Hello,
Did the Addison Lee founder's father make England his permanent home more than 60 years ago? In Sir John Griffin v HMRC, over £20 million of Income Tax turned on that question. This week, our summary explains how a father's domicile could still determine his son's tax position decades later and why the First Tier Tribunal (FTT) would have found against Sir John anyway. While the non-domicile regime ended in April 2025, disputes over earlier years are very much alive.
In another FTT decision we examine this week, Environmental Services Limited (ESL) v HMRC, a waste management company's R&D claim failed on two fronts. Similar to the Tanglewood Care Services Ltd case which we covered recently, the FTT found that ESL’s work, including modifications to a vehicle nicknamed 'the Hulk', was directed primarily at operational problem-solving, rather than seeking an advance in overall knowledge or capability in a field of science or technology. Even if the projects had qualified, ESL could not show how its directors' time and other costs related to them and the FTT made clear that apportioning costs was not its job. Our summary is essential reading for anyone preparing R&D claims for clients.
In other news, the Welsh Government plans to publish its 2027-28 draft Budget on 17 November 2026. This will be the first Welsh Budget since Wales was given the power to set its own Income Tax rates on property income from 6 April 2027. Welsh taxpayers with rental income will no doubt be keen to find out whether Wales intends to follow Westminster’s lead by setting Income Tax on property income at two percentage points above the main rates.
Finally, a reminder from our calendar of tax deadlines. Monday 5 October is the deadline for taxpayers who need to register for Self Assessment for 2025-26 to notify HMRC of their chargeability.
More news, cases and updates below.
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.
Leave the analysis to us and save serious time; our team of qualified accountants and tax advisers will read hundreds of pages of announcements, policy papers and consultations to bring you succinct summaries highlighting the changes that matter to you and your clients. This will ensure that your whole team is up to date, aware of the Budget impacts, and able to communicate the changes to your clients effectively.
- Budget analysis: Sign up to the Practical Tax Resources at rossmartin.co.uk 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.
- 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.
- Book your place now at £99+VAT per person.
- Comprehensive client newsletter: a branded Budget newsletter for your firm to send to clients. Delivered in PDF format by 7 am on 29 October.
- This includes firm-wide access to our Budget Update webinar above - book as many of your team as you wish.
- Order now at £290+VAT with discounts available for rossmartin.co.uk subscribers and 20:20 Innovation Platinum and Premier Plus members.
Quick News
Welsh Budget 2027-28 date announced
The draft 2027-28 Welsh Budget will be published on 17 November 2026, with the final Budget scheduled for 16 February 2027.
One-to-many letters: Tracker
HMRC's latest one-to-many 'nudge' letter targets trusts that may have made an error in their most recent trust and estate tax return by indicating they were not accumulation or discretionary trusts.
Tax Cases (subscription content)
Beneficial owner of property liable for CGT
In Jessbir Kaur v HMRC [2026] TC10006, the First Tier Tribunal (FTT) found that Mrs Kaur was 'absolutely entitled' to a property legally owned by her son. As the beneficial owner, she was liable to Capital Gains Tax (CGT) on the disposal of the property.
No green light for 'Hulk' R&D relief claim
In Environmental Services Limited v HMRC [2026] TC10015, the First Tier Tribunal (FTT) dismissed claims for R&D relief by a waste management company. The company did not show any scientific or technological uncertainty to be resolved and it failed to provide sufficient evidence to support the expenditure claimed.
Addison Lee founder domiciled in England
In Sir John Griffin v HMRC [2026] TC10016, the First Tier Tribunal (FTT) found that the Addison Lee founder was domiciled in England, upholding HMRC's closure notices for an additional Income Tax liability of more than £20 million.
Editor's Choice
This week's Editor's Choice was selected by Carrie-Anne Richards. You can meet our team of editors and writers here: Meet the team.
Winter Fuel Payment recovery
What is the Winter Fuel Payment (WFP)? What is the Pension Age Winter Heating Payment? Who receives it? When should it be repaid to HMRC? When should a taxpayer opt in or opt out?
Globally mobile employees: Short-Term Business Visitors
What is a Short-Term Business Visitor? What is an Appendix 4 agreement? What is an Appendix 8 agreement?
Globally mobile employees: National Insurance
What are an employer's National Insurance obligations when hiring an employee from overseas? What are an employer's Social Security obligations when sending an employee to work overseas? Are there any PAYE reporting requirements concerning National Insurance?
Guides & Updates
Self-employed
Losses (sideways): Restriction for uncommercial trades
What is sideways loss relief? What restrictions apply? When do they apply? What is an uncommercial trade?
Directors & Companies
Loans to participators (Close Company Loans toolkit)
What is the Corporation Tax treatment when a close company makes a loan to a participator (director-shareholder)? How do the 'bed and breakfasting' rules work? What are the concerns with indirect loans, upstream loans and MBOs?
Pre-trading expenses (companies)
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? What about pre-incorporation expenses?
Employers
CIS: Contractors and Subcontractors
What is the Construction Industry Scheme? Who does it apply to? How does it work?
PAYE Settlement Agreements
What are PAYE Settlement Agreements? How do they work? What can be included?
Capital Allowances
Structures & Buildings Allowance (SBA)
Who can claim the Structures and Buildings Allowance? What expenditure is eligible? How to make a claim?
Private Client & Estate Planning
IHT: Normal Expenditure Out of Income (gifts)
When is normal expenditure out of income exempt for Inheritance Tax (IHT)? How do you claim the exemption?
PRR: Private Residence Relief
What is Private Residence Relief (PRR)? What are the qualifying conditions? Can you claim relief on two homes? How do you claim PRR? Can you claim PRR if you develop your garden?
Penalties & Compliance
Penalties: Failure to Notify
What tax penalties apply if you fail to notify HMRC that you are chargeable to tax? Can they be appealed or reduced?
Calendar of tax deadlines and new tax measures
When do common recurring tax deadlines fall? What other tax significant events are upcoming? What do I need to remember this month?
VAT
Partial exemption & input VAT
How do you calculate the amount of input tax you can recover under the VAT partial exemption rules? What are the de minimis rules?
Continuing Professional Development (CPD)
Recent and upcoming webinars include:
- Budget Update - October 2026
- Practice Insight - October 2026 (free)
- Monthly Tax Update - October 2026
- Practice Insight - September 2026 (free)
- Monthly Tax Update - September 2026
- Practice Insight - July 2026 (free)
- Capital Gains Tax Planning Strategies to Maximise Net Proceeds (free)
- Mandatory HMRC Agent Registration Part 2 - Where We Are Now
- Ethics and PCRT for Tax Advisors
Need Tax Support?
Virtual Tax Partner© Support
Have a tax query? Need a second opinion? 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 24 September 2026
- Agent Update 147: September 2026
- HMRC announce details on mandatory payrolling from April 2027
- Additional functionality coming to agent and online service accounts
- HMRC write to contractors over incorrect CIS deduction rates
- Anti-circumvention rules confirmed for reduced cash ISA limit
- ABAB reports record response to survey
- Overnight Visitor Levy confirmed for England
- Companies House filings fatal to BADR claim
- Family Investment Companies
- Fall in Value Relief NEW ...More
Subscribe for news, guides & more
Subscribe now and unlock the site. Subscriptions begin at £57 (+ VAT) per month. All subscriptions are for a 12-month term.
What do you get?
- A comprehensive practical tax resource of guides, checklists, briefings and practice notes, and access to all our time-saving resources.
- A discount on Virtual Tax Partner services.
- Read everything in our comprehensive weekly SME tax news summary. We do the reading, then summarise legislation, HMRC guidance, analyse official reports and cherry-pick the best of the press and the rest.
- Commission guides and checklists for your own practice.