Tax & Accounting

The Upper Tribunal has dismissed Barclays Services Corporation’s appeal against HMRC’s refusal to allow a US Delaware entity into the Barclays UK VAT group. Fixed establishment requires real substance on the application date — not backdated arrangements, not substance-in-progress. HMRC’s protection of the revenue powers are broader than previously understood. Six CFO actions for any business with cross-border VAT group arrangements.

The Upper Tribunal has handed HMRC a comprehensive win in Swiss Centre Ltd v HMRC [2026] UKUT 227, confirming that a £34 million payment taken to P&L was not deductible for corporation tax — not under the loan relationship rules, not as capital enhancement expenditure. Six CFO actions before your next group finance review.

The First-tier Tribunal found that public EV charge points can qualify for 5% VAT, not 20%. HMRC is appealing but the protective claim window is open now. Six CFO actions before your oldest recoverable period expires.

HMRC’s new criminal offence for reckless untrue statements in direct tax closes for consultation on 16 August 2026. The threshold drops from dishonesty to recklessness — and every CFO who signs off a tax return needs to understand what that means.

HMRC’s 23 June 2026 consultation on modernising the distributions framework proposes sweeping changes to capital reduction demergers, share buybacks, loans to participators, and capital vs income treatment for individual shareholders. If these proposals become law, the structuring toolkit for owner-manager exits, PE transactions, and pre-sale demergers will change fundamentally. The consultation closes 14 September 2026.

7 August 2026: the first MTD for Income Tax quarterly deadline is six weeks away. Agent Update 144 confirms no further delay. Here are six CFO actions before the window closes — and what the grace period does and does not cover.

The first UK Pillar Two filings are due on 30 June 2026 — six days away. If your group has consolidated revenues above €750 million and any UK presence at all, you are almost certainly in scope. And the most common mistake is assuming someone else has it covered.

The Court of Appeal has ruled that Bolt’s ride-hailing services do not qualify for the Tour Operators’ Margin Scheme. Bolt faces £190m in VAT. Uber’s £1.4bn dispute is now live. Six CFO actions if your business uses TOMS.

HMRC’s Advance Tax Certainty Service goes live on 1 July 2026, offering binding tax clearance for major UK investment projects with £1bn+ qualifying expenditure. Expressions of interest are open now. Here is everything CFOs need to know and seven actions to take before the window opens.

HMRC has raised the Approved Mileage Allowance Payment from 45p to 55p per mile — the first increase in 15 years, backdated to 6 April 2026. Here are seven CFO actions to take before month-end.