Hello,
It has been a busy couple of weeks in the world of tax. HMRC have made their first Corporate Criminal Offences charging decision, and a voluntary COVID support repayment scheme has been launched, which gives individuals and businesses a chance to repay overclaimed COVID scheme money before tougher sanctions are introduced. We also bring news of a retired cricketer getting caught out on the taxation of sponsorship income.
HMRC have made their first prosecution under the Corporate Criminal Offences (CCO) rules, which came into force some eight years ago on 30 September 2017, for the failure to prevent the facilitation of tax evasion.
HMRC's long-held stance has been that CCO investigations are not the sole measure of success, as the legislation was introduced to drive behavioural and procedural change. If this first charging decision is successful, we wonder if HMRC's appetite for further prosecutions will increase. Although the hearing in this case is not expected for another two years, this will be an important subject to watch as we learn how HMRC will handle CCO prosecutions.
Unsurprisingly, preparations for the Autumn Budget are in full swing. HM Treasury are now inviting Budget representations, and the Government has released its interim report looking at the reform of the business rates system in England.
For those dealing with Additional Dwelling Supplement (ADS) repayment claims in Scotland, do note that the process will change from 22 September, with the upload of a supporting document then becoming mandatory at the time of submitting a request.
In another process change, Form VAT652, for VAT error correction, was withdrawn earlier this month. Our updated 'Correcting VAT errors' guide details the current error correction process to follow.
More news, cases, and updates below, including a case involving a retired cricketer who got caught out when the First Tier Tribunal found that his sponsorship income should have been assessed as self-employment profits.
The Ross Martin Tax Team
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Quick News
Autumn Budget representations now invited
HM Treasury is inviting representations from stakeholders ahead of the 2025 Autumn Budget on 26 November 2025. The portal for representations closes on 15 October 2025.
'Window of opportunity' to repay overclaimed COVID funds
In a bid to recoup lost revenue from COVID fraud, HM Treasury have launched a 'voluntary repayment scheme' allowing individuals and businesses who overclaimed COVID-19 support to pay the money back, with no questions asked.
HMRC make first Corporate Criminal Offences prosecution
HMRC have secured its first charging decision under the Corporate Criminal Offences (CCO) legislation, while the number of live cases being investigated for the failure to prevent the facilitation of tax evasion has remained static, for the third time.
Updated Additional Dwelling Supplement repayment process
From 22 September 2025, Revenue Scotland will implement changes to the Additional Dwelling Supplement (ADS) repayment request process, requiring documents to be uploaded at the time of making a claim.
One-to-many letters: Tracker
HMRC have commenced three more one-to-many 'nudge' letter campaigns. These target: missing 60-day Capital Gains Tax (CGT) returns; VAT recovery for businesses that supply facilities management services, and; employment businesses and recruitment agencies where mini-umbrella companies may exist within their supply chain.
Business Rates reform to be confirmed in Autumn Budget 2025
The Government has published an interim report, 'Transforming Business Rates', summarising how it plans to improve the operation of the business rates system in England.
Tax Cases
Retired cricketer loses sponsorship income appeal
In Paul Collingwood v HMRC [2025] TC09624, the First Tier Tribunal (FTT) found that cricket sponsorship income, which had been assigned to a former England cricketer's company, should have been assessed as profits from self-employment.
Intra-group disregard did not apply after supplier left VAT group
In The Prudential Assurance Company Limited v HMRC [2025] UKSC34, the Supreme Court (SC) agreed with an earlier Court of Appeal (CoA) decision, finding that VAT was due on services provided between two companies that were members of the same VAT group. The services were not invoiced or paid until after the supplier had left the group, meaning that the intra-group disregard did not apply.
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Capital Allowances
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Structures & Buildings Allowance (SBA)
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Land & Property
SDLT: Leases
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Overseas & Residence
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Penalties & Compliance
Named tax avoidance schemes, promoters, enablers
UPDATE: HMRC publish a list of named tax avoidance schemes, promoters, enablers and suppliers. It is not recommended that taxpayers use any of these schemes, as HMRC do not consider that they work and you may end up with a significant tax liability if you engage with the scheme suppliers.
Failure to notify chargeability to tax
UPDATE: What is failure to notify chargeability to tax? What happens if you fail to notify HMRC about your taxes? What penalties apply for failing to notify HMRC that you have a tax liability?
Digital Platform Reporting
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VAT
Correcting VAT errors
UPDATE: What are the VAT error correction time limits? Can you correct errors through the VAT return? Do you have to notify HMRC?
Assessments: Best judgement & time limits
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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
This is a freeview 'At a glance' rolling calendar of common recurring tax deadlines, new tax measures and other tax-significant events.
CPD
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Ross Martin Tax: SME Tax News 4 September 2025
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