SME Tax News

In Orsted West of Duddon Sands (UK) Limited & Ors v HMRC [2025] EWCA Civ 279, the Court of Appeal (CoA) applied a wider interpretation to the term ‘on the provision of plant', than previous tribunals. This meant that the cost of preliminary studies relating to offshore wind farms qualified for capital allowances.

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News this week includes a proposed reporting easement for ‘side-hustlers’ and a new service for tax agents to escalate and resolve self-assessment and PAYE queries with HMRC. We also continue to look forward to the new tax year, with a range of new and updated guides and resources.

In Valesca Valentina Yvette Louwman v HMRC [2025] TC09445, the First Tier Tribunal (FTT) reluctantly ruled that the Transfer of Assets Abroad (ToAA) rules applied to Offshore Income Gains (OIGs) and Accrued Income Profits (AIPs) deemed to arise to a UK deemed domiciled taxpayer from non-resident trusts settled before the taxpayer became UK domiciled. The OIGs and AIPs were chargeable to Income Tax as they arose.

The minister responsible for HMRC, James Murray, has announced that those with side-hustles can earn up to £3,000 before they have to file a tax return, although tax will still be due on earnings over £1,000. A new service will also be launched on 31 March, for agents to escalate and resolve self-assessment and PAYE queries.

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This week we bring news of the planned closure of the HMRC/Companies House joint online filing service for companies. We explore HMRC’s new consultation on the proposed changes to Agricultural Property Relief (APR) and Business Property Relief (BPR), and, as the end of the current tax year draws near, we consider last-minute tax planning opportunities for 2024-25.

HMRC and Companies House have announced that from 31 March 2026, the joint online filing service used to submit company accounts and Corporation Tax returns will close.

The government has published its responses to four consultations regarding its initiative on labour market reform, 'Make Work Pay'. It plans on strengthening union and workers’ rights in areas like zero-hour contracts, unfair dismissal and sick pay.

The government has published its response to the consultation 'Tackling non-compliance in the umbrella company market'. From April 2026, recruitment agencies will be responsible for PAYE, instead of umbrella companies. The Employment Rights Bill will also be amended to bring umbrella companies within the definition of employment business to ensure workers receive similar rights to those of direct employees.

In Fitzgerald & Anor v HMRC [2025] TC09415, the First Tier Tribunal (FTT) ruled that Multiple Dwellings Relief (MDR) was not available for an annexe. The planning permission specified that it could only be used for ancillary purposes to the house and it was not a separate unit of residential accommodation.