Hello,
We have several updates from HMRC this week, with the publication of their April 2026 Agent Update, Employer Bulletin and Employment-Related Securities Bulletin. The VAT fuel scale charge rates for periods beginning on or after 1 May 2026 have also been published, and we examine the latest cases from the courts and tribunals.
With the expenses, benefits and Employment-Related Securities reporting deadlines approaching, the publication of HMRC’s Bulletins is timely. Together with the Agent Update, these contain useful information, including a new dedicated helpline number for trusts, and details of the closure of HMRC’s online service to check overlap relief figures for 2023-24.
Another point worth noting from the Agent Update is that there will be a delay in HMRC issuing Corporation Tax late-filing penalties while updates are implemented to reflect the increased penalties applying from 1 April. Note that this is simply a pause in issuing penalty notices until July; companies that file a return after their statutory deadline will still be charged a penalty.
In this week’s case of Douglas Boulton v HMRC, the First Tier Tribunal (FTT) had to consider whether a director’s settlement agreement with a liquidator, which resulted in part of the director’s loan account being “effectively written off”, gave rise to an Income Tax charge. This decision contrasts with that in Gary Quillan v HMRC, which we reported last year. While both cases relate to the same subject, different fact patterns led to different conclusions from the FTT.
From 1 May 2026, the Renters' Rights Act will abolish fixed-term assured shorthold tenancies, with all tenancies instead being periodic. As a result, it would become more likely for a Stamp Duty Land Tax (SDLT) liability to arise, even though the underlying tenancy arrangements have not substantively changed.
To address this, the government has, this week, announced its intention to legislate in Finance Bill 2026-27 such that any residential lease which will be considered an assured tenancy under the Housing Act 1988, as amended by the Renters' Rights Act, will not give rise to an SDLT charge on the rent element. We can expect more details on this later this year.
More news, cases and updates below, including the latest chapter in the ‘Are large marshmallows normally eaten with the fingers?’ VAT saga.
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Quick News
Agent Update 142: April 2026
HMRC have published their Agent Update for April 2026. We have summarised the key content, including a reminder of the new National Living Wage rates, updates to the Statutory Sick Pay rules and details on how to notify HMRC of the cessation of a trade or property business for Making Tax Digital (MTD) purposes.
Employer Bulletin: April 2026
HMRC have published their Employer Bulletin for April 2026. Key content includes upcoming dates and deadlines, new rates from 6 April 2026, changes to statutory leave and payments, implementing CIS reforms and an Employment Related Securities (ERS) update.
Employment-Related Securities Bulletin 65: April 2026
HMRC have released Employment-Related Securities (ERS) Bulletin 65, which contains details of end-of-year filing requirements, Enterprise Management Incentive (EMI) notifications and penalties for late filing.
Tax Cases
One s'more bite of the marshmallow!
In Innovative Bites Ltd v HMRC [2026] TC09831, the First Tier Tribunal (FTT) again found in favour of Innovative Bites Ltd, holding that its 'Mega Marshmallows' were zero‑rated for VAT as food; they were not confectionery.
Income Tax charge triggered by director’s loan release
In Douglas Boulton v HMRC [2026] TC09846, the First Tier Tribunal (FTT) found that a director’s settlement agreement with the liquidator of his company resulted in his director’s loan account being released or written off, giving rise to an Income Tax charge.
Tribunal agreed that extended time limits for loss carry-back applied
In Hector Lester v HMRC [2026] TC09807, the First Tier Tribunal (FTT) found that the extended loss carry-back time limits applied and that the taxpayer's appeal was valid, despite HMRC not issuing a formal enquiry notice in time.
Editor's Choice
This week's Editor's Choice was selected by Dan Hurst. You can meet our team of editors and writers here: Meet the team.
Annual Tax on Enveloped Dwellings (ATED)
What is the Annual Tax on Enveloped Dwellings (ATED)? Who does ATED apply to? What relief is available and how is it claimed? What are the ATED return filing dates?
Loans to participators (Close Company Loans toolkit)
What is the Corporation Tax treatment when a close company makes a loan to a participator (director-shareholder)? How do the 'bed and breakfasting' rules work? What are the concerns with indirect loans, upstream loans and MBOs?
Striking off a company: Step-by-step
What are the steps required to strike off a company? What are the tax implications?
Guides & Updates
Self-employed
Fines and penalties
How are fines, penalties and payments for damages treated for tax purposes? What determines whether a fine or penalty is allowable or disallowable?
Directors & Companies
Corporate Interest Restriction (CIR)
The Corporate Interest Restriction (CIR) is designed to restrict profit shifting by large corporates by restricting the amount of deductible interest in an accounting period. Who is affected? What is the restriction? What are the penalties?
Directors: Tax planning toolkit for 2026-27
What tax planning opportunities and strategies are available to directors? What's the optimum way to extract profits in 2026-27? What tax reliefs and tax deductions are handy to consider? This planner looks at a range of director tax issues.
Employers
CIS: Contractors and Subcontractors
What is the Construction Industry Scheme? Who does it apply to? How does it work?
Employee Shares: tax reporting for Restricted Stock Units
How are Restricted Stock Units (RSUs) reported for UK tax? How are RSUs taxed? How do I complete my tax return?
Capital Allowances
Short-life assets
What is a short-life asset? How to plan for short-life assets, what can be included and what are the exceptions?
Private Client & Estate Planning
Loan stock: QCBs or Non-QCBs
What is the difference between a Qualifying Corporate Bond (QCB) and a non-QCB? Which is better and why?
Pensions: Unauthorised payment charges
What is a pension unauthorised payment? When does a tax charge arise? Who pays the charge?
Land & Property
SDLT: Leases
UPDATE: The government has announced its intention to legislate in Finance Bill 2026-27 so that any residential lease which will be considered an assured tenancy under the Housing Act 1988, as amended by the Renters' Rights Act, will not give rise to an SDLT charge on the rent element.
Penalties & Compliance
Special Relief
What is Special Relief? When does it apply? Does Special Relief have a time limit to claim?
Overpayment Relief
What is Overpayment Relief? When can you claim Overpayment Relief? What are the conditions for a claim for Overpayment Relief? What are the time limits for a claim for Overpayment Relief?
VAT
Fuel scale charges (VAT)
UPDATE: The VAT fuel scale charge rates which apply for prescribed accounting periods beginning on or after 1 May 2026 have been published.
Continuing Professional Development (CPD)
Recent and upcoming webinars include:
- Monthly Tax Update - May 2026
- 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 16 April 2026
- New tool for loans to participators and other updates
- Welsh Tax Acts legislative proposals consultation outcome
- Wind farm study costs were too remote for CAs
- A share loss claim that sank
- Penalties: Tax advisers (sanctionable conduct) UPDATE
- Globally mobile employees: National Insurance UPDATE
- Self Assessment Tax Return: What goes where? UPDATE
- Tax Agents: HMRC's Standards for Agents
- Mandatory tax adviser registration with HMRC
- Deregistration ...More
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