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The government is launching a targeted programme to simplify areas of the Corporation Tax system where complexity, overlapping regimes and reporting requirements may create unnecessary costs and uncertainty for businesses. The programme builds on the 2024 Corporate Tax Roadmap and will consider changes to guidance, administration and legislation with the aim of supporting business investment, growth and competitiveness. The government will prioritise reforms according to their potential simplification benefits, fiscal impacts, competitiveness and deliverability.
Areas for further work include treaty relief from withholding tax on interest, controlled foreign companies, anti-hybrid mismatch rules, interest deductibility, research and development (R&D) reliefs and their administration, capital allowances, Patent Box, the intangible fixed assets regime, and wider Corporation Tax administration and reporting requirements.
The government also intends to repeal the existing international movements of capital requirement for information to be reported separately within six months of a relevant transaction or event. It will consider whether any of this information should instead be provided through other reporting methods.
The consultation applies to entities subject to Corporation Tax.
Between November 2026 and April 2027, the government will work with businesses and other stakeholders to refine the policy concerns, prioritise them, develop potential solutions and test emerging approaches. Between May and September 2027, it will develop detailed proposals for the highest-priority areas and undertake a final round of technical consultation ahead of a future fiscal event.
Stakeholders wishing to contribute to the programme are invited to express their interest by 21 November 2026.
This is a welcome focus on some of the more compliance-heavy areas of the UK tax landscape. The breadth of the programme is particularly notable: rather than considering individual rules in isolation, it recognises the cumulative complexity that can arise from overlapping regimes and reporting requirements. That approach could provide meaningful simplification if it results in well-targeted changes to legislation, guidance and administration.
The review of controlled foreign companies and anti-hybrid mismatch rules in the context of Pillar Two could be particularly relevant to multinational groups. The government is not proposing to remove these regimes but is considering whether aspects can operate more proportionately alongside Pillar Two. The work on R&D reliefs, Patent Box, intangible fixed assets and capital allowances could also address areas where detailed rules or administrative processes create uncertainty for businesses investing and innovating in the UK.
The practical impact will depend on which potential reforms the government prioritises and how the detailed proposals develop. Businesses affected by the areas under review may therefore wish to engage with the programme as proposals are refined.