10 April 2026
Finance Act 2026 – Royal Assent
The remaining Lords stages of Finance (No. 2) Bill 2024-26 took place on 17 March 2026. The Lords do not amend Finance Bills, and so the Bill was approved unamended from the version passed by the Commons on 11 March 2026. The Bill received Royal Assent on 18 March 2026 and has now become Finance Act 2026.
Updated Company Tax Return and new creative industries supplementary page published
HMRC have published updated versions of the Company Tax Return Form (CT600) and its accompanying guide for the start of the new financial year. A new supplementary page relating to creative industry tax reliefs (CT600P) has been published, as well as updated versions of the CT600L (research and development), CT600A (close company loans and arrangements to confer benefits on participators), and CT600E (charity and Community Amateur Sports Clubs) supplementary pages.
Consultation: corporate re-domiciliation
The Department for Business and Trade has published a predominantly non-tax consultation on detailed design proposals for an inward UK corporate re-domiciliation regime, based on the recommendations in the 2024 report of the UK Independent Expert Panel on corporate re-domiciliation. An initial consultation took place in 2021. Re-domiciliation would enable a foreign-incorporated company to change its place of incorporation to the UK while maintaining its legal identity. Currently, alternative routes must be taken, involving the creation of a new UK entity.
The government states that it will consider what changes might be required to tax legislation once the re-domiciliation framework legislation has been finalised. In the meantime, the government welcomes comments on the independent panel’s considerations in this area. The consultation closes on 19 June 2026.
Consultation: reporting payments between close companies and participators
In line with the government’s announcement at Budget 2025, HMRC have published a consultation exploring proposals to mandate the reporting to HMRC of transactions between close companies and their participators. HMRC are seeking views on the scope of the transactions to be included and the information that would need to be reported, including the format and timing of submissions. The call for evidence closes on 10 June 2026.
HMRC manuals: Construction Industry Scheme fraud
HMRC have added a section to their Construction Industry Scheme Reform Manual (see CISR85000) on new HMRC powers to tackle fraud within the Construction Industry Scheme (CIS). The powers, which were enacted in Finance Act 2026, came into effect on 6 April 2026. The new section includes a list of indicators which, in HMRC’s view, suggest that a business ‘knew or should have known’ about the relevant deliberate compliance failure by another person in the supply chain. It also covers determinations and penalties under the new rules, as well as HMRC’s power to immediately cancel a person’s gross payment status.
Call for evidence: small and medium-sized businesses’ systems integration
HMRC have opened a new call for evidence titled Business Systems Integration. The intention is to gather views on the role business systems integration could play in making it easier for businesses to keep records, and identify how the government can support better uptake and availability of integrations between the systems businesses already use. The government does not anticipate introducing requirements for businesses to integrate their systems. The call for evidence closes on 4 June 2026.
Call for evidence: reform of advance corporation tax
In 1999, advance corporation tax (ACT) was abolished, and a mechanism introduced to allow businesses with 'unrelieved surplus ACT' balances to obtain relief against corporation tax in subsequent accounting periods in certain circumstances. This mechanism, inter alia, introduced the ‘shadow ACT rules’, which were designed to limit the amount of relief a business could obtain to pre-abolition rates.
In line with the government’s announcement at Budget 2025 that it would consult on the future of the remaining ACT regime in early 2026, HM Treasury has published a call for evidence exploring its potential abolition from April 2029. As previously reported (see previous Business Tax Briefing), the shadow ACT rules are repealed for accounting periods ending on or after 1 April 2026.
Colchester Institute Corporation: Further education business activities
In 2024, the Upper Tribunal (UT) held that the provision of further education by Colchester Institute Corporation (the College), funded by government agencies, was the supply of services for consideration (and not a non-business activity, as had previously been considered to be the case). This decision followed a 2020 UT decision between the same parties on related issues impacting the further education sector. HMRC challenged both decisions, and the Court of Appeal (CA) has now found in favour of the College.
HMRC appealed the UT decisions on two grounds. First, that the UT erred in its analysis of the CJEU judgment Le Rayon d’Or Sarl, in which it was held that a lump sum paid by a state sickness insurance fund to care home providers constituted consideration for the supply of healthcare provided by those homes to residents, and was within the scope of VAT. The CA agreed with HMRC that Rayon d’Or did not itself determine the appeal in the College’s favour, as the UT had concluded. The CA did, however, reject HMRC’s argument that the case provided no support to the College’s case. HMRC’s second ground was that the UT had erred in interpreting and applying the requirement for a ‘direct link’ between the supplies made and the consideration received. (The UT had gone on to consider the merits of the College’s case in the event that Rayon d’Or was not determinative of the appeal.) The CA reviewed the funding arrangements and other factors and concluded that the government agencies were providing funds in return for the provision of services by the College to students in the form of approved courses, and not funding the College generally on condition it provide such courses. Accordingly, the CA rejected HMRC’s second ground, and dismissed the appeal.
EMEA Dbriefs webcasts
We have three Dbriefs tax webcasts over the next month: Platforms and GenAI: How can tax and legal teams provide strategic value? (14 April 2026), Post Merger Integration (“PMI”) – key considerations (16 April 2026), UK tax update - April (22 April 2026). Please visit our Dbriefs website for more information, and to view any other recent webcasts on demand.