Missed our SME Tax Updates in December? Here is a summary of the month.
SME Tax News
Hello,
This week, the Scottish Budget has been released. Other highlights include a First Tier Tribunal (FTT) decision on whether an e-learning training platform qualified for Research & Development (R&D) relief, and updates to HMRC’s List 3 (approved professional organisations and learned societies).

In Philip Cox and Debra Cox v HMRC [2026] UT000114, the Upper Tribunal (UT) found that HMRC's decision-making in refusing to suspend penalties applied for an inaccurate Business Asset Disposal Relief claim was not flawed.

In Afzal Alimahomed v HMRC [2025] UKUT 00428, the Upper Tribunal (UT) found that bank transfers from an offshore account to UK recipients amounted to taxable remittances, but the First Tier Tribunal (FTT) had erred in its treatment of offshore credit card transactions.

Over the last six months, HMRC have regularly updated ‘List 3’, its list of approved professional organisations and learned societies. Several new organisations have been added.

Shona Robison MSP, Cabinet Secretary for Finance and Local Government, presented her 2026-27 Budget to the Scottish Parliament on Tuesday, 13 January 2026. Key announcements included above-inflation increases to the Basic and Intermediate rate Income Tax thresholds for 2026-27, and new Council Tax bands from 1 April 2028 for residential properties valued at over £1 million.

Hello,
The start of 2026 has proven to be busy in the world of tax. This week, our news includes a significant update on the imminent reform to Inheritance Tax (IHT), the date of the 2026 Spring Forecast, a decrease in HMRC’s late payment interest rates in time for the upcoming self-assessment payment deadline and its December Agent Update.

In M&C Educational Training Services Ltd v HMRC [2025] TC09709, the First Tier Tribunal (FTT) found that expenditure on an e-learning training platform related to an advance in education, a social science, and did not qualify as Research and Development (R&D) expenditure for the purposes of claiming relief.

The government has announced that the proposed cap to the 100% rates of Agricultural Property Relief (APR) and Business Property Relief (BPR), which is due to apply from 6 April 2026, will be increased to £2.5 million from the £1 million previously announced.

Following the Bank of England’s announcement on 18 December 2025 that the base rate would decrease to 3.75%, HMRC's interest rates are also decreasing by 0.25%, to 7.75% for late payment interest and 2.75% for repayment interest, from 9 January 2026.
