UK Tax Intelligence
The week in UK tax.
Curated from 120+ sources. Every Friday morning.
From September 2026, HMRC will proactively sign up unregistered sole traders and landlords required to use MTD for Income Tax. Practices must prepare clients for mandatory enrolment and associated filing obligations to avoid penalties.
HMRC has published guidance requiring taxpayers to notify of circumstance changes affecting their tax position. This creates a direct compliance obligation for clients and requires practices to establish processes ensuring clients understand and meet notification deadlines.
The First-tier Tribunal in Kane and White v HMRC clarified that agricultural fields acquired with a residential property can constitute taxable 'grounds' under SDLT section 116 if functionally occupied with the dwelling rather than self-standing. This establishes binding precedent on SDLT treatment of land ancillary to residential acquisitions, affecting valuation and relief claims for mixed-use property purchases.
The Upper Tribunal clarified whether woodland qualifies as part of a property's grounds for SDLT purposes under section 116(1)(b) Finance Act 2003, determining accessibility requirements. This binding judgment affects SDLT relief claims on residential properties with associated land.
The Tribunal in Janet Bray Ltd v HMRC held that inaccuracies in PAYE returns arising from employee benefit trust arrangements were caused by carelessness, establishing precedent on penalty liability for EBT-related errors. This clarifies HMRC's ability to assess penalties where loan transactions through sub-trusts create return inaccuracies, affecting advisers' exposure when structuring or reviewing EBT schemes.
Landmaster Investment Ltd v HMRC clarifies whether reserved rights to purchase residential property constitute taxable options or pre-emption rights under SDLT. The judgment provides binding authority on how to characterise acquisition agreements for SDLT purposes, directly affecting structuring advice and compliance obligations.