13 March 2026
Spring Statement
The Chancellor of the Exchequer Rachel Reeves MP delivered her Spring Forecast 2026 speech to Parliament on 3 March 2026. In line with the government’s policy to deliver just one major fiscal event a year, i.e. the annual Budget each autumn, the speech contained no tax announcements. At Budget 2025, the government stated that it would “announce further changes to simplify and improve tax and customs administration at a Tax Update in early 2026.”
Finance Bill progress update
The remaining Commons stages of Finance (No. 2) Bill 2024-26 took place on 11 March 2026. During the Report Stage debate, the MPs accepted amendments tabled by the government last week (see previous Business Tax Briefing for details). MPs then voted to give the Finance Bill its Third Reading. The Bill has now moved to the House of Lords where it had its First Reading on 12 March 2026. The Lords’ version of the Finance Bill, reflecting all amendments made during the Bill’s passage through the House of Commons, has been published. This will effectively be the text of Finance Act 2026, as the Lords cannot change the Bill. The House of Lords has provisionally scheduled its Second Reading and remaining stages for Tuesday 17 March 2026, after which the Bill will be sent for Royal Assent.
HMRC publish consultation on standardising corporation tax computations
HMRC have published a consultation titled Modernising and standardising company tax returns. The consultation document sets out HMRC’s plans to develop a prescribed “standardised, fully tagged format” for corporation tax computations that accompany online submissions of the CT600 Company Tax Return form, applicable from October 2027 (in pilot) and mandated from September 2028. In addition, from 1 April 2027, HMRC propose to change their policy to require amendments to corporation tax computations and returns to be submitted online. The consultation closes on 2 June 2026. Further details are on tax@hand.
HMRC publish consultation on extending uncertain tax treatment regime
HMRC have published a consultation on proposed changes to extend the uncertain tax treatment (UTT) regime. The consultation seeks views on the government’s proposals to bring individual taxpayers and trusts within the scope of UTT, extend the taxes within scope, and introduce a new ‘trigger’. The new ‘trigger’ would capture situations where there is more than one credible legal interpretation and HMRC’s view is not known. The government intends that any legislation will be introduced in the next available Finance Bill and apply to returns filed after 1 April the following year. The consultation closes on 4 June 2026.
HMRC manuals: new 40% first-year allowance for main rate assets
HMRC have added new guidance pages to their Capital Allowances Manual (see CA23195+) on the introduction of a new 40% first-year allowance (FYA) for main rate assets from 1 January 2026, as announced at Budget 2025. The new FYA applies to new expenditure on eligible assets, including most plant or machinery for leasing, but excludes second-hand assets, cars, and assets leased overseas.
UK lists of countries with qualified status for Pillar Two purposes updated
HMRC have updated their notice to specify further countries with a qualified income inclusion rule (IIR) and/or a qualifying domestic top-up tax (QDMTT) that meets safe harbour standards. The update follows changes to the OECD Inclusive Framework’s central record of countries whose local implementation of the Pillar Two rules have so far been assessed as ‘qualified’. Hong Kong SAR and Qatar have been added to HMRC’s lists of countries with a qualified IIR and a QDMTT that meets safe harbour standards. Bahrain has been specified as having a QDMTT that meets safe harbour standards.
Upper Tribunal clarifies approach to question of whether a person has begun to carry on a trade
The Upper Tribunal (UT) has handed down its decision in Putney Power Limited and Piston Heating Services Limited v HMRC, setting aside the original First-tier Tribunal (FTT) decision for errors of law, but reaching the same outcome in favour of HMRC for different reasons. The case focusses on whether Putney Power Limited (‘Putney’) and Piston Heating Services Limited (‘Piston’), had met a condition requiring them to have begun to carry on a trade.
On 4 April 2016, Putney and Piston issued shares to investors pursuant to the Enterprise Investment Scheme (EIS). However, HMRC and the taxpayers disagreed on whether the companies had begun to carry on a trade within two years of the share issue date, i.e. by 4 April 2018, and therefore whether the claims for relief under the EIS rules were valid. HMRC argued that while Putney and Piston’s activities prior to this date were legitimate business activities, they amounted to nothing more than getting ready to trade. On a multi-factorial assessment of the facts and circumstances, the UT concluded that, as at 4 April 2018, both companies were still preparing to trade. The fact the companies were incapable of generating any income from their chosen trades on or before this date represented a firm pointer against the proposition that they had begun to carry on that trade. Although Putney had entered into a matrix of contracts, this formed part of its preparations to trade, rather than conducting the trade itself. By the same date, Piston had not entered into any binding commitments that would result in financial risk or reward.
Charge My Street Limited: Reduced VAT rate for public EV charging
Charge My Street Limited (CMS) supplies electric vehicle (EV) charging to EVs at its charging stations in public places. CMS considered the reduced VAT rate of 5% applied to its supplies, on the basis that they fell within the de minimis limit for supplies of electricity and so were deemed to be for “domestic use”. HMRC ruled that the standard rate applied. The First-tier Tribunal (FTT) has agreed with CMS.
Under Note 5(g), Item 1, Group 1, Schedule 7A of the VAT Act 1994, the provision of electricity to a person at any premises at a rate not exceeding 1000 kilowatt hours (kWh) a month is deemed to be for “domestic use”. The FTT found that, contrary to HMRC’s arguments, “premises” did not require any concept of legal ownership by the recipient of the electricity, nor was it confined to buildings, but could include defined public spaces, such as car parks. The FTT also accepted CMS’s approach that the 1000 kWh limit is measured simply in terms of how much electricity is provided by a supplier to a person at any premises in the month in question, which for public EV charging would almost always be under the limit. Accordingly, the FTT allowed CMS’s appeal in principle.
EMEA Dbriefs webcasts
We have four Dbriefs tax webcasts over the next month: EU Public Tax Reporting requirements in 2026 (17 March 2026), Global Game Plan: Immigration Considerations for Short-term Sports Visitors (18 March 2026), Pillar Two – Unexpected Pillar Two liabilities in M&A transactions (24 March 2026), and Responding to Labour Supply Chain Fraud Risks (1 April 2026). Please visit our Dbriefs website for more information, and to view any other recent webcasts on demand.