Tax Matters Digest

Normal service has also been resumed in terms of the Scottish Budget announcement. A late 2025 UK Budget meant that the 2026-27 Scottish Budget took place in January this year; however, the Scottish Government has recently confirmed that the 2027-28 Scottish Budget will return to its usual pre-Christmas slot, this year on Thursday 3 December 2026.

So, lots to come later this autumn, but in the meantime we have updates to appeal to a range of readers in this September issue.

Our spotlight article explores the latest HMRC guidance for the new Tax Adviser Registration regime , which clarifies how the rules apply in more complex cases and provides procedural detail in relation to the regime’s sanctions and safeguards. Although registration applies to those acting on behalf of third parties, those engaging professional tax advice will find it helpful to understand the requirements facing their agents.

Those in the hotel and pub industry will be interested in our next article summarising the Government’s Call for Evidence which presents a unique opportunity for businesses to have a say on the methodology underpinning business rates assessments across the hospitality and leisure sector.

Sticking to the consultation theme, we then look at the issues HMRC sought to address in the recent consultation on the taxation of UK-resident individual members of US LLCs and other reverse hybrids, as well as sharing the key points KPMG raised in our consultation response.

From consultations to the Courts, our next article looks at the Upper Tribunal decision in Knights Developments that a non-UK resident developer’s profits from disposing of UK land were taxable in the UK. The case is a lead appeal so will have implications for other taxpayers. The approach the Tribunal took to treaty interpretation will also be of wider interest.

We then have a series of articles for employers. The first looks at HMRC’s new Guidelines for Compliance, which helpfully consolidate guidance on the tax, payroll and social security treatment of one of the higher risk compliance areas for employers and employees - short-term business visitors to the UK. The Fair Work Agency has published its first delivery plan and our next article looks at how it intends to bring together labour market enforcement functions currently carried out by separate bodies, including HMRC. Then we have an article exploring the complex tax valuation, payroll withholding, corporation tax, and other reporting obligations (which are at risk of being overlooked) when issuing cryptoassets as remuneration.

The Budget is never far away from our thoughts these days and in his CityAM column this month, Tim Sarson explores the connection between ‘vibes’ (or as economists prefer to call it, ‘sentiment’) and Budget announcements.

Other news in brief this week includes updates to two HMRC manuals to reflect Finance Act 2026 changes – the Corporate Finance Manual (specifically the corporate interest restriction rules) and the Multinational Top-up Tax and Domestic Top-up Tax manual (ownership and controlling interests, excluded entities and consolidated financial statements). We also cover the Oakwood Stamp Duty Land Tax case, where the taxpayer succeeded in a ‘not suitable for use as a dwelling’ argument.

Finally, following our summer break, we have a catalogue of indirect tax weekly Talking Points and Week in Tax editions for you, providing highlights and analysis of indirect and international tax developments.