Hello,

One of this week's major announcements is confirmation that, on 28 October, the Chancellor will present the 2026 Budget. When John Healey rises to deliver his first Budget speech since taking office, just a few months into Andy Burnham's time as Prime Minister, it will be a significant moment for UK fiscal policy, as the new leadership team sets out its economic priorities in full. 

SME tax news

For advisers and their clients, understanding what changes the Budget announcements make, and what they will mean in practice, has rarely mattered more. You can find details below of the Budget analysis, update webinar, client newsletter and other resources we will have available post-Budget, allowing you to stay on top of the announcements, and effectively communicate them to clients promptly.

In other news, HMRC have recently updated their Business Income Manual on the deductibility of interest. The change, which seems to have had little attention so far, affects interest incurred when borrowing funds to finance the withdrawal of capital from a business.

The revisions represent a notable departure from HMRC’s previous guidance and may have real consequences for many unincorporated business owners, as HMRC might increasingly seek to restrict relief. Our news item works through the amendments that HMRC have made, and what they could mean in practice.

Lots more news, cases and updates below, including a look at possible payroll errors leading to double tax relief on workplace pensions; an Upper Tribunal (UT) decision on whether a company has a 'life' for Inheritance Tax purposes; and a second UT judgment dismissing a Business Property Relief claim on serviced offices. 

The rossmartin.co.uk tax team

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


Autumn Budget 2026: Analysis, Client Newsletter & Webinar

This year's Budget on 28 October will be significant: it will be the first delivered by Chancellor John Healey, coming just months into Andy Burnham's tenure as Prime Minister.

With a new leadership team setting fiscal policy for the first time, this Budget will be a key signal of the government's economic direction for the coming years, making it more important than ever for you and your clients to stay ahead of the field.

Our team of qualified accountants and tax advisers will work through the night to provide you with the tools you need to communicate with your clients and advise them immediately. 

  • Budget analysis: Sign up to the rossmartin.co.uk Practical Tax Resource now for access to our full Budget 2026 subscriber guides. 
    • Be kept up to date over the post-Budget days and weeks as Budget announcements take shape, the legislation 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 29 October. 
    • Order now at £290+VAT with additional discounts available for rossmartin.co.uk subscribers and 20:20 Innovation Platinum and Premier Plus members. 
  • Budget Update webinar: an accountants’ guide to the key announcements, with practical insights, planning strategies and more. Live at 12:30 on 29 October 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 £290+VAT with additional discounts available for rossmartin.co.uk subscribers and 20:20 Innovation Platinum and Premier Plus members.

Quick News 

Date announced for 2026 Budget
The Chancellor, John Healey, has announced that the 2026 Budget will be presented on Wednesday, 28 October 2026.

Has HMRC changed its view on interest relief for replacement capital?
A recent update to HMRC's Business Income Manual appears to cast doubt on the deductibility of interest incurred on borrowing used to fund capital withdrawals from a business, even where the proprietor's capital account remains in credit.

Incorrect pension tax treatment may result in double tax relief
The Low Incomes Tax Reform Group (LITRG) has published a report highlighting payroll errors in workplace pension tax relief, warning that confusion between Net Pay Arrangements (NPAs) and Relief At Source (RAS) schemes may be leading to incorrect tax relief, employer PAYE non-compliance, inaccurate HMRC data and risks to the government's forthcoming low-earner pension top-up scheme.  

Autumn Budget 2026 representations invited
HM Treasury is inviting representations from stakeholders ahead of the 2026 Autumn Budget on 28 October 2026. The portal for representations closes on 9 September 2026.

Employment-Related Securities Bulletin 67: July 2026 
HMRC have released Employment-Related Securities (ERS) Bulletin 67, which focuses on accessibility improvements to the ERS end of year templates, guidance and technical notes from 6 April 2027.


Tax Cases (subscription content)

The 'life' of a company for IHT
In Lexgreen Services Limited v HMRC [2026] UKUT 00289, the Upper Tribunal (UT) upheld the decision of the First Tier Tribunal (FTT) finding that a company had a ‘life’ for Inheritance Tax (IHT) purposes. This meant that a corporate settlor was liable to IHT arising on a non-resident trust’s ten-year anniversary.

Unsuccessful appeal for BPR on serviced offices
In The Executors of Keith Denis Lewis Beresford (Deceased) v HMRC [2026] UKUT 00285, the Upper Tribunal (UT) remade a First Tier Tribunal (FTT) decision, dismissing the Executors' appeal because a company's serviced office income was wholly or mainly investment income, refusing Business Property Relief (BPR).

FTT rejects HMRC's strike-out appeal in BADR dispute
In Scott Knight v HMRC [2026] TC09962, the First Tier Tribunal (FTT) refused HMRC's application to strike out an appeal against a closure notice which gave rise to a Capital Gains Tax (CGT) charge on an undeclared capital distribution. 


Editor's Choice

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

Pre-trading expenses (self-employed)
What are pre-trading expenses? What tax relief is available for pre-trading expenses? What are the restrictions on relief? What expenses will not qualify?

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

CGT: Value shifting
What is value shifting? When do the rules apply and what are the implications?


Guides & Updates 

New This Week 

Share matching rules for individuals and companies
How are shares identified for the purposes of calculating a chargeable gain?  What are the matching rules for individuals and companies?  How does the s.104 pool work?  Are there any exemptions? What happens on a share reorganisation? 

Self-employed  

MTD: Toolkit for accountants
What is the current timetable for Making Tax Digital (MTD)? When will MTD for Income Tax become mandatory? How will it work? Which clients will be excluded? What planning needs to be undertaken?

Converting part of a home into an office
What taxes need to be considered when converting part of a home to an office? What relief is available?

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

Distributions & striking off
What is the tax treatment of distributions made in the course of a company striking off? How much can a company distribute without it being treated as an income distribution? 

Employers

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. 

Capital Allowances

Cars, vans & other four-wheel vehicles: Capital Allowances
What capital allowances are available for cars, vans and other four-wheel vehicles? How does HMRC classify what is a car or what is a van?

Private Client & Estate Planning

Pensions: What happens when you die?
What happens to your pension when you die? Will your family have to pay Income Tax if they receive your pension in the future? What can you do to mitigate any tax charges? What are the new IHT rules on pensions for April 2027?

IHT: Estate planning checklist
This checklist covers some of the essential planning points that taxpayers should know when planning for their estate and Inheritance Tax (IHT).

Overseas & Residence

Transfer of Assets Abroad (ToAA)
What are the ToAA rules? When do they apply? How is the tax charge calculated? Is there any defence against the rules? 

VAT

Transfer Of a Going Concern (TOGC)
Buying a business and VAT, do you take over the previous owners' VAT registration? What is a Transfer Of a Going Concern (TOGC)? What conditions must be met? What are the consequences of a TOGC? 


Continuing Professional Development (CPD)

Recent and upcoming webinars include: 

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Missed the Last Tax Update?

Ross Martin Tax: SME Tax Update 30 July 2026

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