10 July 2026
The Supreme Court has refused permission for Muller UK & Ireland Group LLP to appeal a long-running tax dispute with HMRC, stating that the application did not raise an arguable point of law. The case concerned the acquisition of intangible fixed assets and goodwill by a limited liability partnership (LLP) from its corporate members, and in particular whether or not the corporate members were considered "related parties." The Court of Appeal held that the corporate members were related parties, and that consequently the assets transferred did not fall within the intangible fixed assets regime and no deduction for amortisation was available. The Court of Appeal decision, Muller UK and Ireland Group LLP & Ors v HMRC is now final.
HMRC’s Advance Tax Certainty Service was officially launched on 1 July and is now open for applications. HMRC have published a website, and a guidance manual. Once businesses have submitted a tax certainty application, HMRC aim to provide clearance within 90 days of submission. If granted, clearances will be binding for five years, subject to changes in facts and law. The HMRC team can be contacted via advancetaxcertainty@hmrc.gov.uk.
HMRC has published HMRC Transformation Roadmap - Progress Update 2026, an update on the Transformation Roadmap published in 2025, detailing the first year of advancements towards a simpler, more efficient, and automated tax and customs system. The update highlights significant progress in digital services, with 78% of customer interactions now digital and a substantial increase in HMRC app and Personal Tax Account users. It also covers developments in compliance, including the introduction of Making Tax Digital for Income Tax, and increased use of AI.
Yesterday, HMRC published their Annual Report and Accounts for the year to 31 March 2026. The section of the report on performance notes that HMRC collected revenues of £966.4 billion in 2025/26, an increase of £90.4 billion compared to the previous year. HMRC brought in over £50 billion of ‘compliance yield’, collecting tax revenues that would otherwise have been lost through error, fraud and other forms of non-compliance. The report also comments on progress HMRC has made in improving customer services, with more people getting through on the telephone to an HMRC advisor and calls being answered more quickly. The report acknowledges that there is further to go in improving customer service.
St Patrick’s International College Limited and two other institutions providing higher education, argued that their supplies of education services should be exempt from VAT under the direct effect of the EU Principal VAT Directive (PVD), or alternatively, in accordance with Group 6 of Schedule 9 to the Value Added Tax Act 1994 (VATA). Whilst it was common ground that the Appellants had similar educational aims to universities, colleges of universities and Further Education Corporations (FECs), the institutions were Alternative Providers (APs). Unlike Higher Education Institutions and FECs, APs are not included in VATA as ‘eligible bodies’ entitled to VAT exemption. As such, HMRC considered that exemption did not apply, with both the First-tier and Upper Tribunal agreeing with HMRC that the UK was entitled to treat APs differently given the different regulatory regimes that applied, and that there had been no breach of fiscal neutrality. However, the Court of Appeal has allowed the appeals. In addressing Ground 1, that of the incorrect implementation of the PVD into UK statute, the CA held that the FTT and the UT had erred in law in concluding that the test in Rank Group Plc (C-259/10 and C-260/10) – under which a difference in VAT treatment is a breach of fiscal neutrality if the supplies are identical or similar from the point of view of the typical consumer and meet the same consumer needs – does not apply to the ‘supplier condition’ in the education exemption. This conclusion was reached on the basis that the Court was bound by its previous decision in LIFE [2020] EWCA Civ 452 (regarding whether restricting the welfare exemption to certain categories of provider was compatible with fiscal neutrality). As Ground 1 succeeded, the Court did not rule on the Appellants’ alternative arguments. The appeals were allowed. (Contact: Laurie Pay)
HMRC have published a policy paper on the simplification of the Capital Goods Scheme. The measures, which are intended to reduce the administrative burden for VAT-registered businesses, remove computers and items of computer equipment from the list of assets covered by the scheme, and the expenditure threshold for land, buildings and civil engineering work will increase from £250,000 (exclusive of VAT) to £600,000 (exclusive of VAT). The measures come into force from 29 July 2026. Existing assets and expenditure incurred before that date will continue to be treated under the current rules. SI 2026/765: The Value Added Tax (Amendment) Regulations 2026 has been made to implement these changes. (Contact: Ben Tennant)
The next EMEA Dbriefs webcast will take place on Monday 13 July 2026 at 12.00 BST/13.00 CEST. In Global trade update: managing evolving supply chains, customs, and sustainability, we’ll explore the latest tax, trade and supply chain environment developments and their implications for businesses. Our panel will provide insight into recent changes and discuss how organisations can pro-actively manage customs risks. The webcast will cover US Tariff updates, EU customs reform, and import sustainability.
On Thursday 16 July 2026 at 12.00 BST/13.00 CEST, in Private company reward: Strategies from inception to maturity, our panel will discuss the increasing need for private companies’ reward strategies to be agile and deeply aligned with their growth trajectories and long-term ambitions.