Hello,
One of the most significant tax developments this week is the Supreme Court’s judgment in Orsted West of Duddon Sands (UK) Limited & Ors v HMRC. This long-running dispute concerned Orsted’s ability to claim capital allowances on environmental surveys and studies that informed the building of wind farms.
The core question was whether the survey and study costs were incurred ‘on the provision’ of the wind farms. The Supreme Court overturned last year's Court of Appeal decision, applying a narrower test. There had to be a close connection between the expenditure and the plant provided.
This decision will have practical implications not only for large infrastructure projects but also for a wider group of taxpayers, making the Supreme Court's judgment essential reading for anyone advising on capital allowances.
There are also two important updates this week relating to loans to participators. Firstly, HMRC have published a new tool to confirm that a participator has fully repaid a loan reported on a company's tax return. Secondly, the Corporation Tax online service will not be updated to reflect the increased s.455 tax rate (as currently in force) until 6 April 2027. We look at the implications.
On a related subject, we recently examined HMRC’s consultation on Reporting company payments to participators. Given the significance of the proposals it makes, we are preparing a response on behalf of 20:20 Innovation members and rossmartin.co.uk subscribers, and would greatly appreciate your input. Keep an eye out for our email containing a short survey that allows you to share your views.
Finally, do note our two new subscriber guides this week. The first covers what’s new in the 2025-26 tax return, outlining the key changes box-by-box. Our second new guide updates employers and their advisers on the key tax issues to be aware of in 2026-27.
More news, cases and updates below.
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
New tool for loans to participators and other updates
A new loans to participators tool has been published that allows companies, participators, and their agents to confirm to HMRC that a participator has fully repaid a loan declared on a company's tax return. HMRC have also advised that the Corporation Tax online service will not be updated to reflect the increased s.455 tax rates until 6 April 2027.
Welsh Tax Acts legislative proposals consultation outcome
The Welsh Revenue Authority (WRA) has published the outcome of its consultation 'Legislative Proposals Relating to the Welsh Tax Acts'. While there was general support for the proposals made, it will be for the next Welsh government to decide whether to take them forward.
Tax Cases
Wind farm study costs were too remote for CAs
In Orsted West of Duddon Sands (UK) Limited & Ors v HMRC [2026] UKSC 12, the Supreme Court (SC) applied a narrower interpretation to the term ‘on the provision of plant' than was applied by the Court of Appeal (CoA). As such, the cost of preliminary studies and surveys relating to offshore wind farms did not qualify for capital allowances, as there was not a close enough connection between the expenditure and the plant provided.
A share loss claim that sank
In Simon Widers v HMRC [2026] TC09836, the First Tier Tribunal (FTT) found that claimed share loss relief arising from an investment in a marine salvage venture was not allowable because the expenditure was not incurred wholly and exclusively for the acquisition of the shares, and in any event, one of the main purposes of the arrangements was to secure a tax advantage.
Editor's Choice
This week's Editor's Choice was selected by Jenni Davie. You can meet our team of editors and writers here: Meet the team
Penalties: Tax advisers (sanctionable conduct)
UPDATE: What penalties can HMRC charge for tax agents found guilty of sanctionable conduct? How is sanctionable conduct different from dishonest conduct? What are the penalties?
Tax Agents: HMRC's Standards for Agents
Our guide to HMRC's 'Standard for agents', HMRC's approach to tackling bad agent behaviour, and providing a definition of a tax adviser.
Mandatory tax adviser registration with HMRC
From May 2026, all tax advisers who interact with HMRC on behalf of clients will be required to register with them. Who will be required to register? What conditions must be met? What are the consequences of non-compliance with 'mandatory tax adviser registration'?
Guides & Updates
New This Week
Self Assessment Return 2025/26: What's new?
2026 Self Assessment toolkit: top tips for completing tax returns for the year ending 5 April 2026.
Employer's What's On: 2026-27
This employer update is for advisers and their clients for 2026-27 and covers measures from the Autumn 2025 budget. It also considers other topical issues for employers and employees.
Self-employed
Averaging claims
When can profits be averaged? What trades do averaging apply to? How are averaging adjustments calculated and made?
Directors & Companies
Liquidation
How do you wind up (liquidate) a company? What types of liquidation are there? What are the formalities and the tax consequences of liquidation?
Purchase (repurchase) of Own Shares
How can a company repurchase its share capital? What are the Companies Act requirements? What are the tax consequences for the company and shareholders?
Employers
Globally mobile employees: National Insurance
UPDATE: What are my employer's National Insurance obligations when hiring an employee from overseas? What are my employer's Social Security obligations when sending an employee to work overseas? Do I have any PAYE reporting requirements concerning National Insurance?
P11Ds: Employers' checklist & top tips
Top Tips for employers on preparing form P11D together with a checklist.
Private Client & Estate Planning
Self Assessment Tax Return: What goes where?
UPDATE: The Self Assessment Tax Return for individuals is made up of a set of core pages and a number of supplementary pages. This guide explores what goes where on the tax return.
IHT: Agricultural and Business Property Reliefs, April 2026 changes
Significant changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) were announced in the 2024 Autumn Budget, with further changes announced at the 2025 Autumn Budget, and again in December 2025. What is changing? What planning could be considered?
Trusts & Estates: Ten-year charge reporting requirements
What is the ten-year charge (or principal or periodic charge) and when does it apply?
Land & Property
Profits from dealing in or developing UK land
These rules apply UK Income Tax or Corporation Tax to all profits from trading in and developing UK land, regardless of your country of residence.
Penalties & Compliance
Penalties: Deliberate Behaviour
What penalties apply to deliberate behaviour? What is deliberate behaviour?
VAT
Deregistration
When do I have to deregister for VAT? When can I voluntarily deregister? What penalties might HMRC issue if I am late notifying them of mandatory deregistration?
Continuing Professional Development (CPD)
Recent and upcoming webinars include:
- Practice Insight - April 2026 (free)
- Monthly Tax Update - April 2026
- Practice Insight - March 2026 (free)
- Mandatory HMRC Agent Registration Part 1 – Getting Started Before May 2026
- Monthly Tax Update - March 2026 (Spring Forecast)
- Inheritance Tax Planning for 2026/27 and Beyond
- Ethics and PCRT for Tax Advisors
Need Tax Support?
Virtual Tax Partner© Support
Have a tax query? Need a second option? Open a ticket and ask a question. A team of tax experts with a wide range of expertise: covering direct and indirect tax, as well as accounting, reorganisations and much more.
Missed the Last Tax Update?
Ross Martin Tax: SME Tax Update 9 April 2026
- Notifying HMRC that MTD income ceased before April 2026
- Call for evidence on tax treatment of stablecoins
- Online filing exclusions for 2025-26 tax returns
- Reasonable care not taken to comply with CIS
- CoA denies amortisation deduction on intangible assets
- HMRC win UT appeal on 'mixed use' SDLT claim
- Globally mobile employees: PAYE reporting obligations toolkit
- Employers: Who is an employer for PAYE and NI purposes?
- Non-resident tax toolkit
- Finance Acts 2026-27: tax update and Rolling Tax Planner NEW ...More
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