9 October 2026
The Trader Support Service (TSS) is an HMRC service providing support for businesses moving goods between Great Britain and Northern Ireland under the Windsor Framework. HMRC have reminded businesses that the new TSS platform goes live from 20 October 2026. From that date, all such goods movements must be submitted on the new TSS platform. Businesses registered for the TSS will receive emailed instructions from HMRC on how to pre-enrol for the new platform and access a test environment where they can familiarise themselves with how the new platform works.
In the latest in a series of First-tier Tribunal (FTT) cases on eligibility for research and development (R&D) tax reliefs, the FTT found that RDM Wines Ltd (RDM) had not discharged the burden of proof to show that its activities sought an advance in science or technology beyond the level already deducible by a competent professional in the field. Therefore, RDM did not meet the eligibility requirements for R&D tax relief and the taxpayer’s appeal against HMRC’s Closure Notice was dismissed. In particular, the FTT considered case law concerning witness evidence and the reliability of memory, and the importance of contemporaneous documentation and known or probable facts.
HMRC have published their annual report on the operation of the Code of Practice on Taxation for Banks (the Code). The Code describes the approach expected of banks with regard to governance, tax planning and engagement with HMRC. Banks operating in the UK that sign up to the Code commit to adopt good practices in relation to their own tax affairs, and not to promote tax avoidance by others. The 2026 annual report confirms that none of the 315 banks that had adopted the Code at 31 March 2026 were determined to have breached the code during the period. Six banks within the Code population had not adopted the Code at 31 March 2026. Of the 35 banking groups that were subject to HMRC’s Large Business directorate Business Risk Review (BRR+) process during the period, one bank’s compliance with the Code remains under review. All other reviews under the BRR+ process were concluded with no current concerns.
HMRC have published a consultation on the draft legislation and supporting document for the Plastic Packaging Tax (PPT) mass balance approach (MBA) for chemical recycled plastic. The draft Regulations set out the detailed provisions and conditions that businesses must meet if they wish to use an MBA to account for chemically recycled plastic for PPT purposes from 1 April 2027. This includes requirements relating to attribution methodology, certification, auditing, monitoring and record keeping. The draft reference document sets out the methodology for applying dual-use factors where required. The default values will be confirmed before the final legislation and reference document are published. The consultation seeks views on the draft legislation and supporting document to ensure they deliver the policy as intended. The consultation closes on 21 December 2026.
This dispute concerned HMRC assessments for overclaimed input tax issued against Victoria Oil & Gas Plc (VOG). VOG, a holding company, made supplies for consideration in the course of an economic activity to its overseas subsidiaries (collectively GdC). Such supplies would have been taxable if made in the UK and therefore gave a right to VAT recovery. The principal issue before the First-tier Tribunal was whether the VAT incurred was directly and immediately linked to the supplies made to GdC, or rather, to charges made to other subsidiaries which constituted a non-economic activity, and therefore whether VOG’s business was wholly taxable entitling it to full VAT recovery. Before addressing the substantive issue, the FTT first considered whether the assessments were made to HMRC's “best judgment”. The FTT found that the HMRC officer, having repeatedly sought information over an extended enquiry and received inconsistent explanations, undertook an honest and genuine attempt at a reasoned assessment. As such, the assessments were valid as best judgment. In respect of the principal issue, the FTT found that costs recharged in respect of the management, administration and operation of GdC, and the costs relating to litigation/disputes affecting GdC's business, had the requisite direct and immediate link to VOG's taxable supplies to GdC and were recoverable. However, other litigation and legal costs not linked to GdC’s business were not recoverable as no evidence established a reciprocal taxable supply. Consequently, in respect of the “wholly taxable” issue, the FTT concluded that, although GdC was the group's only revenue-generating asset, VOG also incurred costs and devoted resources to other non-productive subsidiaries without consideration or expectation of remuneration. Given this non-economic activity, VOG was not entitled to recover all the VAT incurred. The appeal was allowed in part, with the parties left to agree the apportionments.
The next EMEA Dbriefs webcast will take place on Monday 12 October 2026 at 13.00 BST/14.00 CEST. In UK Carbon Border Adjustment Mechanism we will discuss the implications of the UK Carbon Border Adjustment Mechanism (CBAM) for your business and supply chain. We will cover the key features of UK CBAM, implications for UK and non-UK businesses, and lessons from EU CBAM.
On Wednesday 14 October 2026 at 12.00 BST/13.00 CEST, Alison Lobb will be hosting Beyond Compliance: From Surviving to Thriving in a Pillar Two World. We will explore what Pillar Two may look like over the next three to five years, considering how the legislative landscape, data requirements, technology solutions and tax operating models are expected to evolve. We will discuss how organisations can transition to a more efficient business-as-usual approach while managing compliance costs and creating greater value.