UK: Foreign PE tax exemption to become mandatory from 2027 to block overseas loss relief against profits
The UK government has announced, on 21 May 2026, changes to the taxation of UK-resident companies who conduct part of their business through foreign permanent establishments (PEs). For most companies, it will be mandatory for profits and losses
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UK: HMRC issues transitional guidance on Pillar Two GIR filing, exchange
The UK’s His Majesty’s Revenue and Customs (HMRC) issued new guidance on 19 May 2026 outlining a transitional approach to Global Information Return (GIR) filing and exchange under the OECD’s Pillar Two framework. The guidance follows the
See MoreUK: HMRC consults on draft rules for IHT treatment of unused pension funds
The UK’s His Majesty’s Revenue and Customs (HMRC) has opened a consultation on 18 May 2026 about the draft regulations designed to support the application of inheritance tax (IHT) to unused pension funds. This technical consultation seeks
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UK introduces phased mandatory registration for tax advisers from May 2026
UK’s HM Revenue and Customs (HMRC) has announced the introduction of a mandatory registration requirement for tax advisers, with implementation beginning on 18 May 2026. The new requirement, known as Modernising and Mandating Tax Adviser
See MoreUK: HMRC introduces advance tax certainty service from July 2026
The UK tax authority, His Majesty’s Revenue and Customs (HMRC) has published guidance on 12 May 2026 regarding the Advance Tax Certainty Service, which is scheduled to be launched on 1 July 2026. The Advance Tax Certainty Service is designed to
See MoreUK: HMRC tests Pillar Two reporting ahead of launch
The UK HM Revenue & Customs (HMRC) updated its guidance on “How to report Pillar Two Top-up Taxes” on 14 May 2026, adding details of a testing period for the new information return service ahead of its launch on 19 May 2026. HMRC said the
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UK: HMRC issues letters over BADR lifetime limit breach
The UK HM Revenue & Customs (HMRC) is issuing a second round of letters to taxpayers who claimed Business Asset Disposal Relief (BADR) in their 2024/25 Self Assessment tax return and may have exceeded the GBP 1 million lifetime limit. The
See MoreUK: HMRC updates systems following corporation tax penalty increase
The UK has increased late filing penalties for Corporation Tax (CT) for all returns due on or after 1 April 2026. This measure, originally announced in Budget 2025, is now in effect. HM Revenue & Customs (HMRC) is currently in the process of
See MoreUK: Supreme Court grants permission to appeal in major SDLT anti-avoidance dispute
The UK Supreme Court has granted the Tower One St George Wharf Limited permission to appeal in a high‑value stamp duty land tax (SDLT) dispute with HMRC concerning the transfer of a central London residential property. The appeal will focus on the
See MoreUK: HMRC revises electricity generator levy from July 2026
The UK HM Revenue & Customs (HMRC) has confirmed changes to the Electricity Generator Levy (EGL), increasing the rate from 45% to 55% with effect from 1 July 2026, according to a policy paper released on 6 May 2026. The EGL applies to certain
See MoreUK: HMRC proposes CCA scheme expansion, carbon factor update from 2027
The UK’s HMRC has issued a policy paper on 20 April 2026, outlining proposed updates to the Climate Change Agreements (CCA) scheme in the UK. The proposal focuses on expanding eligibility to additional energy-intensive activities, refining key
See MoreUK sets out economic response to Middle East conflict, outlines energy and tax measures
The UK HM Treasury has issued a statement delivered to Parliament by the Chancellor of the Exchequer, Rachel Reeves, setting out the Government’s economic response to the conflict in the Middle East, including a series of tax-related and energy
See MoreUK: HMRC publishes draft CBAM regulations covering emissions monitoring and administration
The UK’s HMRC has issued draft regulations on the carbon border adjustment mechanism (CBAM) on 9 April 2026. The draft covers the administration of the tax, including emissions, as well as the monitoring and verification of emissions data. This
See MoreUK: HMRC updates guidance on foreign income and gains regime (FIG)
UK’s HMRC has issued updated guidance on the foreign income and gains (FIG) regime on 6 April 2026, setting out eligibility criteria, claim procedures, qualifying income and gains, and the implications for tax allowances. Background: FIG
See MoreUK: Financial Reporting Council issues guidance on generative, agentic AI in audits
The UK’s Financial Reporting Council (FRC) announced it has published guidance for audit firms on using generative and agentic AI tools in audit engagements on 30 March 2026. The guidance sets out how firms can mitigate risks to audit quality
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Estonia: Government approves signing of income tax treaty with UK
Estonia’s government approved the signing of the income and capital tax treaty with the UK on 19 March 2026. The updated treaty is structured to comply with current international norms, in accordance with the OECD/G20 Base Erosion and Profit
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UK: HMRC issues guidance on tax adviser sanctionable conduct
The UK’s HM Revenue & Customs (HMRC) has published guidance on handling tax adviser sanctionable conduct, effective from 16 March 2026. From 1 April 2026, HMRC can take stronger action against advisers who deliberately contribute to tax
See MoreUK: HMRC proposes broader digital tax reporting under MTD
UK’s His Majesty’s Revenue and Customs (HMRC) has introduced regulations requiring the use of compatible software to submit information on business and property income and to maintain associated records. This information will be used to
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