ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø

There were a number of response documents and new consultations published:

• Following on from a consultation published in 2023, a on draft legislation for the reform of the UK’s international tax rules on transfer pricing, permanent establishment and Diverted Profits Tax was published. This is discussed in a separate article in today’s edition;
• on amending the small and medium enterprise exemption from transfer pricing and introducing an International Controlled Transactions Schedule was also published and is the subject of a second separate article in today’s edition;
• There were two updates on the ongoing Tax Administration Framework Review. was published to the earlier consultation on new ways to tackle non-compliance, including confirmation that HMRC will further consider reform of revenue correction powers, approaches to taxpayer self correction and options to harmonise and simplify compliance powers across tax regimes. And was published on improving HMRC’s approach to dispute resolution which includes proposals to simplify and align appeals processes to “combine the benefits of both indirect and direct taxes approachesâ€� and reforms to improve access to alternative dispute resolution;
• was published to the earlier consultation on Stamp Taxes on Shares modernisation, alongside a to take forward proposals to modernise the 1.5 percent higher rate charge on Stamp Taxes on Shares which applies in certain circumstances when UK securities are transferred overseas;
• on reform of Landfill Tax in England and Northern Ireland signals the first radical reset of UK Landfill Tax for many years and will impact not only on landfill site operators but on waste producers and waste processors. The headline changes â€� intended to link Landfill Tax to the circular economy - include moving to a single rate within five years, removing water discounting and removing exemptions for quarry and landfill restorations meaning that few sectors will avoid the impact of the proposals;
• There were a number of other releases in relation to Indirect Taxes including responses to earlier consultations on , , and the . There were new consultations published on , the and the ; and 
• A consultation was published on to make changes to the restitution interest rules for corporation tax which apply in relation to claims made for payment of tax under mistake of law.

There were a number of other updates included in the TUSAR package, some of which had already been announced previously. Some of the more noteworthy include the following:

• As discussed in a separate article in today’s edition, employers will be pleased to have an extra year to prepare for mandatory payrolling for benefits in kind (BiKs) and taxable employment expenses. A confirmed that this will be introduced from April 2027 rather than April 2026 “after feedback from external stakeholdersâ€� (the challenges around payrolling company car benefits were discussed in our last edition before the date change was announced). However, HMRC are also considering retaining Forms P11D and P11D(b) for specific cases involving internationally mobile employees who are part of modified PAYE arrangements (commonly referred to as EP Appendix 6 and Appendix 7A). Further details are expected when draft guidance is published later this year;
• Employers will also be interested in changes to HMRC’s Check Employment Status for Tax (CEST) digital tool with effect from 30 April 2025. Revised guidance that offers help on how to answer the revised questions has been promised but had not been published at the time of writing;
• HMRC will establish a working group to simplify and improve the administration rules for Corporate Interest Restriction (CIR) and, in particular, reporting company appointments under the regime - a topic that was discussed in our last edition;
• From June, HMRC will no longer send a selection of non-statutory Corporation Tax letters to taxpayers for information that can be accessed online. More widely the intention is to reduce print and postage costs by £50 million annually by 2028-2029;
• A new interactive compliance guidance tool, launched on 30 April and to be continuously developed thereafter, has been designed to provide “a better understanding of what to expect and what needs to be done at each stage of a compliance check, making it easier for taxpayers to get things right and to understand their rightsâ€�;
• The Government will reform the Cultural Gift Scheme by removing the restriction on jointly owned objects and allowing tax credits to be used more flexibly. The offers individuals and companies a tax reduction when ‘Pre-Eminent Objectsâ€� (or collections of objects) have been donated to be held for the benefit of the public or the nation;
• The VAT Capital Goods Scheme (CGS) will be simplified by increasing the threshold for land, buildings and civil engineering work from £250,000 to £600,000 (exclusive of VAT) and removing computers from CGS assets. These changes will take effect “at a later date within this parliamentâ€�; and
• The functions of the Valuation Office Agency, which deals with property valuations, will be brought within HMRC by the end of this financial year with the .

For further information please contact:

• Tim Sarson
• Sharon Baynham