Hello,
HMRC’s mandatory registration of tax advisers has now begun. Agents who interact with HMRC about someone else’s tax affairs have three months from their ‘start date’ to register. The first start date of 18 May applies to advisers interacting with HMRC without an Agent Services Account, Self Assessment or Corporation Tax account, as well as new advisers.
In Beer Express Ltd v HMRC [2026] TC09873, the First Tier Tribunal (FTT) found that project expenditure did not qualify for Research & Development (R&D) relief in the absence of evidence from a competent professional. The FTT placed no reliance on vague and loosely termed reports prepared by an R&D advisory firm that could not be reached when the claims were challenged.
As proposed at Budget 2025, HMRC have introduced a targeted advance assurance service for Research and Development (R&D) tax relief claims. The service, which is a pilot, aims to provide Small and Medium-sized Enterprises (SMEs) with clarity on complex or high-risk areas before a claim is made.
The application process for mandatory tax adviser registration opened on 18 May 2026. In light of this, HMRC have issued a press release encouraging advisors to check whether they need to register.
In Mark Gadsden v HMRC [2026] TC09884, the First Tier Tribunal (FTT) found that a taxpayer had exercised due care and diligence. It allowed his appeal against HMRC's refusal to treat his late-paid Class 2 National Insurance contributions as paid for State Pension purposes.
In Vereley Homes Limited v HMRC [2026] TC09881, the First Tier Tribunal (FTT) found that a fenced-off and overgrown plot of land, which previously formed part of a demolished neighbouring property, constituted part of the garden or grounds of an adjacent dwelling for Stamp Duty Land Tax (SDLT) purposes.
HMRC have published an issue briefing 'Tax fraud warning: Attempts to use 'Bills of Exchange’ to pay HMRC', highlighting schemes that are marketed particularly to the recruitment and temporary labour sectors. HMRC do not accept Bills of Exchange as a valid form of payment.
Hello,
Among this week's highlights are more warnings about relying on unverified Artificial Intelligence (AI) output, the latest employment status tribunal decision, HMRC’s view on the VAT liability of public electric vehicle charge points and the First Tier Tribunal's (FTT) interpretation of the Statutory Residence Test.
In Omar Rafique v HMRC [2026] TC09874, the First Tier Tribunal (FTT) found that an application to reinstate a struck-out VAT appeal should be refused. The appellant had persistently failed to comply with tribunal directions and 'Unless Orders', and had repeatedly submitted AI-generated correspondence containing fabricated case authorities.
In Professional Game Match Officials Limited v HMRC [2026] TC09870, the First Tier Tribunal (FTT) found that referees engaged by the company were not employees. The long-standing case emphasises the 'multi-factorial' approach required when determining employment status.
