Hello,
With the Chancellor’s Spring Statement just a few days away, there is a little less tax news than normal this week. As a result, we continue to focus on planning around the end of the tax year, and we explore some particularly interesting court and tribunal decisions.
The Court of Appeal (CoA) has published its decision in Orsted West of Duddon Sands (UK) Limited, a case which may be more familiar to some as Gunfleet Sands. This dispute largely focused on the term ‘on the provision of plant’ in a capital allowance context, and its application to expenditure incurred on studies.
The CoA confirmed that capital allowances were largely available for the companies in question, overturning the decision of the Upper Tribunal (UT), which had taken a narrow view in interpretation.
The October 2024 Corporate Tax Roadmap published by HM Treasury noted that due to concerns over the UT’s earlier decision, a consultation would be launched on capital allowances and predevelopment costs. Subject to any appeal by HMRC, the CoA decision will provide important clarification for many businesses, particularly those involved in renewables.
In other news, HMRC have released a Capital Gains Tax (CGT) adjustment calculator for 2024-25, to assist taxpayers in reporting gains affected by the mid-year change in CGT rates. This is particularly significant for those who will use HMRC’s online filing facility as this will not always calculate CGT at the correct rates, meaning a manual adjustment may be required to the return.
More news, cases and updates are below, including a year-end OMB tax planning checklist, two more tax planning toolkits for 2025-26 and a First Tier Tribunal decision looking at Business Property Relief on a Furnished Holiday Letting business.
The Ross Martin Tax Team
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Quick News
HMRC's new 2024-25 CGT 'adjustment' calculator
HMRC have released a calculator for those affected by the 2024-25 change in Capital Gains Tax (CGT) rates. Taxpayers using HMRC's online tax return filing service may need to use this tool to calculate a CGT 'adjustment figure', as the tax return calculation will not automatically calculate CGT at the new main rates where they apply.
Online filing exclusions for 2024-25 tax returns
Some taxpayers will be unable to file their Self Assessment returns online for the year ended 5 April 2025, due to software specification issues from HMRC. Lists of filing exclusions for individuals and partnerships have recently been published by HMRC.
Update on refunds for Tax Credits Ltd customers
HMRC are calling for clients of Tax Credits Ltd who made paper form applications for tax assignments from 1 January to 26 October 2022 to contact them. This follows a successful ongoing Account Forfeiture Order on the bank accounts of Tax Credits Ltd and prior to the distribution of its assets to the state.
Tax Cases
Wind farm study costs qualified for CAs
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.
No BPR for FHL business
In Executors for the Estate of the late Gertrud Tanner v HMRC [2025] TC09456, the First Tier Tribunal (FTT) found that a furnished holiday letting business did not qualify for Business Property Relief (BPR). The business was mainly one of holding investments.
Sky presenter loses IR35 appeal
In PD & MJ Limited v HMRC [2025] UKUT 00094, the Upper Tribunal (UT) found that Sky Sports presenter, Phil Thompson, was an employee for Income Tax and National Insurance purposes.
Editor's Choice
Year-end top tips for OMBs 2024-25
Final year-end tax planning advice for owner-managed businesses. What should you focus on before the end of the tax year? What tax planning should you consider for longer term changes? This guide aims to provide you with a refresher on coming tax changes and provide some planning ideas and tips.
Tax Data Card 2025-26
NEW: A summary of key tax rates and allowances for 2025-26 and 2024-25.
We're hiring: you looking? Tax Adviser/Consultant
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Guides & Updates
Making Tax Digital
Making Tax Digital: Client letter
NEW: A template letter for accountants to use to communicate with clients about the introduction of Making Tax Digital for Income Tax from 6 April 2026.
Making Tax Digital: MTD Roadmap Infographic
NEW: A downloadable Making Tax Digital for Income Tax Roadmap Infographic which sets out the new rules in a graphical format, ideal for ‘visual learners’ and those who don’t like reading! This infographic is designed to allow you to add your firm’s branding.
Self-employed
Motor expenses (self-employed)
What expenses can you claim for motor and travel if you are self-employed? Why are there different versions of the rules? Which method is most beneficial for me?
Pre-trading expenses (self-employed)
What are pre-trading expenses? What tax relief is available for pre-trading expenses? What are the restrictions to relief? What expenses will not qualify?
Capital Allowances
What expenditure qualifies for plant & machinery allowances?
What is plant and machinery? What expenditure qualifies as plant and machinery? What is treated as part of a building?
Full expensing & First Year Allowances
What is full expensing? When does it apply and what is the rate of allowance? How are disposals of full expensing assets dealt with? What assets qualify for the 50% First Year Allowance (FYA)? How do I deal with disposals of 50% FYA assets? How do I make a claim?
Directors & Companies
Tax-efficient extraction of profits: toolkit (2025/26)
NEW: This is a general guide and refresher which aims to help a company and its owner decide how company profits are to be extracted based on current tax, rates, reliefs and allowances.
Directors: Tax planning toolkit for 2025/26
NEW: What tax planning opportunities and strategies are available to directors? What's the optimum way to extract profits in 2025-26? What tax reliefs and tax deductions are handy to consider? This planner looks at a range of director tax issues.
Employers
Termination, redundancy and leaving payments
How are redundancy and termination payments taxed? What amounts can be paid tax-free? What amounts are taxable as earnings?
Private Client & Estate Planning
CGT: Loans to traders relief
What is loans to traders relief? When can it be claimed? What are the conditions of the relief?
Tax Return questionnaire
What information is needed to complete a Self Assessment Tax Return? This questionnaire will help you gather the documents and information required.
Land & Property
Furnished Holiday Letting (FHL): Abolition of the regime: Briefing
UPDATE: HMRC have published draft legislation and related notes detailing how the abolition of the Furnished Holiday Letting (FHL) rules in April 2025 will operate. We consider the practical impact of losing the FHL rules and provide some essential planning points.
VAT News & Cases
Land & Property: DIY Housebuilders scheme
It is possible to recover VAT on constructing a new residential dwelling, or dwellings, even where there is no planned sale of the property. This recovery can arise under the special refund scheme for DIY housebuilders.
Partial exemption & input VAT
How do you calculate the amount of input tax you can recover under the VAT partial exemption rules? What are the de minimis rules?
Tax Tools & Calculators
Tax tools & calculators
We have a suite of useful tax tools that help agents, business owners and sole traders calculate their taxes.
Calendar of tax deadlines and new tax measures
UPDATE: This is a freeview 'At a glance' rolling calendar of common recurring tax deadlines, new tax measures and other tax-significant events.
CPD
CPD for lunch: Byte-sized chunks of lunchtime CPD (free for our Subscribers)
- How to run the most tax-efficient business 2024/25.
- Purchase of Own Shares: all the details.
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Missed the Last Tax Update?
Ross Martin Tax: SME Tax News 13 March 2025
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- Tracker of HMRC's one-to-many letters
- UK deemed domiciled subject to ToAA rules
- Official rate of interest UPDATE
- Tax Data Card 2025-26 NEW
- Sole trader v. limited company: Tax differences & savings (2025/26) NEW
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- Making Tax Digital: MTD Roadmap Infographic NEW ...More
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