September 14th, 2026
Introduction Eighteen months after the most significant changes to the UK’s non-domicile regime in a generation, the first wave of disputes is beginning to reach the First-tier Tribunal. These cases offer early insights into how HMRC is interpreting the transitional provisions and where taxpayers may find themselves unexpectedly caught out. The April 2025 Overhaul The […]
September 10th, 2026
Corporate settlors and IHT – Introduction Do companies have a “life” for inheritance tax purposes? Deep, deep philosophical questions? Just a day’s work for the tax tribunal! The Upper Tribunal has confirmed that they do, closing an escape hatch that corporate settlors have relied upon to avoid secondary IHT liability on offshore trusts. In Lexgreen […]
September 6th, 2026
Trust nudge letter – Introduction If you’re a trustee who submitted a notice of intent to disclose undeclared tax liabilities but then failed to follow through, check your post. HMRC is writing to you, and the tone is less “friendly reminder” than “we haven’t forgotten.” The latest salvo in HMRC’s ongoing “one-to-many” letter campaign targets […]
September 5th, 2026
Automatic MTD sign-up – Introduction HMRC has fired a warning shot across the bows of hundreds of thousands of taxpayers this September: if you haven’t signed up for Making Tax Digital for Income Tax, the Revenue will do it for you. Whether you like it or not. The announcement, made in mid-August but taking effect […]
September 4th, 2026
HMRC error correction powers – Introduction HMRC has published draft legislation that would fundamentally change the relationship between taxpayers and the Revenue. Under the proposals, taxpayers would be legally obliged to correct errors in past tax returns, even errors made innocently, with failure to do so opening the door to assessments stretching back 20 years […]
