional clarification on the use of digital signatures is needed, this can be requested using the form on the contact tab at the bottom of the GOV.UK page for the specific service.
Income record viewer
Agents are strongly recommended to report technical issues using the 'Is this page not working properly?' link at the bottom of key HMRC online service pages.
- By completing the form available at this link, your inquiry will be promptly directed to a member of HMRC's digital support team for assistance.
- Using this channel is beneficial because it captures valuable technical information that helps HMRC's technical team investigate, prioritise and resolve issues efficiently.
- HMRC will keep users updated by email throughout the process and may ask for more information if necessary.
After implementing a solution, HMRC will request the user to verify whether the issue has been resolved or to supply additional information if further analysis is necessary.
- This process is not unique to the income record viewer and should be used for technical issues arising from other services, such as the agent services account.
HMRC were recently able to promptly identify the issue that prevented the tax code breakdown being displayed in the income record viewer after agents alerted them to it using the 'Is this page not working properly?' link.
- This enabled HMRC to identify the source of the problem and a resolution was implemented quickly for the majority of those affected.
Service updates
To ensure agents receive regular service updates, they should select the option 'add email alerts' in their agent services account.
- An option to select the type of updates you wish to receive is also available.
External link