Other news in brief

HMRC have added synthesised text of the Multilateral Instrument and the 2015 UK-Senegal Double Taxation Convention and the 2011 UK-Armenia Double Taxation Convention to the collection of published tax treaties on their website. The synthesised text reflects the changes made to those treaties by the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly known as the Multilateral Instrument or MLI).

HMRC have updated their summary guidance on the Corporate Interest Restriction (CIR) rules and submitting a CIR return to reflect the main changes made by Finance Act 2026 (FA2026). In respect of CIR reporting companies, for periods of account ending on or after 31 March 2026, reporting company appointments are notified to HMRC in the CIR return (instead of appointing by submitting a separate form), and groups can retrospectively appoint a reporting company with no time limit.

As expected, following changes introduced by FA2026 affecting individuals (see our previous articles “Finance Bill: Other measures of note” and “Inheritance tax changes: APR and BPR allowances increased to £2.5m”), a large number of updates to HMRC guidance and manuals were published on 6 and 7 April 2026. Updated guidance on Inheritance Tax (IHT) Agricultural Property Relief (APR) was published which also covers Business Property Relief (BPR) to the extent that APR/BPR are combined for the 100 percent allowance. This guidance refers to HMRC’s updated Inheritance Tax Manual which includes a new section IHTM25500 on the APR/BPR 100 percent relief allowance and a new page IHTM25570 on the APR/BPR 50 percent relief for unlisted shares and securities. HMRC have also published a tool to calculate the 100 percent allowance and related updates to the Shares and Assets Valuation Manual. Separately, FA2025 introduced the new four-year Foreign Income and Gains (FIG) Regime and reform of the Domicile rules from 6 April 2025. FA2026 includes a number of amendments to these rules, some of which are reflected in updates to HMRC’s Residence and FIG Regime Manual, Remittance Basis and Domicile Manual and Investment Funds Manual. It is anticipated that further guidance and manual updates will be published on the FA2026 changes and, at the time of writing, we are still awaiting publication of HMRC guidance on the taxation of carried interest and IHT on unused pensions.  

FA2026 made changes to the ‘tainted charity donation rules’ which were first introduced by FA 2011 to prevent the abuse of the tax reliefs available to donors to charities and Community Amateur Sports Clubs. To reflect this, HMRC have added a new ‘Annex viii A: tainted charity donations on or after 6 April 2026’ to their detailed tax guidance for charities. Annexes i, ii and iii have also been updated with guidance around new charity compliance measures, particularly in respect of legacies, investments and the relationships between charities and their trading subsidiaries.