18 September 2026
Corporation tax late filing penalties: automatic notices resume
HMRC have announced that the automatic issue of penalty notices for late filed corporation tax returns has resumed. HMRC paused the automatic issue of notices while its systems were updated to reflect the increased penalties applying to corporation tax returns with filing dates on or after 1 April 2026. HMRC note that some businesses who filed late may receive notices later than usual while processing returns to normal.
HMRC guidance widens obligations for directors to report unpaid positions
HMRC have updated their Self-Assessment tax return guidance (SA150) and notes for employment pages (SA102 notes) concerning unpaid directorships. The revised SA150 guidance requires directors of almost any UK company, including dormant companies, to complete the SA102 pages, unless the position is an unpaid one for a registered charity or a community interest company. Previously, this was generally only required for directors receiving income. Detailed information, such as the company’s registration numbers and any shareholdings in the company are only required for directors of close companies.
Cogefin: Bermuda-incorporated company was UK resident
The First-tier Tribunal (FTT) has issued its decision in the corporation tax case Cogefin (Bermuda) Limited & Anor v HMRC. The FTT dismissed the substantive appeal on residence but partially allowed other aspects of the taxpayers’ appeal. The key issue was whether a Bermuda-incorporated company (‘Cogefin’) was resident in the UK by virtue of UK domestic case law, i.e. whether its place of ‘central management and control’ was in the UK. In its decision, the FTT compares the role of the company’s Bermudian-resident directors, who worked for a local law firm, with the involvement of a UK-based individual (‘Mr Ciardi’), the economic settlor and beneficiary of the trust that owned the company. Mr Ciardi was not a director of Cogefin and was self-described as an ‘investment advisor’ to the company.
The FTT found that the strategic, high-level, decision making of the business rested with Mr Ciardi and not with Cogefin’s directors, who did not make the relevant decisions at the level required for central management and control to be located in Bermuda. Instead, the directors (or the administrative staff working with them) undertook administrative functions to ensure that Cogefin could and did undertake Mr Ciardi’s proposals. As a result, Cogefin was resident in the UK only.
Pillar Two: updated information return and further administrative guidance
The G20/OECD Inclusive Framework has published a collection of documents in relation to the Pillar Two global minimum tax rules. These include an updated GloBE information return (GIR) template for use for 2026 year ends onwards, further administrative guidance to address (i) the treatment of ‘explicitly conditional taxes’ and (ii) the use of local financial accounting standards under a qualified domestic minimum top-up tax (QDMTT), and the terms of reference and methodology for the full legislative review of countries’ implementing legislation. Further details are in Deloitte’s alert.
RCB 7 (2026): Changes to the VAT Capital Goods Scheme
HMRC have published Revenue and Customs Brief 7 (2026) on changes to the VAT Capital Goods Scheme (CGS). From 29 July 2026, computers and items of computer equipment have been removed from the list of assets covered by the CGS, and the expenditure threshold for land, buildings, and civil engineering work has increased from £250,000 (exclusive of VAT) to £600,000 (exclusive of VAT). HMRC’s VAT Notice 706/2, Capital Goods Scheme, has also been updated.
Temporary VAT zero rate for domestic electricity – Statutory Instrument
Following the government’s announcement on 21 July 2026, The Value Added Tax (Supplies of Domestic Electricity) Order 2026, with an accompanying tax information and impact note, has now been made to introduce a zero rate for domestic supplies of electricity in Great Britain from 1 October 2026 to 31 March 2027; currently subject to the reduced rate of 5%. (The order does not apply to Northern Ireland.) The zero rate applies to supplies for ‘qualifying use’, which covers ‘domestic use’ (supplies to homes and certain residential settings and supplies below a de minimis threshold) and non-business use by a charity. The definition of ‘qualifying use’ is the same as for currently reduced rated supplies of electricity.
HMRC have issued RCB 10 (2026): Temporary zero rate of VAT for domestic electricity in Great Britain to explain the application of the zero rate. The RCB includes how to deal with billing periods that span 1 October 2026, namely suppliers may determine VAT liability on the date of the energy’s consumption, with meter readings being HMRC’s recommended approach, although other methods may be used if they provide a fair and reasonable outcome.
EMEA Dbriefs webcasts
We have three Dbriefs tax webcasts over the next month: EU Pay Transparency in Practice: Taking Stock and Taking Action (23 September 2026), Leading the future of tax with AI (6 October 2026), and Beyond Compliance: From Surviving to Thriving in a Pillar Two World (14 October 2026). Please visit our Dbriefs website for more information, and to view any other recent webcasts on demand.