Other news in brief

As expected, the new Advance Tax Certainty Service (ATCS) launched on 1 July 2026 and is now available to businesses planning to invest £1 billion or more in qualifying UK expenditure over a project's lifetime, who wish to apply for certainty on key tax issues. The new service covers the following taxes and schemes: corporation tax, VAT, stamp duty land tax, income tax, PAYE regulations and the Construction Industry Scheme. If a taxpayer is eligible to apply for a clearance under the regime, there is also the ability to apply for a view that there is a low risk of future compliance intervention in relation to the unallowable purpose rules. HMRC recently published their final guidance in the form of an ATCS manual which outlines the scope, process and eligibility requirements of the ATCS. Please speak to your usual KPMG in the UK contact for advice if your business is considering a large investment in the UK for which the ATCS may be applicable.

The Taxation (Energy and Vehicles) Bill was introduced into Parliament on 24 June 2026. It legislates for three previously announced measures related to fuel/energy and cost of living pressures: an increase in the rate of electricity generator levy (from 45 percent to 55 percent) and mileage amounts relating to income tax (from 45p to 55p for the first 10,000 miles) and temporary rates of vehicle excise duty for goods vehicles. The Bill completed its passage through the House of Commons on 1 July 2026 and is scheduled to complete the House of Lords stages on 14 July 2026. Like a Finance Bill, this Bill cannot be amended by the Lords, so these stages are a formality.

The UK Supreme Court recently granted The Tower One St George Wharf Limited permission to appeal the Court of Appeal's decision in The Tower One St George Wharf Limited v HMRC [2025] EWCA Civ 1588 which held that the stamp duty land tax (SDLT) anti-avoidance provisions in sections 75A–75C Finance Act 2003 applied to the relevant arrangements. Our analysis of the Court of Appeal's judgment can be found in our earlier article. The appeal is now provisionally scheduled to be heard in February 2027 and will provide the Supreme Court with an opportunity to consider the scope and application of these provisions. 

The Supreme Court decided on 29 June 2026 to refuse permission to appeal in Muller UK and Ireland Group LLP & Ors v Commissioners for His Majesty's Revenue and Customs [2026] EWCA Civ 248 because “the application does not raise an arguable point of law”. This case considered the deductibility for its corporate members of the amortisation of intangible assets held by a Limited Liability Partnership (LLP). The Court of Appeal decision, which is now final, was discussed in our earlier article.

The Department for Business and Trade is consulting on the proposed approach to holiday pay compliance and enforcement by the Fair Work Agency (FWA). The state enforcement of workers’ holiday pay rights from April 2027 will have a significant business impact on employers: both to ensure their compliance processes are robust, and in the cost and reputation consequences of any errors. Organisations should therefore consider engaging with this consultation to ensure their views are heard, and to calibrate their preparations for ensuring compliance with their holiday pay and other obligations enforced by the FWA. This consultation closes on 22 September 2026. We are currently considering our views on the proposals and what submissions we might make. Please contact your usual KPMG in the UK contact if you would like to discuss this further.