This monthly briefing note summarises some tax and other news items of interest to UK-focused private companies and their management teams and shareholders.
United Kingdom | Deloitte Private | 30 September 2026
Chancellor delivers speech on growth
On 7 September 2026, Chancellor of the Exchequer John Healey MP delivered his Growth Speech, in which he set out his plan to drive growth across the UK. The government also published an accompanying press release. In his speech, Healey set out the government’s approach to growth, which includes partnerships with businesses to drive productivity and growth through more investment, innovation and jobs. The speech included a package of measures to tackle barriers to growth, including plans to reduce the number of government consultations. This is in line with the government’s new Simplification and Agency of Government approach, which seeks to reduce administrative burdens and encourage faster decision-making. There was little mention of tax policy in the speech, other than the reconfirmation of the government’s plans to set out a roadmap to fiscal devolution at the Budget.
HMRC guidance widens obligations for directors to report unpaid positions
HMRC have updated their Self-Assessment tax return guidance (SA150) and notes for employment pages (SA102 notes) concerning unpaid directorships. The revised SA150 guidance requires directors of almost any UK company, including dormant companies, to complete the SA102 pages, unless the position is an unpaid one for a registered charity or a community interest company. Previously, this was generally only required for directors receiving income. Detailed information, such as the company’s registration numbers and any shareholdings in the company are only required for directors of close companies.
HMRC manuals: substantial shareholdings exemption and EU-UK inbound migrations
On 19 August 2026, HMRC updated their Capital Gains Manual (see CG53080A) to set out their view that section 184J Taxation of Chargeable Gains Act 1992 (which applies when a company migrates to the UK from the EU and its assets were subject to an EU exit charge) does not constitute a ‘deemed disposal and reacquisition’ for the purposes of the substantial shareholdings exemption’s holding period requirement.
The updated manual page states that “the holding period is not affected where a company migrates to the UK and has been subject to an “EU exit charge” and is treated as acquiring its assets at market value for corporation tax purposes under section 184J TCGA 1992. That rule does not provide for the deemed disposal and reacquisition as required by TCGA1992/Sch7AC/Para11.”
Environmental Services Limited: waste management activities did not amount to R&D
The First-tier Tribunal (FTT) has dismissed the taxpayer’s appeal in the research and development (R&D) tax relief case Environmental Services Limited v HMRC. Environmental Services Limited (‘ESL’), a waste collection and transportation business, appealed against HMRC's closure notices for the periods ending 31 July 2020 and 31 July 2021, disallowing its claims for R&D tax relief in respect of two interlinked projects. ESL submitted that the projects were not routine waste-management activities and instead involved experimentation to solve technological problems concerning the handling and transportation of complex waste streams.
The FTT first considered whether ESL had demonstrated that it had undertaken R&D within the meaning of the relevant legislation and the Business, Energy, Innovation and Skills (BEIS) Guidelines. The FTT held that ESL undertook practical problem-solving in response to operational and commercial challenges rather than projects directed towards achieving an advance in science or technology. The resulting improvements were to ESL’s operations rather than to the underlying field of waste management technology. Therefore, ESL did not establish that the activities amounted to R&D. Even if the projects had constituted qualifying R&D activities, the FTT also concluded that ESL had not established the amount of qualifying expenditure for which relief could be claimed.
Cogefin: Bermuda-incorporated company was UK resident
On 30 July 2026, the First-tier Tribunal (FTT) issued its decision in the corporation tax case Cogefin (Bermuda) Limited & Anor v HMRC. The FTT dismissed the substantive appeal on residence but partially allowed the appeal in relation to penalties and allowed the appeal against a personal liability notice. The key issue was whether a Bermuda-incorporated company (‘Cogefin’, the first appellant) was resident in the UK by virtue of UK domestic case law, i.e. whether its place of ‘central management and control’ was in the UK. In its decision, the FTT sets out detailed findings of fact on how the company was managed and controlled, and compares the role of the company’s Bermudian-resident directors, who worked for a local law firm, with the involvement of a UK-based individual (‘Mr Ciardi’, the second appellant), the economic settlor and beneficiary of the trust that owned the company. Mr Ciardi was not a director of Cogefin and was self-described as an ‘investment advisor’ to the company.
The FTT found that the strategic, high-level, decision making of the business rested with Mr Ciardi and not with Cogefin’s directors, who did not make the relevant decisions at the level required for central management and control to be located in Bermuda. Instead, the directors (or the administrative staff working with them) undertook administrative functions to ensure that Cogefin could and did undertake Mr Ciardi’s proposals. The “very few instances” where the directors appeared to have made a relevant decision were insufficient to render Cogefin dual resident in the UK and Bermuda. As a result, Cogefin was resident in the UK only.
RCB 8 (2026): VAT refunds for non-UK businesses in a VAT group
HMRC have published Revenue and Customs Brief 8 (2026) (RCB), on changes to how non-UK businesses that are members of a VAT group outside the UK claim refunds of UK VAT. A non-UK business is a business that is not UK VAT-registered, does not have a business establishment or a fixed establishment in the UK, and does not make supplies in the UK. Before 1 January 2021, EU-established businesses that were part of a non-UK VAT group could submit UK VAT refund claims in their own name, but non-EU-established businesses had to submit claims through their VAT group’s representative member. From 1 January 2021, all non-UK businesses that were members of a VAT group had to submit claims through the representative member. In some cases, such as where the representative member was UK VAT-registered, the non-UK business was not able to claim a VAT refund. HMRC’s policy has now changed, and non-UK businesses that are members of a VAT group must submit their own UK VAT refund claims, not via the representative member. As a transitional measure, HMRC will accept claims for VAT incurred in the 2025/2026 year (1 July 2025 to 30 June 2026), due by 31 December 2026, from either the business that incurred the VAT or the representative member. HMRC have also said that they will review refund claims for VAT incurred from 1 January 2021 that were rejected because the representative member did not submit the claim, provided the business asks HMRC to do so before 31 August 2027. The RCB includes details of how to ask HMRC to review a claim. VAT Notice 723A, Refunds of UK VAT for non-UK businesses, has been updated accordingly. This is also a timely reminder to submit claims for the 2025/2026 year by 31 December 2026. (Contact: Alistair Lord)
Revenue and Customs Briefs
HMRC have published Revenue and Customs Brief 7 (2026) on changes to the VAT Capital Goods Scheme (CGS). From 29 July 2026, computers and items of computer equipment have been removed from the list of assets covered by the CGS, and the expenditure threshold for land, buildings, and civil engineering work has increased from £250,000 (exclusive of VAT) to £600,000 (exclusive of VAT). HMRC’s VAT Notice 706/2, Capital Goods Scheme, has also been updated.
HMRC have also published Revenue and Customs Brief 9 (2026) (RCB), on the VAT treatment of supplies of education by alternative providers of higher and further education, following the Court of Appeal’s decision in St Patrick’s International College Limited & Ors that VAT exemption applied to services supplied by St Patrick’s and two other higher education providers, even though they were not ‘eligible bodies’, on the basis of fiscal neutrality. The RCB states that HMRC policy remains that exemption does not apply to supplies of education by providers that are not ‘eligible bodies’. HMRC have been granted permission to appeal to the Supreme Court, but recognise that businesses may want to protect their position pending the outcome of the appeal, so alternative providers that consider themselves to be in the same position as St Patrick’s International College can submit a claim for a refund of VAT, which HMRC will review on a case-by-case basis.
HMRC publish Guidelines for Compliance 20: Help with VAT on fund management services
HMRC have issued a new Guidelines for Compliance (GfC), Help with VAT on fund management services — GfC20. The GfC sets out HMRC’s recommended approach to determining the VAT treatment of outsourced fund management services, and in particular, whether such services should be treated as a single supply or multiple supplies. Fund managers frequently outsource fund management services to third parties, often under master service agreements (MSAs), with separate contracts for more detailed information regarding services and fees for individual funds.
The GfC states that a supply of services by a third party to a fund manager is only VAT exempt if the fund is a ‘qualifying fund’ and the services form a distinct whole that is specific to and essential for the management of that qualifying fund. This places significant focus on the single/multiple supply analysis, given that each supply can only have a single VAT liability – and many taxpayers will be looking to avoid a situation where a single supply of management services is made in relation to both qualifying and non-qualifying funds, resulting in the whole supply being treated as taxable. The GfC sets out four indicators to consider in determining whether a supply with multiple elements constitutes multiple supplies, namely: the number of suppliers; the view of the typical customer; the contractual terms and economic reality; and the legislative intention (that is, “these rules must not be used to extend the VAT exemption beyond what the law allows”). The GfC concludes that businesses providing fund management services can use the guidelines to help determine whether the supply of services is a single supply or multiple supplies, and then apply the VAT exemption rules accordingly. (Contact: Alex Beattie)
Pillar Two: subject to tax rule multilateral instrument entry into force
The OECD has announced that the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) will enter into force on 1 January 2027. The subject to tax rule (STTR) is a model treaty provision, agreed by the G20/OECD Inclusive Framework on BEPS as part of its work on Pillar Two, that is designed to allow developing countries to amend their tax treaties such that they can impose taxation at source on many cross-border payments. The payments affected are those between connected companies where the recipient is subject to a statutory or regime corporate tax rate below 9%.
The STTR MLI is intended to facilitate the implementation of the STTR within relevant existing bilateral tax treaties, however changes will only be made once both treaty partners to a specific bilateral tax treaty have taken the required steps to ratify the convention.
Pillar Two: updated information return and further administrative guidance
On 11 September 2026, the G20/OECD Inclusive Framework published a collection of documents in relation to the Pillar Two global minimum tax rules. These include an updated GloBE information return (GIR) template for use for 2026 year ends onwards, further administrative guidance to address (i) the treatment of ‘explicitly conditional taxes’ and (ii) the use of local financial accounting standards under a qualified domestic minimum top-up tax (QDMTT), and the terms of reference and methodology for the full legislative review of countries’ implementing legislation. Further details are in Deloitte’s alert.
HMRC publish corporation tax statistics
HMRC have released the latest edition of their annual national statistics publication, Corporation Tax Statistics. The publication provides details and breakdowns of UK corporate tax amounts (which for these purposes also include bank surcharge, bank levy, residential property developer tax, energy profits levy, and electricity generator levy amounts) covering receipts received up to the 2025-26 tax year, and tax liabilities up to the 2024-25 tax year. Total receipts from all corporate taxes increased by 4% in 2025-26 to £100.4 billion, which HMRC attribute largely to a strong post-pandemic recovery, the increase in the main rate of corporation tax to 25% in April 2023, and the introduction of new corporate taxes and levies. A breakdown of corporation tax receipts by sector shows that the financial and insurance sector remained the single largest contributing sector.
HMRC publish creative industries tax relief statistics
On 17 September 2026, HMRC also published their creative industries tax relief statistics for financial years up to 31 March 2025. The statistics include the number and value of claims for film, high-end TV, animation, children’s TV, video games, theatre, orchestra, and museums and galleries exhibition tax reliefs. The latest statistics also include claims made for the new audio-visual expenditure credits (AVEC) and video game expenditure credits (VGEC). In 2024/25 a total of £2.45 billion of relief was paid out across all creative industries tax reliefs and expenditure credits, with over a third (38%) attributable to high-end TV tax relief (including AVEC) and 29% to film tax relief (including AVEC and independent films).
EMEA Dbriefs webcasts
The next EMEA Dbriefs webcast will take place on Tuesday 6 October 2026 at 12.00 BST/13.00 CEST. In Leading the future of tax with AI, hosted by Frankie Jell, we will consider what the tax function will look like in 2030, and what leaders should be doing today to prepare. We will discuss the rise of agentic compliance; the future of tax administrations, including digital audits, real-time reporting, e-invoicing and machine-to-machine interactions between taxpayers and authorities; how leading organisations are reimagining the tax operating model; the future of the tax workforce; the use of data, AI and emerging technologies to provide strategic business insights; and practical actions tax leaders can take now.