Tax Matters Digest

Next we move on to new measures to fix anomalies in the CGT gift holdover relief restriction on shares in relation to certain company assets. The measure was originally announced at Autumn Budget 2025 and could affect individuals gifting shares in ‘trading’ companies or holding companies of trading groups, where assets are held which are not used in the trade and assets are also held which qualify for the Substantial Shareholding Exemption, or are subject to the Intangible Fixed Assets regime.

After that we take a look at HMRC’s Call for Evidence in relation to PAYE Settlement Arrangements (PSAs). HMRC have stated that the exercise is not about changing how benefits and expenses are taxed, but it may inform future changes to PSA guidance, processes or compliance expectations. It therefore offers an opportunity for employers to feedback on PSAs and shape their future use.

The Tax Update 2026 documents also included a couple of items on ISAs – our article looks at both. Firstly, the surprisingly simple First Time Buyer ISA and, secondly, the cash ISA anti-avoidance rules which accompany the lowering of the cash ISA threshold from £20,000 to £12,000 as announced in Autumn Budget 2025.

We close off with three compliance focussed articles. The first looks at a consultation on fundamental reforms requiring more timely and frequent payments from Income Tax Self Assessment taxpayers from April 2029. The second looks at a targeted change to how Quarterly Instalment Payments are calculated when a business has income from Research & Development Expenditure Credits, Audio-Visual Expenditure Credits and Video Games Expenditure Credits. The final article in this section looks at a consultation proposing to introduce a criminal offence for making reckless or untrue statements in relation to direct tax matters. The proposals would broaden HMRC’s powers and give prosecutors and juries an alternative charge where dishonesty cannot be proved.

Other articles

A year on from the publication of HMRC’s Transformation Roadmap, HMRC have published an update. As a reminder, the Roadmap set out plans to improve day-to-day performance and the overall customer experience, close the tax gap, and reform and modernise tax and customs administration. Our article sets out the progress HMRC have reported.

Our case update in this edition focusses on the Supreme Court judgment in the BlueCrest Capital Management (UK) LLP case. The judgment provides important guidance on whether a UK LLP member is to be taxed as an employee or a self-employed partner.

Across the Channel in the EU, a number of significant measures are being discussed. The European Commission has published proposals to recast the Directive on Administrative Co-operation (DAC) framework. It has also published a ‘Tax Omnibus’ package which proposes amendments to some key EU Tax Directives. These measures will be ones to watch over the coming months.

Our final article provides a link through to Tim Sarson’s latest International Tax Review as published in Tax Journal which, this month, looks at the first Pillar Two GloBE Information Return filings, an AG opinion and Australia and New Zealand Budget measures.

We round off this bumper edition with our regular round ups. In Other News In Brief we provide updates on:

• HMRC’s Advance Tax Certainty Service which is now live;
• A Bill to increase rates of EGL, mileage allowance amounts and to temporarily reduce VED which has completed its Commons passage;
• The provisional scheduling of Supreme Court hearing dates for The Tower One St George Wharf Limited case which considers the scope of the SDLT anti-avoidance provisions;
• The Supreme Court has refused permission to appeal in the Muller LLP case; and
• The publication by the Fair Work Agency of a holiday pay compliance and enforcement consultation.

Finally, we include links to our regular Indirect Tax Weekly Talking Points and our Week in Tax publications.