31 July 2026
Date of Budget confirmed
On 31 July 2026, the Chancellor of the Exchequer, John Healey MP, announced that the Budget will take place on Wednesday 28 October 2026. The Budget will be presented alongside the latest economic and fiscal forecasts commissioned from the Office for Budget Responsibility (OBR). HM Treasury is inviting Budget representations from interested stakeholders until 9 September 2026.
Prime Minister announces devolution package
UK Prime Minister Andy Burnham MP has announced a devolution package, which will give more powers to English mayors. The government will also support areas without a mayor to “establish strategic authorities and gain greater control over local priorities.” Further details are included in a Cabinet Statement setting out the government’s vision for devolution in England. As part of the package, mayoral authorities will retain more locally generated revenue, starting with business rates from spring 2027 and followed by a share of income tax revenues from 2028, with further details to be set out in a roadmap at the Budget. Local leaders will also be given greater control over areas including housing, transport, skills, employment support and public services.
GfC5: Help to avoid errors in claims for plant and machinery allowances – updated
On 27 July 2026, HMRC published updates to the capital allowances Guidelines for Compliance (GfC), Help to avoid errors in claims for plant and machinery allowances – GfC5. GfC5 sets out common areas of error when claiming capital allowances on plant or machinery. It has been updated to reflect changes announced at Budget 2025 and now includes sub-sections on the new 40% first-year allowance, which took effect from 1 January 2026, and hybrid writing down allowances following the reduction in the main rate writing down allowance from 18% to 14% from 1 April 2026 for corporation tax purposes.
Upper Tribunal dismisses HMRC’s appeal on SDLT repayment time limits
The Upper Tribunal (UT) has dismissed HMRC’s appeal in the stamp duty land tax (SDLT) case HMRC v Candy. The decision concerns a claim for overpayment relief where SDLT was suffered on a ‘substantially performed’ conditional land purchase contract and where the contract’s condition failed to be met more than a year afterwards. The taxpayer attempted to claim relief directly under section 44(9) Finance Act 2003, which permits a repayment of SDLT where a contract is subsequently “rescinded or annulled, or for any other reason not carried into effect”. Section 44(9) however specifies that the repayment “must be claimed by amendment” to the return. In 2022, the Court of Appeal unanimously held that section 44(9) did not operate as an exception to the normal 12-month time limit for amending SDLT returns, and so dismissed this claim.
The taxpayer had also made an alternative claim for relief under SDLT ‘overpayment relief’ provisions (Paragraph 34 Schedule 10 Finance Act 2003). Similar overpayment relief rules apply to corporation tax, income tax and capital gains tax, and these can provide a statutory backstop for obtaining a refund of overpaid tax where other statutory relief provisions have been exhausted. HMRC argued that the requirement for a section 44(9) claim to be made by amending an SDLT return also prevented equivalent relief being claimed through overpayment relief. The UT, like the First-tier Tribunal before it, disagreed, concluding that the amendment requirement was specific to section 44(9) claims. The UT agreed with the approach endorsed in BTR Core Fund JPUT that paragraph 34 provides a separate statutory remedy of last resort, with its own time limits, procedure, and restrictions.
In a separate SDLT case concerning a late attempt to claim multiple dwellings relief (MDR), Warner v HMRC, the UT found in favour of HMRC, holding that the taxpayer had not made a formal overpayment relief claim, having instead sought a late amendment to his SDLT returns.
Pillar Two: HMRC deadline for resubmission of GIRs that failed validation
On 13 July 2026, HMRC updated their guidance on the extended deadline for corrections to GloBE Information Returns (GIRs) that were submitted by the 30 June 2026 deadline (or 31 July deadline if applicable) but not accepted (see previous Business Tax Briefing). As a reminder, such GIRs will be recorded as successful submissions within HMRC systems on the date of original filing on condition that they are amended to pass validations and are re-submitted on or before 1 September 2026.
OECD publishes updated corporate tax statistics
The OECD has released the 2026 edition of its annual Corporate Tax Statistics report and accompanying database. The report and database provide internationally comparable statistics covering more than 170 jurisdictions, supporting analysis of corporate taxation generally and base erosion and profit shifting (BEPS) in particular. The OECD highlights that corporate tax rates have remained stable across G20/OECD Inclusive Framework member countries, with an average combined statutory rate of around 21.2% in 2020 and 2026, with slight variations in the intervening years.
GfC8: Help with VAT compliance controls – new section on temporary reduced VAT rate
HMRC have published a new section of Guidelines for Compliance 8 (GfC8), Help with VAT compliance controls, covering the temporary reduced VAT rate for children’s meals, tickets and family attractions. GfC8 sets out what HMRC consider to be best practice for VAT accounting and compliance processes, supporting businesses to identify and assess risk, and put in place appropriate controls. The new section sets out the parameters of the temporary reduced rate, which applies from 25 June 2026 to 1 September 2026 inclusive, and notes that businesses are expected to pass the benefit of the reduction on to customers. The guidelines then set out examples of both risks that may arise and controls that may help businesses reduce the risk of error and support accurate reporting. The guidelines also note that businesses must ensure the correct VAT rate is applied from 2 September 2026. HMRC have also published an update to Revenue and Customs Brief 5 (2026) on the temporary reduced VAT rate. (Contact: Adam Routledge)
EMEA Dbriefs webcasts
The next EMEA Dbriefs webcast, Mandatory overseas permanent establishment exemption, will take place on Thursday 20 August 2026 at 12.00 BST/13.00 CEST. The webcast will cover the government’s announcement that UK-resident companies will be required to exclude profits and losses attributable to foreign permanent establishments (PEs) from their corporation tax computation, effectively making the UK’s existing ‘foreign branch exemption election’ mandatory. Our panel will discuss the new UK approach set out in the draft legislation, including changes to the existing overseas permanent establishment exemption rules, restricted losses and transitional rules, and implementation dates and next steps.