15 May 2026
King’s Speech 2026
As part of the State Opening of Parliament, the King’s Speech was delivered on 13 May 2026 setting out the government’s legislative agenda for the second session of the current Parliament. Tax policy announcements are typically reserved for Budget statements and so taxation did not feature heavily in the speech.
Details of 34 new Bills and three Draft Bills to be taken forward in this session are included in the speech’s background briefing notes. The Bills include an Overnight Visitor Levy Bill, to “provide a legislative framework to enable mayors and potentially other local leaders to introduce a levy”, as well as an Electricity Generator Levy Bill to enact the previously announced increase in the rate of the electricity generator levy (EGL) (see previous Business Tax Briefing). A European Partnership Bill will also be introduced to “deliver the manifesto commitment to improve the UK’s trade and investment relationship with the EU by facilitating the implementation of new deals agreed with the EU now and in the future.”
HMRC guidance: Advance Tax Certainty Service
On 12 May 2026, HMRC published a new guidance page on the Advance Tax Certainty Service for major investment projects. Broadly, the service will be available for projects with qualifying UK expenditure of at least £1 billion. The guidance confirms that the service will launch on 1 July 2026, with expressions of interest accepted from 1 June 2026 via email to advancetaxcertainty@hmrc.gov.uk or the business’s Customer Compliance Manager (CCM). Following the expression of interest, an early engagement meeting with HMRC will be scheduled before a clearance is formally submitted in writing.
HMRC manuals: transfer pricing reforms – intangible fixed assets
HMRC have updated their Corporate Intangibles Research and Development Manual (see 24 April 2026 update) for changes to the intangible fixed assets legislation that were included in Finance Act 2026, and formed part of the transfer pricing reforms consulted on in Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax. For further details see our previous alert.
HMRC publish MLI synthesised texts of UK tax treaties with Bahrain and Cote D’Ivoire
HMRC have published new ‘synthesised texts’ showing how the operation of the 2012 UK-Bahrain Double Taxation Convention and the 1985 UK-Cote D’Ivoire (formerly known as Ivory Coast) Double Taxation Convention are modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’).
First-tier Tribunal finds in favour of taxpayer in SDLT group relief decision
The First-tier Tribunal (FTT) has found in favour of the taxpayer in the Stamp Duty Land Tax (SDLT) group relief case HC-One No.1 Limited. The case considers the SDLT consequences of a corporate reorganisation undertaken by the BUPA corporate group, alongside the unwind of an existing securitisation structure, as part of the divestment of certain care homes. The properties were first transferred intra-group from various operating companies (OpCos) to HC-One No.1 Limited, a newly formed subsidiary intended to serve as the sale vehicle. Group relief from SDLT was claimed on each transfer. Subsequently, the shares in HC-One No.1 Limited were sold to an unrelated third-party. Immediately prior to the sale, a parent company of the OpCos was placed into members' voluntary liquidation.
HMRC contended that the intra-group transfers formed part of arrangements of which a main purpose was the avoidance of SDLT, such that the targeted anti-avoidance provision (Schedule 7 paragraph 2(4A) Finance Act 2003) applied. Alternatively, HMRC contended that the anti-avoidance provision in section 75A Finance Act 2003 applied to recharacterise the transactions. The FTT concluded that the liquidation of the parent company to preserve group relief did not constitute tax avoidance and therefore allowed the taxpayer’s appeal on the main purpose issue. In the FTT’s view, the exclusion from the clawback of group relief where the purchaser ceases to be a member of the same group as the vendor by reason of the winding up of the vendor or a company above it is “unconstrained” and “not limited to insolvent liquidation or liquidation with a commercial motivation.” The FTT also concluded that section 75A did not apply, finding that the neither the share sale nor the liquidation was a transaction "involved in connection" with the intra-group transfers of the properties.
RCB 4 (2026): VAT liability of supplies of electricity from public EV charge points
HMRC have published Revenue and Customs Brief 4 (2026) (RCB) on the VAT liability of supplies of electricity from public electric vehicle charge points. The RCB provides an update on HMRC’s position following the First-tier Tribunal (FTT) decision in Charge My Street Limited. The reduced VAT rate of 5% applies to supplies of electricity for domestic use. The provision of electricity to a person at any premises at a rate not exceeding 1000 kilowatt hours a month is deemed to be for domestic use. The FTT agreed with Charge My Street that its supplies of EV charging at public charging stations fell within the de minimis limit for supplies of electricity, and so were deemed to be for domestic use and, accordingly, subject to the reduced rate. The RCB states that HMRC’s “position remains that charging electric vehicles at public charge points is standard rated for VAT”. HMRC have applied for permission to appeal the FTT decision. (Contact: Donna Huggard)
EMEA Dbriefs webcasts
Three EMEA Dbriefs webcasts will take place next week: