HMRC clearances

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FORTHCOMING CHANGE relating to new advance clearance processes: Following an initial announcement at Autumn Budget 2024 as part of the government’s Corporate Tax Roadmap, which was followed by a consultation published at Spring Statement 2025, at Budget 2025 the government published a consultation outcome and confirmed that HMRC will launch a new advance tax certainty service in July 2026. The new service is expected to apply for qualifying persons investing in ‘major projects’ involving at least £1bn of in-scope UK expenditure. The Budget 2025 announcements indicated that the service will cover a specified range of taxes including corporation tax, VAT and stamp taxes, but will exclude transfer pricing, valuation and purpose-based tests and hypothetical scenarios. Clearances will bind HMRC (but not the taxpayer) against changing its interpretation of the law, as applied to fully disclosed facts, for up to five years, subject to unchanged facts and law, with pragmatic renewal. No fees or publication of anonymised clearances will apply initially. Legislation is introduced in Finance Bill 2026 for this

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Latest Tax News

Tax weekly highlights—11 December 2025

This week's edition of Tax weekly highlights includes: (1) News Analysis on the new measures contained in Finance Bill 2026 (FB 2026) to tackle the promotion of marketed tax avoidance schemes, (2) News Analysis on publication of the Final Report of the independent review of the Loan Charge and the government’s response to that Report, (3) News Analysis on the FB 2026 measure that provides an SDRT relief for new UK listings, (4) News Analysis on the FTT’s refusal to allow amortisation deductions for goodwill created by a predecessor partnership in County Insurance Services Ltd v HMRC, and (5) News Analysis on the FTT’s finding that mixed-use SDLT rates applied to the acquisition of an apartment with a basement storage unit in Sehgal v HMRC.

Finance Bill 2026—UK listing relief—Stamp duty reserve tax holiday for new listings

Tax analysis: Natasha Kaye, partner at Akin Gump Strauss Hauer & Feld, highlights the key features and practical considerations of the new stamp duty reserve tax (SDRT) UK listing relief announced at Budget 2025 and brought into effect that day.

Finance Bill 2026—Loan charge review: Final Report and government response

Tax analysis: The Final Report of the independent review of the Loan Charge, together with the government’s response to the Final Report, were both published at Budget 2025, with Finance Bill 2026 containing provisions in respect of the accepted recommendations. Jackelyn West, a senior associate in Macfarlanes’ tax disputes team, sets out the key outcomes of the Final Report and government response below.

Finance Bill 2026—Closing in on promoters of tax avoidance schemes

Tax analysis: The government is legislating in Finance Bill 2026 for new measures to tackle the promotion of marketed tax avoidance schemes. Abigail McGregor and Ian Robotham, Legal Directors in Pinsent Masons’ Contentious Tax team, analyse the measures and consider their practical consequences.

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