Hello,

The taxation of stablecoins, online filing exclusions for 2025-26, tax relief for intangible asset amortisation and reasonable care when considering compliance with the Construction Industry Scheme (CIS) are among this week’s topical issues. 

SME tax news 15

HMRC have recently published a call for evidence on the taxation of stablecoins, a type of cryptoasset that seeks to maintain a stable value by reference to another asset, such as a fiat currency.

Currently, stablecoins are generally taxed in the same way as other cryptoassets, but the government says it may be appropriate to consider implementing different rules to treat stablecoins in a way that better reflects how they are used. These rules would therefore diverge from the tax treatment that applies to other cryptoassets. This is likely to be an area to watch for future development, albeit change may be some way off, as this is stage one of a five-stage consultation process.

Now that we have moved into a new tax year, a vast number of previously announced measures have come into effect, some of which may have slipped under the radar. These include the introduction of a requirement to claim Incorporation Relief and increased Corporation Tax late filing penalties.

Do take a look at our newly published Rolling Tax Planner for 2026-27. It records the key tax announcements that impact the 2026-27 tax year and beyond, in one easy point of reference. This makes it easy to see, at a glance, what changes are on the horizon in a particular area; it is an excellent timesaving and planning tool.

We cover three cases this week. As well as reasonable care in the context of CIS, these examine amortisation deductions for intangible assets and the meaning of ‘mixed use’ for Stamp Duty Land Tax (SDLT) purposes.

More news and updates below.

The rossmartin.co.uk tax team

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


Quick News 

Notifying HMRC that MTD income ceased before April 2026
HMRC have clarified the best routes to notify them when all of a sole trader or landlord's Making Tax Digital (MTD) relevant income has ceased before April 2026. This can be done via webchat or telephone by the taxpayer or their agent.

Call for evidence on tax treatment of stablecoins
HMRC has published a call for evidence on the 'Taxation of stablecoins', a type of cryptoasset. It seeks opinions on issues around the tax treatment of stablecoins for both individuals and companies. 

Online filing exclusions for 2025-26 tax returns
Some taxpayers will be unable to file their Self Assessment returns online for the year ended 5 April 2026 due to software specification issues from HMRC. A list of filing exclusions for individuals has recently been published by HMRC.


Tax Cases

Reasonable care not taken to comply with CIS
In Kalinga Holdings Limited v HMRC [2026] TC09812, the First Tier Tribunal (FTT) found that a company that purchased an old office building to convert into residential flats was liable to make deductions under the Construction Industry Scheme (CIS) and it had not taken reasonable care to comply with that obligation. 

CoA denies amortisation deduction on intangible assets
In Muller UK and Ireland Group LLP & Ors v HMRC [2026] EWCA Civ 248, the Court of Appeal (CoA) found that the related party restriction on claiming deductions for intangible assets applied to the Limited Liability Partnership (LLP) and its corporate members. As a result, the taxpayer's amortisation deductions were denied tax relief.

HMRC win UT appeal on 'mixed use' SDLT claim
In HMRC v Christopher Brzezicki [2026] UKUT 00125, the Upper Tribunal (UT) allowed an appeal from HMRC, ruling that a property purchase that included a fishing stream and a separate island was residential for Stamp Duty Land Tax (SDLT)  purposes. 


Editor's Choice

This week's Editor's Choice was selected by Andie Ross. You can meet our team of editors and writers here: Meet the team

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. 

Employers: Who is an employer for PAYE and NI purposes?
This guide provides useful ‘crib notes’ and summaries of the relevant legislation in the event that there is a dispute with HMRC as to who is an actual employer.

Non-resident tax toolkit
This toolkit covers the key UK tax issues for non-UK resident individuals holding UK assets and property and working in the UK.


Guides & Updates 

New This Week

Finance Acts 2026-27: tax update and Rolling Tax Planner
NEW: This rolling planner tracks the key tax announcements that impact the 2026-27 tax year and beyond. This planner is updated on an ongoing basis.  

Self-employed  

Allowances: Trading and Property
What are the trading and property allowances? Who can claim them? What are the restrictions?

Directors & Companies

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

PAYE Settlement Agreements
What are PAYE Settlement Agreements? How do they work? What can be included?

Removal and relocation expenses
How much may an employer reimburse for removal and relocation expenses? What are the conditions for tax relief?

Capital Allowances

Disposal values & rules
What is a disposal for capital allowance purposes? What is the tax consequence of a disposal? What value needs to be accounted for on a disposal?

Private Client & Estate Planning

Divorce & Separation: Toolkit
A summary of the tax implications which can arise on divorce and separation.

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

Land & Property

Land: future consideration (overage)
A guide to the tax treatment of future consideration payable on the disposal of land.

Gardens: selling or developing
What are the tax consequences of selling a garden for development purposes? What if the owner develops the garden? 

Penalties & Compliance

Adviser's Tax Penalty Planner
A guide to the key direct and indirect tax penalty regimes for returns and payments, excluding VAT.

VAT

Post-deregistration VAT recovery
When can VAT be recovered following deregistration? How is such VAT recovered?


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 Update 2 April 2026

  • Agent Update 141: March 2026
  • Revenue Scotland considers electronic-only communications
  • New 'sanctionable conduct' powers for HMRC
  • With MTD days away, HMRC send more mandation letters
  • Corporate Criminal Offences six-monthly update
  • Half-hearted SME acceptance of e-invoicing
  • Political donations not made from 'normal expenditure'
  • Directors: Tax planning toolkit for 2026-27 NEW
  • Penalties: Tax advisers (sanctionable/dishonest conduct) UPDATE
  • Calendar of tax deadlines and new tax measures UPDATE 
  • Mandatory tax adviser registration with HMRC UPDATE
  • Named tax avoidance schemes, promoters, enablers UPDATE  ...More

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