Latest Insights

After months of delay, HMRC’s new Loan Charge Settlement Scheme is finally in force. The Employment and Trading Income etc. (Loan Charge Settlement Scheme) Regulations 2026 came into force on **5 August 2026**, following the publication of HMRC’s detailed guidance on 17 July. For individuals and employers who have spent years trying to resolve disguised remuneration liabilities, there is now a formal route to settlement under the revised terms announced following Ray McCann’s review.

HMRC’s revised settlement terms for disguised remuneration cases remain unpublished, despite earlier indications that they would be released in the spring. For affected taxpayers and advisers, the continuing delay is frustrating and prolongs uncertainty in an area already marked by significant financial and personal strain. This update considers why revised, workable settlement terms are urgently needed, the unresolved issues arising from HMRC’s 2020 settlement approach, and the hope that the eventual guidance will provide a clearer and more pragmatic route to resolution.

HMRC can issue information notices to UK taxpayers outside the UK, but the practical risks often lie less in the validity of the notice and more in how the enquiry develops.

The Court of Appeal’s decision in HMRC v Bolt Services UK Ltd is not just a private hire vehicle case. It is a reminder that the Tour Operators Margin Scheme is a narrow VAT exception, not a general margin scheme for businesses that buy in and resell travel-adjacent or accommodation-related services. For businesses that have applied TOMS outside a conventional travel agency or tour operator model, the decision should prompt a careful review of the historic position, current VAT treatment, and exposure to future HMRC enquiry.

HMRC’s proposed expansion of the Uncertain Tax Treatment regime represents a potentially significant shift in tax compliance expectations for large businesses, high-net-worth individuals and trustees.

HMRC’s latest publication of deliberate tax defaulters is a timely reminder that film industry tax relief claims remain firmly under scrutiny, particularly where post-production arrangements appear artificial or inflated. The publication highlights the seriousness of HMRC’s current enforcement activity in this area and underlines the importance of ensuring that claims are supported by genuine commercial arrangements, robust documentation and defensible costings.

A small but important amendment to Incorporation Relief was included in the Autumn 2025 Budget, and many businesses may not yet be aware of its implications.

Following Ray McCann’s review of the Loan Charge and the recommendations set out within it, HMRC has now started to contact taxpayers who fall within scope of the new settlement terms.

The outbreak of conflict involving the US, Israel and Iran on 28 February 2026, and the wider instability that has followed across the region, has prompted many individuals and families living in the UAE to reassess their position. The conflict began with coordinated US-Israeli strikes on Iran on 28 February, and that it has since widened, affecting the Gulf more broadly and disrupting normal assumptions around regional stability. For many internationally mobile families, the question is no longer simply whether the UAE has been an effective base. It is whether, in light of recent events, they should remain where they are, relocate elsewhere, or return to the UK — and what UK tax consequences may follow from that next step, even if the relocation is only temporary. That is not a question to answer casually.

In November HMRC announced further details of its Strengthened Reward Scheme, following similar initiatives overseas. The scheme offers significant financial rewards for individuals who report serious tax avoidance or evasion.