HMRC’s Transfer Pricing and Diverted Profits Tax Data Sends a Clear Message to Multinationals

HMRC’s latest figures show a sharp rise in transfer pricing yield, longer enquiry timelines, and a continued focus on profit diversion. For large groups with UK operations, this is not just a statistical update. It is a sign that international tax risk remains high on HMRC’s agenda. The latest publication, released on 11 March 2026, shows a transfer pricing yield of £3.387 billion for 2024–25, up from £1.786 billion a year earlier. At the same time, the average age of settled transfer pricing enquiries rose to 41 months.

At Apex Accountants, we see this data as important for any multinational group, UK subsidiary, or mid-sized business with cross-border related-party transactions. The numbers point to a tougher and more persistent compliance environment. They also arrive just as the UK moves away from Diverted Profits Tax as a standalone regime and toward the new Unassessed Transfer Pricing Profits, or UTPP, rules for accounting periods beginning on or after 1 January 2026.

Snapshot of Transfer Pricing and Diverted Profits Tax

Measure2023–242024–25What it suggests
Transfer pricing yield£1.786bn£3.387bnHMRC secured much more tax from international tax work
Settled enquiry cases128143Case closures rose, but not dramatically
Average age of settled enquiries33.1 months41.0 monthsDisputes are taking longer to resolve
HMRC staff on international tax issues395392Resource stayed broadly stable
APAs agreed2726Advance certainty remains available
MAP cases resolved86115Double tax dispute resolution activity increased
DPT net amount£108m£94mThe direct DPT take fell, even while wider diverted profits work remained significant

What UK transfer pricing rules means in simple terms

Transfer pricing is about how connected companies price transactions between themselves for tax purposes. That includes charges for goods, services, financing, royalties, and other cross-border dealings inside the same group. UK transfer pricing rules are based on the arm’s length principle. HMRC requires these transactions to follow the same pricing standards used between independent businesses.

Transfer pricing plays a key role in deciding how much profit is reported for UK tax purposes. If HMRC believes too little profit has been allocated here, it can challenge the position and increase taxable profits. Under UK rules, a transfer pricing adjustment can increase taxable profits or reduce a loss. It cannot reduce profits or increase a loss.

Why the 2024–25 figures matter

The headline number is the £3.387 billion transfer pricing yield. That is the highest figure in the six-year data series shown by HMRC. It is almost double the previous year’s result. Even without a huge increase in settled case numbers, the yield surge suggests HMRC closed some large and complex cases with significant tax at stake. That is an inference from the published figures, not a statement HMRC makes directly.

The second key point is timing. Settled enquiries averaged 41 months in 2024–25, up from 33.1 months in 2023–24. For finance teams, that means international tax disputes can remain open for years. The cost is not only tax. It also means management time, documentation pressure, audit scrutiny, and uncertainty in forecasting.

HMRC assigned 392 full-time equivalent staff to handle international tax issues concerning multinational businesses in 2024–25. The modest change from the prior year suggests enforcement efforts remain steady.

UK Diverted Profits Tax is changing, but the risk is not disappearing

Diverted Profits Tax, or DPT, was designed to push large companies away from contrived arrangements that reduce UK tax liabilities. HMRC’s latest statistics say DPT will be repealed and replaced by UTPP for accounting periods beginning on or after 1 January 2026. The new rules are intended to retain the core features of DPT but move the charge into the corporation tax regime.

That change matters for two reasons. First, DPT does not vanish overnight. It still applies to earlier accounting periods. Second, the policy direction is continuity rather than retreat. According to the government, UTPP will preserve the reach of DPT and apply to similar structures in a similar way.

There is also a practical upside for some businesses. Government material says UTPP will sit within the UK’s treaty network, and businesses subject to UTPP should be able to use the Mutual Agreement Procedure to deal with double taxation in the usual way. That was a welcome point in the consultation response.

The wider diverted profits picture is still substantial

Although DPT’s net amount for 2024–25 was £94 million, HMRC’s wider diverted profits results were much larger. The department reported £1.769 billion of additional tax, mainly corporation tax, from transfer pricing-settled investigations into diverted profits in 2024–25. Since DPT was introduced in 2015–16, HMRC says more than £10.5 billion has been secured.

By the end of March 2025, HMRC was reviewing approximately 53 multinational cases linked to profit diversion, with roughly £3.5 billion of tax at stake. That shows the compliance pipeline remains active even while the legal framework evolves.

Why PDCF still matters

The Profit Diversion Compliance Facility gives multinational groups a route to review and disclose outstanding liabilities linked to profit diversion. HMRC first launched it in January 2019. In the latest statistics, HMRC says over £872 million of additional revenue has been secured from resolution proposals and behavioural change since their introduction, and that around three quarters of targeted large businesses used the facility.

For some groups, that makes PDCF a risk-management tool rather than a sign of failure. A voluntary review, backed by proper documentation and technical analysis, can be far better than waiting for a long enquiry or a formal notice.

What businesses should do now

If your group has UK cross-border related-party transactions, this is the time to review the basics.

  • Check whether intercompany pricing still matches the arm’s length principle
  • Refresh transfer-pricing documentation and benchmarking
  • Review financing arrangements, royalties, and service charges
  • Revisit permanent establishment and profit diversion risks
  • Consider whether past periods need correction or disclosure
  • Prepare for the move from DPT to UTPP from 1 January 2026 for relevant accounting periods
  • Assess whether MAP, APA, or PDCF could reduce uncertainty in the right case

How We Help Businesses in UK

At Apex Accountants, we help businesses manage international tax risk in a practical and commercially focused way.

Our support includes:

  • transfer pricing risk reviews
  • intercompany pricing policy reviews
  • documentation support and evidence packs
  • cross-border finance and royalty reviews
  • profit diversion risk assessments
  • HMRC enquiry support
  • APA and MAP support
  • tax governance and compliance planning for multinational groups

We focus on clarity, defensible positions, and early action. That is especially important when HMRC enquiries now routinely stretch over several years.

Conclusion

HMRC’s 2024–25 transfer pricing and diverted profits data is a warning sign, not just a technical update. The yield is up sharply. Enquiries are taking longer. Profit diversion remains a live issue. And from 1 January 2026, UTPP will carry that policy forward inside the corporation tax regime.

For businesses with cross-border group transactions, the message is simple. Review your position early, document it properly, and do not treat transfer pricing as a year-end formality. In the current HMRC climate, weak documentation and old assumptions can become expensive. 

FAQs About HMRC’s Transfer Pricing and Diverted Profits Tax

What is transfer pricing?

It refers to the pricing applied to transactions between related companies within the same group. UK tax rules require these prices to match what independent businesses would reasonably agree to in similar circumstances.

What is the Diverted Profits Tax?

It is an anti-avoidance rule targeting large companies that shift profits away from the UK tax base. It still applies to earlier periods, even though UTPP will replace it for future ones.

What is UTPP?

UTPP stands for Unassessed Transfer Pricing Profits. It is the replacement for DPT for accounting periods beginning on or after 1 January 2026, with the charge brought into the corporation tax regime.

Do SMEs need to worry about transfer pricing?

Many small and medium-sized enterprises are still exempt under current UK rules, though there are exceptions and the government has consulted on changes to the SME exemption, including removing the exemption for medium-sized enterprises.

What is an APA?

An Advance Pricing Agreement is an agreement with HMRC that establishes the transfer pricing approach for particular transactions over an agreed period, helping limit future tax disputes.

What is MAP?

The Mutual Agreement Procedure is a treaty-based process that tax authorities use to resolve double taxation disputes. HMRC resolved 115 MAP cases in 2024–25, and UK transfer pricing MAP cases outperformed the global average resolution time in OECD statistics for calendar year 2024.

Bingo duty in the UK stays the same – and is about to vanish

With the UK government reshaping gambling duties, the most striking feature of the Autumn Budget 2025 for bingo halls is what didn’t happen: the bingo tax wasn’t raised. At 10% on bingo promotion profits, the duty has remained unchanged since Chancellor George Osborne halved it in 2014. That steady rate now stands on the brink of abolition; legislation in the Finance Bill 2025‑26 will repeal the duty from 1 April 2026. In other words, bingo duty UK stays the same for one final year before it disappears – a decision that reflects both the Treasury’s revenue strategy and the social role of bingo.

Bingo halls are more than a revenue stream

Bingo may evoke flashing lights and cash prizes, but for many communities it remains a social anchor. A House of Commons briefing observed that around 400 bingo clubs operated across the UK and that the sector raised £75 million in bingo duty in 2012/13. Those halls support jobs and provide social space for older and lower‑income customers, and successive governments have acknowledged that value. When ministers cut the duty from 20% to 10% in 2014, the official policy papers noted that “bingo halls play an important role in their local communities” and that the reduction was intended to support them. Hansard records show then‑Chancellor Osborne telling MPs that bingo duty would be halved to “protect jobs and protect communities”.

The cut had a marked effect: the duty has remained at 10% ever since, even as other gambling taxes rose or were reformed. Industry lobbying and the perception of bingo as a low‑harm, socially embedded activity helped maintain that stability. Contrast that with the introduction of machine games duty, remote gaming duty and other levies in the last decade, which targeted forms of gambling seen as more harmful or more profitable. In that context, the government’s choice to leave bingo duty untouched in the latest Budget was not inertia but deliberate policy.

A tax that stayed the same for a decade

Understanding the stability of the bingo duty requires a brief history. Until 2003, bingo duty was charged on total stakes and added prize money; it then shifted to a gross profits tax at 15%. Financial pressures on the industry saw the rate raised to 22% in 2009 before lobbying prompted a cut to 20 per cent a year later. The 2014 Budget made a bolder move, reducing the rate to 10 per cent from June 2014. That change, justified by the sector’s community role, cost the Exchequer about £30 million in the first year.

Since then, the duty has generated a modest but stable stream of revenue. HMRC guidance sets out that bingo promoters must pay 10% of their bingo promotion profits – receipts from participation fees and stakes minus winnings – for each accounting period, forming part of the wider tax rules for bingo halls UK. This applies only to in‑person bingo; remote or online gaming is taxed under separate regimes. The persistence of the 10 percent rate stands out when compared with the shift towards taxing remote gambling. Remote gaming duty, introduced at 15% in 2007, will jump from 21% to 40% from April 2026, while a new 25% rate for remote betting arrives in 2027.

Autumn Budget 2025: no change today, abolition tomorrow

The government’s consultation on remote gambling concluded that the duty system needed modernisation but should be differentiated between high-risk and low-risk activities. The summary of responses emphasised that bingo is a “lower risk gambling activity that supports communities across the UK”. As a result, ministers decided to preserve the duty unchanged for 2025/26 and abolish it entirely from 1 April 2026. The same policy paper notes that repealing bingo duty will simplify the system by removing one of seven gambling duties.

This decision sits alongside a significant tax hike for online gambling. By raising remote gaming duty to 40% and introducing a remote betting duty of 25%, the Treasury aims to extract revenue from sectors with lower overheads and higher perceived harm. Bingo halls, with their physical premises and local employment, are spared this increase. Maintaining the 10% duty for another year ensures continuity for operators and prevents a cliff‑edge reduction in receipts before the duty’s abolition.

What the status quo means for bingo operators under bingo duty UK

For UK bingo promoters, the immediate message is: keep paying the duty until 31 March 2026. HMRC’s excise notice requires promoters to calculate bingo receipts, deduct winnings, and remit 10% of the resulting profits under bingo duty UK. Returns must continue to be filed on the usual schedule, and operators should keep detailed records of receipts and payouts. Small‑scale bingo at travelling fairs or in societies remains exempt, but commercial halls and clubs are not.

As the abolition approaches, there are practical points to consider:

  • Final duty return – the last duty accounting period before 1 April 2026 will need a final return. Ensure systems can separate periods before and after abolition.
  • Cash flow planning – freed‑up cash from the removal of duty could support refurbishment, marketing or staff training. Preparing a budget now helps maximise the benefit.
  • Remote operations – online bingo sites may be taxed as remote gaming; under the new rules, remote gaming duty at 40% could apply. Operators offering both in‑person and online games should review their product mix and corporate structures.
  • Compliance with other duties – bingo halls often operate gaming machines that are subject to machine games duty, which forms part of wider bingo halls tax compliance UK obligations. Abolition of bingo duty does not affect these obligations.

Beyond bingo: a wider gamble on tax policy

The differentiation between land‑based bingo and remote gambling illustrates a broader shift. The government’s consultation response stresses that remote gambling has grown by over 60% since 2015/16 while land‑based gambling has declined. By targeting online gaming, ministers hope to discourage harmful behaviour and harness revenue from a growing digital sector. Abolishing bingo duty, on the other hand, signals support for leisure activities that encourage face‑to‑face socialising. Businesses in the broader leisure and hospitality sector should note this policy trajectory: low‑harm, community‑based activities may find a friend in future Budgets, while digital or high‑risk operations face tougher tax regimes.

How Apex Accountants & Tax Advisors can help

Navigating the end of bingo duty requires more than simply waiting for 1 April 2026. Our specialist tax team can assist with:

  • Compliance reviews – supporting strong bingo halls tax compliance UK by ensuring accounting systems accurately calculate bingo promotion profits and file final duty returns.
  • Cash‑flow and investment planning – projecting the financial impact of duty abolition and modelling how to reinvest savings.
  • Classification advice – determining whether online bingo products fall under remote gaming or betting duties and optimising your business structure accordingly.
  • Indirect tax strategy – assessing exposure to machine games duty, VAT and other indirect taxes to avoid surprises.

With decades of experience advising leisure and hospitality businesses, Apex Accountants can offer tailored support through this transition. Contact us today to arrange a consultation.

Frequently asked questions

What is the current rate of bingo tax?

The duty on in‑person bingo remains at 10% of bingo promotion profits. The rate has been unchanged since June 2014.

When will the bingo duty change?

The Finance Bill 2025‑26 repeals bingo duty from 1 April 2026. Operators must continue to file and pay the 10 per cent duty until then under the current tax rules for bingo halls UK.

Who has to pay bingo duty?

Any bingo promoter running commercial games on licensed premises must register and pay bingo duty. Small-scale bingo organised by societies, travelling fairs, or at home remains exempt.

How do I calculate bingo duty?

Any bingo promoter running commercial games in licensed premises must register and pay bingo duty. Small-scale bingo organised by societies, travelling fairs, or at home remains exempt.

How do I calculate bingo duty?

HMRC requires promoters to add up bingo receipts (participation fees and stakes), deduct winnings, and apply the 10 per cent rate to the resulting profit. Detailed records must be kept.

What happens to online bingo under the new regime?

Online or remote bingo may fall within remote gaming duty, which will increase to 40% from April 2026. Businesses offering remote games should seek advice to ensure correct classification and compliance.

Does the abolition of the bingo duty affect any other gambling taxes?

No. Machine game duty, gaming duty at casinos, and general betting duty remain in force. Remote gaming and betting duties will rise sharply, while land‑based betting duty stays at 15 per cent.

HMRC Investigations Into Big Businesses Now Last Years — And Companies Are Feeling the Pressure

HMRC investigations into big businesses have become markedly longer, with many major corporate tax enquiries now stretching across several years. Freedom of Information data analysed by law firm Pinsent Masons shows that open enquiries handled by HM Revenue & Customs’ Large Business Directorate now last about 41 months – nearly three and a half years. The same analysis found that the number of active investigations into companies with annual revenue above £200 million rose from 2,031 to 2,149 in the year to March 2025. HMRC’s scrutiny of large corporations is therefore both broader and deeper, and HMRC investigations into large UK companies now have consequences for business planning, cash flow and the wider UK economy.

What the data reveal about HMRC investigations into big businesses

  • HM Revenue and Customs (HMRC) does not publish full data on all large-business enquiries, making precise timelines difficult to determine.
  • The most reliable indicators come from transfer pricing and diverted profits tax cases, which tend to be the most complex.
  • These cases often involve multinational companies and cross-border transactions, making them slower and more resource-intensive.

Recent statistics (2024–25)

MetricLatest figurePrevious year
Average age of settled transfer pricing enquiries41.0 months33.1 months
Number of cases settled143128

HM Revenue and Customs acknowledges that long-running enquiries can create uncertainty for businesses, but says there has been clear progress in reducing the time it takes to close cases recently. It also says that speed won’t sacrifice the correct tax amount. The broader picture reflects a mixed trend: while closed cases are now being resolved more quickly, many open enquiries continue to run for several years. Despite improvements in efficiency, the volume and complexity of cases prolongs the overall timeline for large-business tax investigations.

Why these investigations take so long

Several structural factors explain why HMRC investigations into large businesses often stretch over several years.

Complex international tax structures

Many enquiries involve multinational groups with complex cross-border arrangements. Transfer pricing disputes, questions around permanent establishments, or the use of overseas subsidiaries require detailed analysis of global transactions. These cases frequently involve cooperation between multiple tax authorities and extensive documentation reviews. As a result, investigations can take considerable time to resolve.

Governance and oversight within HMRC

Large-business tax cases are subject to strict internal oversight. HMRC has adopted a cautious approach following past criticism over corporate tax settlements. Major decisions must pass through several levels of review to ensure they are robust and defensible. While this strengthens accountability, it can slow the pace at which disputes move towards resolution.

A growing compliance workload

The number of enquiries opened into large companies has increased in recent years, reflecting a wider rise in HMRC investigations into large UK companies. HMRC continues to prioritise large-business compliance because these companies account for a substantial share of UK tax revenues. As the volume and complexity of cases rise, investigations naturally take longer to progress through the system.

The nature of corporate tax disputes

Large corporate tax enquiries often evolve into detailed technical disagreements, particularly in complex HMRC tax enquiries for large UK businesses. Companies may challenge HMRC’s interpretation of tax rules, provide additional evidence, or seek clarification through negotiation. This process can involve multiple rounds of correspondence, expert analysis, and sometimes international consultations before both sides reach agreement.

Co-operative compliance challenges

HMRC assigns a Customer Compliance Manager to major groups to maintain ongoing dialogue. In practice, however, differences in interpretation or gaps in documentation can still lead to prolonged discussions. When disagreements arise, reaching a settlement may take significant time, particularly if both parties need to revisit earlier positions.

Business impact

Prolonged investigations carry several consequences for large companies:

  • Financial uncertainty: Pending enquiries often involve substantial tax liabilities. HMRC charges late-payment interest on any underpaid tax, currently 7.75%, meaning that protracted cases can significantly increase costs. Businesses may also need to provision for contingent liabilities in their accounts, affecting reported profits and dividend decisions.
  • Resource diversion: HMRC tax enquiries for large UK businesses demand significant management time, professional fees and administrative support. According to Pinsent Masons, many of the UK’s largest firms have multiple concurrent enquiries, compounding the burden.
  • Reputational and operational risk: Unresolved tax disputes can create uncertainty for investors and may hinder a company’s ability to bid for government contracts or complete corporate transactions. Uncertainty also discourages long‑term investment decisions, undermining the UK’s competitiveness.

HMRC’s response and the policy landscape

HMRC argues that it is making progress in reducing the time taken to close enquiries and that its co‑operative compliance model remains a cornerstone of large‑business tax administration. The NAO report praises the hands‑on approach for doubling the compliance yield and reducing the long‑term tax gap. However, the public debate is shifting towards transparency and accountability. The Public Accounts Committee has launched an inquiry into tax compliance by large businesses, scrutinising how HMRC manages its caseload and whether current governance structures strike the right balance between efficiency and fairness.

The government’s 2021 Review of tax administration for large businesses recognised that timeliness is a key concern and committed to further embedding co‑operative compliance. Meanwhile, HMRC’s transfer‑pricing statistics show that staffing levels for international tax remain relatively static at 392 full‑time equivalent specialists. Unless resources increase in line with caseloads, the average age of enquiries may continue to creep upwards.

Practical steps for large businesses

While companies cannot control HMRC’s internal processes, they can take steps to reduce the risk of drawn‑out disputes:

  • Strengthen tax governance: Boards should ensure that tax policies are documented, risks are identified and escalated, and there is clear oversight from the finance and audit committees. A robust governance framework helps resolve issues quickly when HMRC asks questions.
  • Engage early with HMRC: Proactive disclosure through real‑time working or the Profit Diversion Compliance Facility can pre‑empt formal investigations and demonstrate a willingness to co‑operate.
  • Maintain thorough documentation: transfer pricing positions, transaction analyses, and internal policies should be well-evidenced and updated. Poor documentation is a common cause of delays. Detailed records also facilitate the negotiation of advance pricing agreements, which provide certainty but still take around 44 months to agree.
  • Monitor emerging policy: The Large Business Directorate’s success means HMRC is considering extending the close‑contact approach to other complex or high‑risk businesses. Medium‑sized groups should prepare for similar scrutiny.
  • Seek professional advice: Specialist advisers can help interpret HMRC correspondence, gather evidence, and negotiate settlements. Early intervention often reduces the lifespan of enquiries.

How Apex Accountants & Tax Advisors can assist

Navigating an HMRC investigation is both a technical and a strategic challenge. Apex Accountants & Tax Advisors support large businesses at every stage of the process. Our services include:

  • Risk assessments and governance reviews: Evaluating existing tax controls against HMRC expectations and best practice to identify potential triggers for enquiry.
  • Documentation and transfer‑pricing support: Preparing robust transfer‑pricing reports and documentation that stand up to HMRC scrutiny and align with international guidelines.
  • Dispute management: Representing clients in correspondence and meetings with HMRC, helping to narrow issues and achieve timely resolution. Where appropriate, we can assist with Advance Pricing Agreements or mutual agreement procedures to secure certainty.
  • Strategic advice on co‑operative compliance: Advising on whether to join HMRC’s Profit Diversion Compliance Facility or other disclosure programmes, balancing transparency with commercial considerations.
  • Training and ongoing compliance: Providing training for finance teams on record‑keeping, risk management and responding to HMRC queries. We can help design procedures to monitor tax positions across the group.

For tailored support and to minimise the impact of long‑running HMRC enquiries on your business, contact Apex Accountants today to arrange a confidential consultation.

FAQs

What is the average duration of an HMRC investigation into large businesses?
Recent FOI data indicate that open investigations into the UK’s largest companies last around 41 months (about three and a half years). HMRC’s own statistics show that the average age of settled transfer‑pricing enquiries is also around 41 months.

Why do HMRC investigations take so long?
The main drivers are the complexity of international transactions, limited specialist resources, layered governance processes and the sheer volume of cases. Transfer‑pricing disputes require coordination with other tax authorities and often take years to resolve.

How many large‑business investigations are open?
Data from HMRC’s Large Business Directorate show that there were 2,149 open investigations at the end of the 2024‑25 year, up from 2,031 a year earlier.

Does HMRC publish data on investigation length?
HMRC publishes limited statistics. The Transfer Pricing and Diverted Profits Tax statistics report includes the average age of settled enquiries. FOI responses obtained by Pinsent Masons provide further insight into the average age of open enquiries.

How can businesses reduce the duration of an HMRC enquiry?
Companies can reduce delays by keeping comprehensive documentation, engaging proactively with HMRC through their Customer Compliance Manager, addressing queries promptly and considering advance pricing agreements for complex transfer‑pricing issues. Professional advice can help streamline the process and avoid pitfalls.

Could HMRC’s close‑contact model be extended beyond large businesses?
Yes. The NAO reports that HMRC is exploring whether to apply the Large Business Directorate’s hands‑on approach to other complex or high‑risk businesses. Medium‑sized groups should monitor developments and prepare for increased engagement with HMRC.

The Government Launches Fraud Strategy 2026-2029: A Comprehensive Approach to Tackling Fraud in the UK

On 9th March 2026, the UK government, led by The Rt Hon Lord Hanson of Flint, the Home Office Minister of State, introduced the Fraud Strategy 2026-2029. This strategy aims to address the growing threat of fraud, which has become the most common crime in the UK. It accounts for 45% of all crime. The UK government is taking significant steps to tackle this issue head-on, investing £250 million over the next three years.

Why the Government Introduced the Fraud Strategy

Fraud has become a critical challenge, affecting millions of individuals and businesses across the UK. In 2025 alone, there were 4.15 million incidents of fraud. Criminals are using increasingly sophisticated methods, such as AI, deepfakes, and social engineering, to exploit victims. These scams are not only financially devastating but also erode public trust, harm businesses, and undermine economic stability.

Recognising the urgent need for action, the government introduced the Fraud Strategy 2026-2029 to strengthen the UK’s response to fraud, protect vulnerable groups, and ensure a safer digital economy. This strategy focuses on three main pillars: Disrupt, Safeguard, and Respond, each targeting a different aspect of prevention and victim support.

The Three-Pillar Approach of the New Fraud Strategy

1. Disrupt: Preventing Fraud at its Source

The first pillar of the strategy, Disrupt, is focused on making it harder for criminals to commit fraud. The government is strengthening fraud prevention measures by closing gaps that criminals exploit. Also denying them access to the tools and methods they use to operate.

Key Initiatives:

  • Online Crime Centre (OCC): Launching in 2026, the OCC will be a public-private partnership that will centralise data sharing and intelligence gathering. It will identify and disrupt fraud trends in real-time. This collaboration aims to tackle fraud across telecommunications, financial services, and online platforms.
  • International Collaboration: The UK is partnering with Nigeria, Vietnam, and other countries to tackle cross-border fraud and dismantle global fraud networks.
  • Strengthened Regulations for Technology and Financial Services: The government is introducing new measures to address fraud in telecommunications, online platforms, and cryptoassets.

2. Safeguard: Protecting Individuals and Businesses

The Safeguard pillar aims to reduce vulnerability and build resilience to fraud. By educating the public and businesses, particularly those most at risk, the government seeks to prevent fraud before it happens.

Key Initiatives:

  • Public Education Campaigns: The Stop! Think Fraud campaign will be expanded to raise awareness about fraud, targeting both individuals and businesses. The campaign will work closely with schools, universities, and vulnerable communities to improve fraud literacy.
  • Cyber Resilience for Businesses: With small businesses being frequent targets of fraud, the government will provide cybersecurity support and encourage businesses to adopt best practices for data protection and fraud prevention.
  • Protection for Vulnerable Groups: The strategy focuses on elderly people, young adults, and those in financial distress, ensuring they are more informed and less vulnerable to scams.

3. Respond: Supporting Victims and Delivering Justice

The third pillar, Respond, is focused on supporting fraud victims and ensuring that fraudsters are held accountable. This includes improving reporting systems, providing victim support, and reforming fraud laws to keep pace with modern fraud tactics.

Key Initiatives:

  • Fraud Victims Charter: This new initiative will establish national standards for victim care. It will ensure that fraud victims receive timely responses, emotional support, and financial reimbursement where applicable.
  • Report Fraud Service: The Report Fraud Service will offer a streamlined and secure way for victims to report incidents. This will enable law enforcement to take swift action and gather intelligence for future cases.
  • Fraud Law Reforms: An independent review of fraud laws will ensure that current legal frameworks are fit for purpose in addressing new fraud methods. It will enable victims to receive justice in a timely manner.

Sectors Focused by the Fraud Strategy

The Fraud Strategy 2026-2029 targets sectors that are particularly vulnerable to fraud due to their reliance on digital platforms, financial transactions, and large data flows. The key sectors being focused on are:

  1. Telecommunications: Preventing fraud via mobile phones and communication platforms. As these platforms are often exploited by fraudsters for phishing and other fraudulent activities.
  2. Financial Services: Addressing both unauthorised fraud and authorised fraud (such as APP fraud), and regulating emerging threats from cryptoassets and digital currencies.
  3. Cybersecurity: Strengthening resilience against cybercrime, with particular focus on small businesses that are often targeted by fraudsters.
  4. Online Platforms: Tackling fraud on social media, marketplaces, and advertising platforms. Fraudsters exploit these spaces to reach a large number of victims.

Our Viewpoint on the Government’s Fraud Strategy

At Apex Accountants, we fully support the Fraud Strategy 2026-2029 and its multifaceted approach to combatting fraud. We recognise that the growing sophistication of fraud requires a collaborative effort from the government, law enforcement, the private sector, and industry stakeholders. This strategy’s focus on prevention, education, and resilience is essential for reducing the impact of fraud across the UK.

In particular, we are encouraged by the government’s emphasis on cybersecurity and small business support, which aligns with our own efforts to help businesses strengthen their fraud risk management and cyber resilience. As fraud continues to evolve, so must our response, and this strategy sets the foundation for a more secure future in which fraud is actively disrupted before it can cause harm.

While the Disrupt pillar focuses on shutting down the avenues criminals use, the Safeguard and Respond pillars are equally important. Educating individuals and businesses to recognise fraud and providing timely support to victims is crucial. It helps reduce both the financial and emotional toll fraud takes. We welcome the initiative to provide a Fraud Victims Charter, ensuring that victims receive the justice and support they need.

Conclusion

The government’s launch of the Fraud Strategy marks a significant step in the fight against fraud. This strategy promises a coordinated effort to tackle fraud at its source, protect vulnerable individuals and businesses, and support victims in their recovery. Apex Accountants stands ready to help businesses navigate these changes and protect themselves from the increasing threat of fraud. We are committed to supporting your business every step of the way in tackling fraud and ensuring a secure future.

FAQs on Fraud and New Fraud Strategy 

1. What are the 7 types of fraud?

The seven types of fraud typically include financial fraud, identity theft, credit card fraud, insurance fraud, mortgage fraud, tax fraud, and cyber fraud. Each involves deception for personal gain.

2. What are the 4 components of a fraud management strategy?

A fraud management strategy typically includes prevention, detection, response, and investigation. These components help businesses identify, manage, and mitigate fraud risks effectively through a structured approach.

3. What are the 4 P’s of fraud?

The 4 P’s of fraud are: Prevention, Pursuit, Protection, and Prosecution. These elements aim to stop fraud before it occurs, catch offenders, protect victims, and ensure offenders face legal consequences.

4. What does a fraud strategist do?

A fraud strategist develops and implements policies and systems to prevent, detect, and respond to fraud. They analyse risks, identify vulnerabilities, and create strategies to safeguard businesses and individuals from fraudulent activities.

UKDI Fast-Paced Innovation Competition Enters New Phase with Fresh Defence Funding

The UKDI fast-paced innovation competition has entered a new phase after the UK Ministry of Defence’s innovation unit, UK Defence Innovation (UKDI), announced fresh funding rounds aimed at accelerating defence and security technology development across the United Kingdom. The programme opened its latest competition phase in early 2026, inviting companies, universities and research organisations to submit proposals that address emerging defence challenges. The initiative operates through rapid funding calls designed to move ideas from concept to testing quickly, supporting technologies that strengthen national security and defence capability.

The competition is administered through the UK Government’s defence innovation framework and aims to encourage collaboration between the private sector, academia and defence agencies. Successful applicants may receive government-backed funding to develop prototypes, conduct feasibility studies and demonstrate practical applications.

Why this matters

Innovation programmes linked to defence spending often influence wider sectors of the economy. Funding competitions from government bodies can create opportunities for technology companies, research institutions and specialist manufacturers.

The new phase of the UKDI fast-paced innovation competition signals continued government investment in emerging technologies, particularly those that can be deployed rapidly. For UK businesses operating in engineering, data science, cybersecurity, robotics and advanced manufacturing, the programme represents a potential source of research funding and commercial partnership.

Key points

  • The UK Defence Innovation unit has launched a new phase of the UKDI fast paced innovation competition.
  • The programme funds rapid development of defence and security technologies.
  • UK companies, research institutions and universities can submit proposals.
  • Projects may receive government funding to test prototypes and new concepts.
  • The scheme supports collaboration between industry and the Ministry of Defence.

What Has Happened

The Ministry of Defence has opened a new round of submissions under the UKDI Fast-Paced Innovation Competition, a programme designed to identify and support innovative technologies that could strengthen UK defence capabilities.

The competition typically operates through short application windows. Proposals are assessed quickly, with selected projects receiving funding to move from concept to demonstration within a relatively short timeframe.

The objective is to reduce the gap between research and operational use, allowing defence agencies to evaluate new solutions more rapidly than traditional procurement processes allow.

Government-backed innovation programmes often focus on emerging areas such as:

  • Artificial intelligence and data analysis
  • Autonomous systems and robotics
  • Advanced sensing technologies
  • Cybersecurity tools
  • Resilient communications infrastructure

Background and Context

UK defence innovation programmes have expanded over the past decade as governments attempt to accelerate technology development and maintain strategic advantage.

The Ministry of Defence has used a number of mechanisms to support innovation, including the Defence and Security Accelerator (DASA) and other targeted funding competitions. These programmes provide grants or contracts to organisations developing technologies that could support defence operations or national security.

The fast-paced competition model reflects a shift in procurement strategy. Traditional defence procurement often involves lengthy development cycles. Rapid competitions aim to identify promising technologies earlier and test them quickly.

Government innovation funding also supports the UK’s broader industrial strategy. By funding research and development projects, the government encourages collaboration between private companies, universities and defence agencies.

Key Details and Changes

Although competition themes may vary by round, the structure typically includes:

  • Open calls inviting proposals from UK businesses and research organisations
  • Short application windows designed to speed up evaluation
  • Funding for feasibility studies, prototype development or testing
  • Collaboration between technology developers and defence stakeholders

Projects selected through the programme may move forward to further development stages if early testing proves successful.

Who Is Affected

The UKDI fast-paced innovation competition is relevant to several sectors:

  • Technology startups working in defence-related innovation
  • Advanced engineering firms
  • Cybersecurity companies
  • Universities and research laboratories
  • Data analytics and AI developers

Small and medium-sized enterprises often benefit from such competitions because they provide access to funding and defence-sector partnerships that might otherwise be difficult to secure.

However, participation also requires careful planning around intellectual property, compliance with government contracting rules and financial reporting requirements.

Apex Accountants Insight

Government innovation competitions can provide valuable funding and strategic partnerships for technology businesses. Yet they also introduce operational and financial considerations.

Projects supported by public funding may require:

  • Formal project accounting and reporting
  • Grant compliance documentation
  • VAT treatment assessments where funding is linked to deliverables
  • R&D tax relief analysis where applicable

Businesses receiving innovation funding should review how the funding is structured. Some grants may qualify for specific tax treatment, while others could influence eligibility for relief schemes such as R&D tax credits.

Strong financial oversight is essential during innovation projects. Research programmes often involve staged funding and milestone payments, which require careful accounting.

Why This Matters for UK Businesses

Innovation competitions linked to defence spending can influence the wider technology ecosystem.

Potential impacts include:

  • Increased research funding for technology firms
  • New collaboration opportunities between industry and government
  • Faster development cycles for emerging technologies
  • Growth opportunities for defence-related startups

However, businesses must also consider compliance requirements tied to government funding. Financial reporting, grant conditions and intellectual property arrangements can create administrative complexity.

What Businesses Should Do

Companies considering participation in innovation competitions should:

  • Review eligibility requirements before applying
  • Assess financial reporting obligations linked to grant funding
  • Evaluate intellectual property implications of government partnerships
  • Consider tax treatment of funding and development costs
  • Maintain clear project accounting records

Professional financial advice can help businesses manage these obligations effectively.

How We Can Help

Businesses participating in the UKDI fast-paced innovation competition may face complex financial, tax and reporting requirements. Innovation funding can affect accounting treatment, VAT obligations and eligibility for R&D tax relief.

Apex Accountants & Tax Advisors supports companies involved in research and innovation projects across the UK. Our services include:

  • Accounting support for grant-funded projects
  • R&D tax relief reviews and claims
  • Financial reporting for government-funded programmes
  • VAT treatment of innovation grants
  • Strategic financial planning for technology businesses

Need guidance on innovation funding or R&D tax relief? Contact Apex Accountants today.

Conclusion

The latest phase of the UKDI fast-paced innovation competition highlights the UK government’s continued focus on accelerating defence-related technological development. By providing funding and rapid evaluation processes, the programme encourages collaboration between industry, academia and government.

For businesses operating in advanced technology sectors, the competition may offer opportunities for funding and partnership. Careful financial management and compliance planning remain essential for organisations seeking to benefit from government-backed innovation programmes.

UK Economy in 2026: Retail Sales Rise, Exports Strengthen and Public Finances Record Surplus

The UK economy in 2026 is stronger than many expected. Retail sales rose sharply in January. Export demand improved. The Government recorded a significant monthly surplus in public finances.

At the same time, unemployment remains elevated in certain regions. Business tax pressures are still present. Growth forecasts remain modest.

So what is really happening? And what should businesses do now?

At Apex Accountants, we look beyond headlines. Below, we break down the facts, explain the drivers, and outline practical actions for UK businesses.

Snapshot: What the latest data shows

Here is a summary of the key figures reported for early 2026:

IndicatorLatest FigureWhat It Means
Retail sales growth (January)+1.8%Strongest monthly rise in over a year
December retail growth+0.4%Shows upward momentum
UK Composite PMI (February)53.9Activity expanding (above 50)
Public sector surplus (January)£30.4bnHighest January surplus on record
Self-assessment receipts£29.4bn£3.6bn higher than previous year
London unemployment rate7.6%Above national average (5.2%)

The numbers show economic momentum in spending and exports. However, the labour market remains under pressure in some areas.

Retail sales rebound: What it means for businesses

Retail volumes rose by 1.8% in January. This is significant. It suggests consumers returned to spending after a cautious end to 2025.

Why spending increased

Several factors contributed:

  • Post-holiday promotions and discounting
  • Slight easing in inflation pressures
  • Wage growth stabilising real income
  • Increased online purchasing

Non-store retail activity performed strongly. Jewellery and discretionary goods saw notable demand.

What this means for business owners

Retail growth can improve cash flow in the short term. However, this does not mean consumer confidence is fully restored.

Businesses should:

  • Monitor sales trends monthly
  • Review stock management carefully
  • Avoid over-expansion based on one strong month
  • Maintain tight cost control

Spending is improving. But it remains selective.

Exports and private sector growth: A positive signal

The UK composite PMI reading of 53.9 indicates expansion. Any reading above 50 shows growth.

Export orders increased at the fastest pace since 2021. This supports manufacturers and internationally focused businesses.

What is driving export growth?

  • Improved global demand conditions
  • Competitive pricing from sterling movements
  • Services sector resilience

The services sector remains the largest driver of UK economic activity. Hospitality, finance, healthcare and leisure contributed to growth.

Strategic takeaway

If your business trades internationally:

  • Review export pricing structures
  • Consider currency exposure management
  • Assess new market opportunities

Export demand recovery can provide growth opportunities. However, global conditions remain uncertain.

Public finances surplus explained

January recorded a £30.4 billion public sector surplus. This means government receipts exceeded spending for the month.

This was largely due to:

  • Strong self-assessment tax receipts
  • Income tax threshold freezes
  • Lower debt interest payments

Self-assessment receipts reached £29.4 billion. This was significantly higher than the previous year.

Why this matters for taxpayers

A surplus does not mean tax cuts are imminent. In fact:

  • Income tax thresholds remain frozen
  • Fiscal headroom is still tight
  • Government borrowing levels remain historically high

Businesses and individuals should not assume immediate tax relief.

Labour market concerns: A key risk factor

While spending and exports improved, employment data presents challenges.

London’s unemployment rate has risen to 7.6%. Youth unemployment stands significantly higher.

Sectors affected include:

  • Hospitality
  • Retail
  • Entry-level services

This creates a mixed economic environment. Strong spending data does not remove labour market pressures.

Practical actions for business owners

Economic data provides direction. But strategy matters more. Here is what we advise clients at Apex Accountants:

Cash flow first

  • Review cash flow forecasts monthly
  • Build contingency reserves
  • Plan for tax liabilities early

Tax planning

  • Assess self-assessment and corporation tax exposure
  • Use available reliefs properly
  • Review dividend strategy

Cost control

  • Audit fixed costs
  • Renegotiate supplier contracts
  • Monitor payroll growth carefully

Growth decisions

  • Avoid reacting to one month’s data
  • Base expansion on sustainable revenue
  • Stress-test projections

Short-term improvement does not remove long-term risks.

Sector outlook summary

SectorCurrent OutlookRisk Level
RetailImproving but cautiousMedium
HospitalityDemand rising, labour pressureMedium–High
ManufacturingExport boost positiveMedium
Professional servicesStableLow–Medium
SMEs overallGrowth modestMedium

This environment rewards careful planning. Overconfidence can create problems.

How We Help Businesses in UK

At Apex Accountants, we support businesses through economic shifts with practical financial guidance.

Our services include:

  • Corporation tax planning
  • Self-assessment tax advice
  • VAT compliance and strategy
  • Management reporting
  • Cash flow forecasting
  • Virtual CFO services
  • Business growth strategy
  • Budgeting and forecasting

We focus on clarity, reduce risk, and help you make informed decisions.

Economic data changes every month. Strong financial structure protects your business in both good and challenging periods.

Conclusion

Early 2026 has started with encouraging signals. Retail spending has improved. Export demand has strengthened. Public finances showed a strong January surplus.

However, unemployment pressures remain. Growth forecasts are still modest. Tax burdens remain elevated.

The UK economy is stabilising. It is not booming.

For business owners, the message is clear:

  • Stay disciplined
  • Plan ahead
  • Monitor cash closely
  • Optimise your tax position

Economic momentum can support opportunity. But financial control determines long-term success.

If you would like tailored advice on how current economic conditions affect your business, contact Apex Accountants today and book a consultation.

FAQs About UK Economy in 2026

Based on current UK search trends and client discussions, common questions include:

1. Is the UK economy recovering in 2026?

There are signs of short-term improvement. Retail and exports are stronger. However, growth is expected to remain modest overall.

2. Will taxes increase again?

There are no confirmed new increases at present. However, threshold freezes continue to increase effective tax burdens.

3. Should businesses expand now?

Expansion decisions should be based on cash flow strength and sector-specific performance. Caution remains important.

4. Is inflation still a risk?

Inflation has eased from peak levels. However, cost pressures remain for energy, wages and supply chains.

Proposed ISA Cash Rules: Government Response and Investor Impact

The Autumn 2025 Budget confirmed major changes to Individual Savings Accounts (ISAs) aimed at pushing savers out of low-yield cash and into investments. From 6 April 2027 the annual cash ISA allowance for under‑65s will fall from £20,000 to £12,000. To stop savers simply shuffling funds between accounts, new draft regulations propose anti‑avoidance measures. For example, transfers from stocks and shares ISAs into cash ISAs would be blocked, and “cash‑like” asset tests would determine what investments are allowed in a stocks and shares ISA. Crucially, HMRC has signalled it will charge a tax rate on ISA cash interest earned on cash held inside a stocks-and-shares or Innovative Finance ISA. In effect, these ISA cash rules would revive the pre-2014 rule where idle cash in a stocks and shares ISA was taxed at 20%. The new cap and anti-avoidance rules explicitly apply to savers under 65; over-65s retain a £20,000 ISA cash limit.

  • New cash ISA limit (from April 2027): £12,000 per year for under‑65s (Over-65s stay at £20,000).
  • Transfer restrictions: No transfers from stocks-and-shares or IF ISAs into cash ISAs.
  • “Cash‑like” tests: Criteria will define which assets (e.g. short-term bonds or money-market funds) count as too cash-like to hold in a stocks-and-shares ISA.
  • Interest charge: Any interest paid on cash held in a stocks-and-shares ISA would be taxed, likely at a flat rate around 20%.

These rules were announced in HMRC’s November 2025 tax-free savings newsletter and are subject to industry consultation on the draft legislation. The government’s goal is to encourage long-term investing by making cash ISAs comparatively less attractive. However, the proposals have sparked concern from financial firms, and recent industry-HMRC talks suggest the plans may be softened in response.

Industry Feedback and Potential Softening of ISA Cash Rules

Many investment platforms and asset managers warned that the draft ISA rules were overly complex and could deter savers. For example, AJ Bell’s CFO Michael Summersgill cautioned that taxing idle cash in a stocks-and-shares ISA would “punish retail investors for using the stocks and shares ISA the way it was designed”. He noted that money flows in and out of these ISAs routinely (contributions, dividends, withdrawals) and urged the Chancellor to avoid “horrendous complexity” in the ISA regime. Others pointed out that no ISA can truly be “cash-free” – even routine operations use cash – and that aggressive bans on cash-like assets could undermine savers’ flexibility.

After these warnings, HMRC officials held detailed discussions with industry groups. According to sources, the tone of negotiations has shifted. Platforms report a growing sense that HMRC might ease the hardest measures on cash and cash-like investments. 

One leading investment platform said it was “cautiously optimistic” that HMRC will favour a principles-based approach rather than rigid rules. Another provider remarked they were “a lot more confident [HMRC is] coming around than we were this time two weeks ago”. In other words, talks have opened the door to compromise on both the proposed interest levy and on how “cash-like” is defined.

Indeed, industry participants expect final rules only after further consultation and technical refinements. HMRC has promised a full public consultation on the draft ISA Regulations ahead of implementation. As one government spokesperson told accountants, the aim is to prevent “easy circumvention” of the new cash limit, but HMRC is “listening to concerns and engaging collaboratively” with providers. This suggests some flexibility: the final framework may include targeted safeguards and guidance, rather than inflexible bans.

Key Industry Concerns Regarding New ISA Cash Limits

Interest charge level: 

The proposed tax rate on ISA cash interest is still undetermined. Industry papers have speculated on flat rates around 20% or even 22%. (AJ Bell and others initially feared a 22% flat rate on such interest.) HMRC has not confirmed a rate, but a common assumption is 20%, mirroring the old regime.

Cash-like definitions: 

What counts as “cash-like” is a grey area. Money market funds, short-dated gilts or corporate bonds could be deemed cash-like. Building societies are pushing for tighter rules here, arguing cash-rich MMFs harm bank funding. Conversely, platforms note that small cash buffers and money-market holdings help investors ease into equities. Freetrade’s Alex Campbell calls cash-like funds “a perfect stepping stone into investing” for novices. The Treasury Committee has already asked pointed questions about what counts as cash-like, and HMRC will clarify these criteria in the consultation.

Complexity and investor impact: 

There is broad concern that restrictive ISA changes could deter savers. Tom Selby of AJ Bell warned a “heavy-handed approach” to anti-avoidance “will undermine stocks-and-shares ISAs” at a time when the government wants more retail investment. Justin White of Kaldi argued that discouraging use of cash and cash-like assets in ISAs might confuse new investors, defeating the policy’s aim to close the investment gap. In short, providers fear that discouraging safe cash buffers could backfire unless carefully balanced with investor education and flexibility.

Potential Compromises and Safeguards

Given these reactions, HMRC is reportedly considering softer measures. For example, rather than an automatic tax hit, regulators may rely on platforms to monitor excessive cash balances and encourage customers to invest more. One compromise under discussion would let providers set proportionate cash thresholds and flag idle balances, instead of blanket bans. Providers could also agree not to offer artificially high interest rates on ISA cash, removing the arbitrage that the tax charge seeks to close. IG Group’s Michael Healy notes platforms already track ISA cash levels and could distinguish normal “transactional” cash from long-term parked cash.

On money market funds, HMRC may opt for targeted restrictions rather than an outright ban. A source said regulators now recognise that banning MMFs “outright could do more harm than good for investors”. Safeguards might include limiting high-interest MMFs or classifying them as cash-like, rather than excluding all such funds. Importantly, any transitional cash (e.g., pending investment) is expected to be carved out of the tax levy.

On transfers, HMRC appears set on the no-transfer rule as a hard line but might clarify exceptions. For instance, existing ISAs opened before the change may be grandfathered, and normal intra-ISA transfers (e.g., cash ISA to cash ISA) will still work. The government has emphasised it will provide “clear guidance before the changes come into effect”, so providers and savers can prepare.

At a glance, the likely outcome is a framework where savers can still hold some cash in investment ISAs, but large, long-term cash positions lose their tax advantage. A practical compromise could involve:

  • Platforms automatically channel large cash balances into equity or bond investments, unless the saver specifically opts out.
  • Caps on ISA interest rates (to stop promotional “top-up” offers that gamers could exploit).
  • A clear definition of minimal cash allowed (e.g., a few per cent of the portfolio for liquidity).
  • Detailed guidance or FAQs from HMRC on scenarios like dividends, pending trades, or modest emergency buffers.

While details await legislation, platforms are already modelling responses. Firms preparing now will adapt their ISA account structures and customer communications before April 2027.

From an investor’s standpoint, it’s wise to:

  1. Maximise the remaining cash ISA allowance: With the £20,000 limit intact until 2027, many advisers suggest using the full cash ISA cap now if you value tax-free cash.
  2. Review your ISA asset mix: Plan how much to park in equities vs cash. If you rely on ISAs for cash income, consider alternative wrappers (e.g. bonds outside ISAs or simply accepting tax on savings).
  3. Stay informed: Watch for HMRC updates and consult your financial adviser. ISA rules are technical, and professional advice can help navigate compliance.

How We Help Our Clients Navigate The Proposed ISA Changes

At Apex Accountants, we’re monitoring these ISA developments closely to help clients adapt. Our services include:

  • ISA Review & Planning: We analyse your current ISA holdings and cash allocations, advising on tax-efficient strategies under the new rules.
  • Investment Structuring: We help clients balance cash and equity exposures, taking into account any “cash-like” restrictions.
  • Tax Compliance: Our team ensures all reporting (including interest receipts) is handled correctly in line with HMRC guidance.
  • Regulatory Updates: We keep you informed of any changes to ISA regulations, so you’re never caught by surprise.
  • Consultation Support: For businesses or investors, we can liaise with you on technical questions or draft responses to HMRC consultations.

Our experts simplify complex tax news into actionable advice. If you’re concerned about how the ISA reforms might affect your savings or investments, contact Apex Accountants for a consultation. We’ll help you make the most of the current ISA rules and prepare for the changes ahead.

Conclusion

In summary, the UK government’s ISA reforms aim to steer savers toward investment accounts, but the strongest measures (like high cash-interest taxes and strict cash-like tests) may be trimmed after industry feedback. Official drafts will follow in due course, with HMRC indicating a collaborative approach. Savers should keep an eye on developments: the broad direction is clear, but final rules may be more flexible than first feared. For now, focus on making the most of existing ISA allowances and seek professional advice to stay compliant. As always, Apex Accountants will update clients on any final ISA legislation and advise on the best strategies to protect and grow your savings.

FAQ: Key Questions for Savers

1. Will interest on cash in my Stocks & Shares ISA be taxed? 

Under the draft rules, any interest earned on cash held in a stocks-and-shares or IF ISA would lose its tax-free status. The government’s current plan is a flat charge of about 20% on that interest. No double taxation is intended – you would pay this special ISA charge instead of normal savings tax.

2. What counts as a “cash-like” investment? 

HMRC will define cash-like assets in the consultation. Likely candidates include money market funds, short-dated gilts/bonds or other very low-risk funds. The intention is to stop people using such assets to skirt the £12k cash limit. We expect guidance to clarify this well before April 2027.

3. Can I still move money between ISAs? 

Cash-to-cash ISA transfers remain allowed. However, transfers from a stocks & shares or IF ISA into a cash ISA would be blocked under the new rules. All other ISA-to-ISA transfers (e.g. between cash ISAs, or within stocks & shares ISAs) should still work normally.

4. What if I need emergency cash? 

The proposals don’t ban holding any cash in investment ISAs, they target excessive cash balances. HMRC is aware that savers need some liquidity. Early guidance suggests small cash buffers (for example, unsettled trades or dividend income waiting to reinvest) may be exempt from the interest charge.

5. When will these changes happen? 

The new rules are set to apply from 6 April 2027. HMRC will consult on the draft legislation before then. Expect technical details to emerge throughout 2026. It’s prudent to plan for the changes, but final outcomes could be milder than originally drafted.

HMRC Is Hiring Valuation Agents Ahead of New Mansion Tax Plans

The High Value Council Tax Surcharge, often referred to as a “mansion tax”, is a new annual charge on owners of residential properties in England valued at £2 million or more based on 2026 valuations. It was announced in the 2025 Budget and is expected to come into effect from April 2028. As part of the preparation for this policy, HMRC is hiring valuation agents to support the assessment of high-value properties and identify those that fall within scope. The charge will apply to property owners rather than occupiers and will be payable alongside standard Council Tax. Social housing will be excluded from the scope of this surcharge.

Key facts include:

  • Threshold and Bands: Properties valued £2.0m–2.5m pay £2,500 per year; £2.5m–3.5m pay £3,500; £3.5m–5.0m pay £5,000; and homes over £5m pay £7,500 (based on 2026 valuations). These charges will rise each year with CPI inflation from 2029‑30 onwards.
  • Scope: Fewer than 1% of homes in England will pay this surcharge. The Valuation Office Agency (VOA) will run a targeted valuation exercise during 2026 to identify all properties above £2m. Existing Council Tax will continue unchanged; the surcharge revenue goes to the Treasury (though collected by local councils).
  • Frequency: Once identified, affected homes will be re-valued on a rolling basis every 5 years. A public consultation on details (reliefs, appeals, ownership rules etc.) was held early 2026. Further consultations will cover support for those who struggle to pay, reliefs/exemptions, and complex ownership arrangements.

Also Read: The Problems with the Mansion Tax: A Closer Look at Design Issues and Criticisms

Why Is HMRC Hiring Valuation Agents?

HMRC is recruiting up to 1,000 new valuation officers in anticipation of this surcharge. About a third of these roles will help implement the high-value surcharge, with the rest covering other priorities (such as customs checks on goods). The VOA (responsible for council tax banding) is being merged into HMRC in April 2026, and will use these extra staff to carry out property revaluations.

According to Treasury officials, these hires will peak in 2027–28 and 2028–29 to handle the extra workload. VOA Chief Executive Jonathan Russell told MPs that the agency plans to use “professional valuers” and additional support staff to assess homes potentially in scope. In fact, the VOA has said it will review not just homes over £2m, but also many houses from about £1.5m upwards, to make sure nothing is missed.

The Treasury’s own analysis suggests roughly 150,000–200,000 properties could be caught by the surcharge. For example, any house that might now be worth over £2m (and even up to £5m) is likely to be rechecked. These figures come from VOA estimates and parliamentary evidence; current Council Tax band data shows under 1% of homes are above £2m, but the broader review up to £5m (and including £1.5m+) expands the pool to about 0.5–0.7% of properties.

What This Means for Homeowners

Who pays: 

Only owners of qualifying homes pay the surcharge – not tenants or lodgers. That means any mortgage or equity-share owner on the title at the valuation date (2026) would be liable.

Where it applies: 

Only homes in England are affected. Northern Ireland, Scotland and Wales use different systems. Social housing (council and housing association homes) is explicitly exempt.

How payments work: 

The new charges will be collected by local councils alongside normal Council Tax, but funds go to central government. Owners will get an annual bill. The surcharge is in addition to existing Council Tax, not a replacement.

Valuation and appeals: 

The VOA will use up-to-date market data (2026 values) and property attributes (size, location, features) to assess each home. In most cases the initial valuations will be done by officials (a “desk-based” valuation using sales data and maps). However, homeowners can challenge their surcharge valuation through a formal appeals process, details of which will be set out in new legislation. Affected owners should keep property records (purchases, improvements, planning info) handy.

Timeline: 

VOA valuations are expected to start in late 2026 or early 2027, so that bills can be ready for 2028. HMRC has not confirmed exactly when each house will be reviewed, but Jonathan Russell told MPs the review of high-value homes will begin this year (2026). Revaluations will then follow every five years for properties over the threshold.

Also Read: Mansion Tax in UK to Affect 200,000 Homes Starting in 2028

How We Help Deal With Mansion Tax

Apex Accountants can help high-value homeowners and professionals prepare for the new surcharge:

  • Property Review: Analyse your property portfolio. If any home may be near £2m (or held by company/ trust), we check the likely 2026 value.
  • Tax Planning: Advise on timing sales/purchases. Build the surcharge into financial planning. Model the annual cost and cash flow.
  • Ownership Structuring: Guide on whether to own property in a company, trust, joint names or a partnership. We will stay up-to-date on the government’s consultation outcomes for complex ownership.
  • Valuation Support: Help provide information to the VOA valuers. Ensure improvements and unique features of your property are documented to justify value.
  • Appeals Assistance: If you believe an assessment is too high, we can work with you (and a surveyor if needed) to submit evidence and appeal the valuation.

Conclusion

The new high-value Council Tax surcharge is now law, with detailed rules to follow a public consultation. From 2028 on, owners of homes worth £2m+ (and some up to £5m) will pay an extra annual tax. HMRC’s VOA is already preparing for this by recruiting specialist valuers and planning assessments for up to 200,000 homes. For those potentially affected, early preparation is key – understanding the bands and possible reliefs and keeping good records will make the transition smoother.

UK Buy-To-Let is Going Corporate As Landlords Respond To Tax Pressure

In the UK private rented sector, the big structural shift is no longer just “landlords selling up” or “rents rising”. It is how landlords are buying and holding property: increasingly through limited companies rather than personal names. This trend is particularly evident in the UK buy-to-let market, where tax and financing pressures are reshaping how investors structure their portfolios.

The newest incorporation figures point to a market that is still accelerating. Hamptons (using Companies House records) reports that:

  • 66,587 new buy-to-let companies were formed in 2025, a new annual record. That is 8% higher than 2024 and 363% higher than a decade earlier. 
  • The pace continued into 2026, with 5,922 new buy-to-let limited companies created in January 2026, 11% higher than January 2025. 
  • By the end of 2025, there were around 443,272 active buy-to-let companies on the register—nearly five times the 2016 figure quoted in the same analysis. 

For information on the mansion tax impact on your property, read: Analysing the Impact of Mansion Tax on the Prime Property Market in UK

The Shift Towards Corporate Ownership in the UK Buy-to-Let Market

This is not a niche move by “mega landlords”. It is now the dominant route for many new investor purchases. Hamptons says around three-quarters of new buy-to-let purchases are being made through limited companies, and trade reporting puts it as high as around four-fifths. 

On ownership, the shift is visible in land title data too. Across England and Wales, 755,042 property titles are now held by buy-to-let companies, up from 272,964 around a decade earlier. Hamptons estimates that this corresponds to roughly 1.5 million rental homes held inside limited company structures. 

At the same time, investors are actually a slightly smaller slice of overall home purchases than a year ago. Hamptons puts investors’ share at 10.8% of purchases in 2025, down from 11.9% in 2024. The takeaway is simple: fewer purchases are “landlord purchases” overall, but a larger share of landlord purchases are corporate. 

Why Landlords Are Incorporating Now

From an accountancy standpoint, the surge is not mysterious. It is the combined effect of tax rules, fiscal drag, borrowing costs, and upcoming regulation.

Mortgage Interest Relief Changes

Mortgage interest relief rules changed the baseline. Since April 2017, tax relief for finance costs on residential property for individuals has been restricted and was fully in place by April 2020.

In practice:

  • Individual landlords can no longer deduct mortgage interest fully from rental income
  • Relief is now limited to the basic rate via a tax reduction

For landlords with significant borrowing, this creates pressure:

  • Taxable income may appear higher than actual cash profit
  • Some landlords are pushed into higher tax bands

This has made the traditional personal ownership model less tax efficient.

Fiscal Drag and Frozen Tax Thresholds

Frozen income tax thresholds are quietly increasing tax burdens.

  • Personal allowance: £12,570
  • Higher-rate threshold: £50,270

These thresholds have been frozen for several years.

When income rises but thresholds stay the same:

  • More landlords move into the 40% tax band
  • Overall tax liability increases without real growth in profits

This effect is widely referred to as fiscal drag.

Corporation Tax Advantage

Limited companies are taxed differently.

  • 19% corporation tax on profits up to £50,000
  • 25% corporation tax on profits above £250,000
  • Marginal relief applies between these limits

Compared with:

  • 40% income tax for higher-rate individual landlords

This creates a strong incentive to operate through a company, especially for landlords with larger portfolios or higher incomes.

Impact of Rising Borrowing Costs

Higher mortgage rates have also played a role.

  • Individual landlords face restricted interest relief
  • Company landlords can still deduct full finance costs

This means:

  • Companies often show lower taxable profits
  • Cash flow can be more manageable under a company structure

For leveraged investors, this difference is significant.

Dividend Tax Changes from April 2026

Tax efficiency does not end at corporation tax.

Many landlords take profits out of their company through dividends. However, changes from April 2026 will affect this:

  • Ordinary rate increases from 8.75% to 10.75%
  • Upper rate increases from 33.75% to 35.75%
  • Additional rate remains at 39.35%

This means:

  • Taking profits out becomes more expensive
  • Retaining profits within the company becomes more attractive

Reinvest vs Withdraw Strategy

The right structure now depends heavily on how profits are used.

  • If profits are reinvested, a company structure can remain efficient
  • If profits are withdrawn regularly, the tax advantage may reduce

There is no single “best” option. Each landlord’s position must be reviewed individually.

For insights on reducing tax through capital allowances, read our article: How to Claim Capital Allowances on Commercial Property in the UK.

Limited Company Versus Personal Name: The Tax Reality

At Apex Accountants, we see the same misconception again and again: “A limited company always reduces tax.” It can, but only when the numbers and the landlord’s goals line up. 

Here is the clean way to think about it.

If you hold buy-to-let personally:

  • Rental profit is subject to income tax. For many landlords in Great Britain, the relevant bands are 20%, 40% and 45%, with the personal allowance tapering away above £100,000 and reaching zero at £125,140. 
  • Mortgage interest relief is restricted for individuals, phased in from 2017 and fully implemented from 2020. 
  • When you sell an investment property, capital gains tax applies for individuals. From April 2025 onwards, residential property gains are taxed at 18% (basic-rate band) and 24% (higher/additional-rate band). 

If you hold a buy-to-let limited company:

  • Rental profit is subject to corporation tax (19%/25% with marginal relief, depending on profit levels). 
  • Mortgage interest is generally treated as a business expense in computing taxable profits. This is the practical contrast that keeps coming up in landlord incorporation commentary following the finance cost restriction for individuals. 
  • Tax does not stop at corporation tax if you want the money personally. If you extract profits, dividend tax rules apply (and the headline rates increase from April 2026 as noted above). 

What usually makes the buy-to-let limited company route work best

  • You are a higher-rate taxpayer (or close to it) because of employment income plus rents, and your borrowing costs are meaningful. 
  • You plan to leave profits inside the company to repay debt or fund the next purchase, rather than drawing everything each year. 
  • You want a structure that supports co-investment more cleanly. Hamptons-linked reporting highlights a growing share of buy-to-let companies with multiple shareholders. 

When personal ownership can still be better

  • Your total income keeps you firmly in basic rate, and your borrowing is modest. (The finance-cost restriction tends to bite hardest at higher-rate levels.) 
  • You rely on rental profits for day-to-day living costs. In that case, the “second layer” tax on extraction becomes more relevant—especially with dividend rate rises. 
  • Your portfolio is small enough that the compliance cost and admin time outweigh the marginal tax gains. Hamptons also flags Companies House filing fees rising faster than inflation in recent years. 

Costs, Traps and Compliance That Many Landlords Underestimate

The incorporation trend is clear. However, it is not frictionless. Many landlords focus on tax savings, but the real risks often sit in three areas: transferring properties, ongoing costs, and regulatory changes that affect income.

Transferring Properties into a Company

Moving property into a limited company is not a simple administrative step.

In most cases, HMRC treats transfers between connected parties at market value. This applies even where no money changes hands.

In practice, this can trigger two immediate tax exposures. The individual may face Capital Gains Tax on the disposal, while the company may be liable for Stamp Duty Land Tax based on the market value. In addition, higher rates for additional properties often apply.

These combined costs can be substantial and need to be calculated carefully before any transfer.

Incorporation Relief and Practical Limitations

In certain cases, Incorporation Relief can defer Capital Gains Tax. This applies when a business is transferred as a going concern in exchange for shares.

However, the key issue is whether a buy-to-let portfolio qualifies as a “business”. This is a fact-sensitive area. HMRC looks at the level of activity, not just ownership of properties.

For many landlords, the answer is not straightforward. This is why tax modelling and proper documentation are essential before proceeding.

Rising Company Running Costs

The idea that property companies are cheap to run is becoming outdated.

Companies House fees have increased, with incorporation fees doubling and confirmation statement fees rising. These changes reflect wider regulatory reforms and identity verification requirements.

Alongside these, landlords must factor in accountancy fees, annual filings, and ongoing compliance. Over time, these costs can become significant, especially for smaller portfolios.

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SDLT Rules for Company Purchases

Stamp Duty Land Tax rules are stricter for companies than for individuals.

Companies purchasing residential property generally pay higher rates. In some cases, particularly for higher-value properties, a rate of up to 17% can apply.

Recent changes have also removed some planning opportunities. Multiple Dwellings Relief was withdrawn from June 2024, and large acquisitions are now treated differently under non-residential rules.

This makes upfront cost planning even more important when acquiring property through a company.

Changing Tenant Law and Rent Controls

Regulation is also changing how landlords manage their income.

Under the Renters’ Rights reforms, rent increases will follow a single, more structured process. In most cases, rent can only be increased once a year, with at least two months’ notice, using the statutory procedure.

Tenants will also have the right to challenge increases through the First-tier Tribunal. The tribunal will assess whether the rent reflects the market level, and landlords will not be able to backdate higher rents following a challenge.

These changes are designed to make rent setting more transparent, but they also introduce new constraints for landlords.

Impact on Cashflow and Rent Strategy

These regulatory changes have direct implications for cashflow.

Landlords now need to be more precise when setting rents. Increases must reflect market conditions from the outset, as adjustments later may be challenged.

Recent market data reflects this shift. Newly-let rents have slightly declined, while renewal rents have continued to rise, although at a slower pace. This suggests that landlords are becoming more cautious and aligning rents more closely with market levels.

Why Landlord Tax Planning Matters More Than Ever

Incorporation can still be effective in the right circumstances. However, it is not a simple decision based on headline tax rates.

You need to consider the full picture, including transfer costs, ongoing compliance, financing, and how you plan to use the income.

Without careful planning, the structure can create unexpected tax charges or reduce overall efficiency. A detailed review is essential before making any changes.

How Apex Accountants Can Help

At Apex Accountants, we approach landlord incorporation and portfolio structuring as a numbers-led exercise. Not a trend-led one.

Our day-to-day work in this space typically includes:

  • Personal vs limited company modelling

We run side-by-side forecasts using current income tax thresholds, corporation tax bands, and the post-2017 finance cost rules. 

  • Incorporation planning for existing portfolios

We assess exposure to SDLT and capital gains calculations, and we review whether reliefs like Incorporation Relief are even in scope given HMRC’s conditions. 

  • Company compliance built for property businesses

Confirmation statements, statutory accounts, director/shareholder housekeeping, and practical support around the continuing Companies House reforms and fee changes. 

  • Rent and tenancy change readiness

We help landlords understand how rent-setting and cashflow could shift under the Renters’ Rights framework, particularly around annual rent increases and the tribunal challenge process. 

  • Ongoing landlord tax planning support

Self Assessment for individuals, corporation tax for property companies, and profit extraction planning in light of the upcoming dividend tax rate changes. 

Conclusion

The headline numbers tell the story: 2025 set a record for buy-to-let company formations, and January 2026 suggests the trend is not cooling. The drivers are structural. Restricted finance cost relief for individuals, frozen thresholds pulling more landlords into higher-rate tax, and the gap between personal and corporate tax treatments are all influencing decisions.

But “incorporate” is not a universal answer. It is a strategy with trade-offs. There can be SDLT and capital gains implications when transferring existing properties, higher ongoing admin costs, and a second layer of tax when profits are extracted. From April 2026, dividend tax rates will increase, which makes planning even more important.

You can contact Apex Accountants to discuss your position and get clear, tailored advice on the most suitable structure for your circumstances.

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