Business Tax Briefing

Corporate re-domiciliation consultation published

On 25 March 2026, the Department for Business and Trade published a consultation on detailed design proposals for an inward UK corporate re-domiciliation regime, and an accompanying analytical paper. The proposals are based on the recommendations in the 2024 report of the UK Independent Expert Panel on corporate re-domiciliation and follow an initial consultation undertaken 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 consultation predominantly covers non-tax issues, however 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.

Corporate Criminal Offences statistics updated

HMRC have updated their statistics on investigations of corporate criminal offences (CCO) for the failure to prevent the facilitation of tax evasion. As at 31 December 2025, HMRC had secured one charging decision, with an additional 11 live CCO investigations. A further 32 identified cases were under review as to whether they should proceed to an investigation. The cases identified span 10 business sectors. To date, HMRC have reviewed and rejected an additional 126 cases. However, HMRC note that some of these previous investigations have led to satisfactory explanations that have caused CCO investigations to be dropped but have instead led to other tax and regulatory offences being pursued.

Making electronic communications default for Revenue Scotland: consultation

On 23 March 2026, the Scottish government published a consultation on proposals that would enable Revenue Scotland to use electronic communications as its default means of communicating with taxpayers. Digitally excluded taxpayers and those not wishing to receive correspondence digitally would be able to opt out. It also proposes that correspondence sent by ordinary post would have a rebuttable presumption of receipt by the taxpayer. The Scottish government notes that it will be for a future administration to determine any next steps, including whether to bring forward any legislation. The consultation closes on 15 June 2026.

Land and buildings transaction tax: independent report and Scottish government response

On 25 March 2026, the Scottish government published a report resulting from an independent review of land and buildings transaction tax (LBTT), assessing whether five areas of LBTT are achieving their intended policy objectives and their interaction. The areas considered were the treatment of non-residential and mixed-use property, multiple dwellings relief (MDR), the six plus dwellings additional dwelling supplement (ADS) exemption, first-time buyer relief, and alignment with Scotland’s Just Transition and Net Zero goals.

In its response, the Scottish government comments on the report's recommendations in each of the five areas, and states that the recommendations “offer a constructive basis for future policy development” and “provide useful evidence that will inform future consideration by the next Scottish Parliament”.

Boehringer Ingelheim Limited: VAT on pharmaceutical payments

Boehringer Ingelheim Limited (BIL) supplied branded pharmaceutical products to the NHS at the standard rate of VAT. Between 2014 and 2020, BIL made payments to the Department of Health and Social Care (DHSC) under two voluntary schemes, the purpose of which was to control the NHS’s spend on branded medicines. The payments were calculated as a percentage of net sales and were made after the supplies had been made. BIL submitted claims for over-declared VAT, on the basis that the payments should have been treated as reducing the consideration for the products, which HMRC rejected. The First-tier Tribunal (FTT) agreed with BIL. However, in overturning the FTT decision, the Upper Tribunal (UT) has held that BIL was not able to reduce the consideration for payments made under the schemes.

The UT considered that DHSC was not part of the supply chain. There was not a sufficient link between the payments made by BIL and the original supplies. While the DHSC funded the NHS, including the purchase of products and medicines, there was no direct link to any individual supply, only general, non-ringfenced funding. The payments were not a reduction in the price paid by the final consumer, but were payments made outside the supply chain, which did not reduce the amount of consideration. The UT set aside the FTT’s decision and remade it, allowing HMRC’s appeal, except in relation to a limited number of payments made in respect of medicines that BIL had supplied directly to the DHSC.

EMEA Dbriefs webcasts

The next EMEA Dbriefs webcast will take place on Wednesday 1 April 2026 at 12.00 BST/13.00 CEST. In Responding to Labour Supply Chain Fraud Risks, hosted by Matt Davies, our panel will be joined by guest speakers from HMRC’s Fraud Investigation Service and Large Business Directorate to discuss labour supply chain fraud, potential consequences for businesses caught up in fraudulent supply chains, steps to reduce risk and detect fraud, where to find support, actions HMRC are taking to reduce risk in this area, and the read across to impending legislation regarding umbrella companies and agencies for employment tax purposes from April 2026.

Deloitte’s Business Tax Briefing is taking a one-week break for Easter. The next edition will be published on Friday 10 April 2026.