A Complete Guide on Hair and Beauty Tax Rules in the UK

Hair and beauty businesses often use flexible working models. A salon may have employees, chair renters, mobile stylists, freelance beauty therapists, and room renters working under one roof.

That flexibility can work well, but it also creates tax risk.

The key issue is not just what a contract says. The real working arrangement matters too. As per the hair and beauty tax rules, workers in this industry are either employed or self-employed, and that status affects income tax, national insurance, and VAT responsibilities.

For salon owners, barbers, nail technicians, beauty therapists, and chair renters, this is now a good time to review contracts, payment flows, client ownership, and VAT treatment.

At Apex Accountants, we help hair and beauty businesses get these areas right before small issues become expensive problems.

What is the new tax guidance for hair and beauty services?

The latest focus is on how people actually work in salons, barbershops, and beauty studios.

There is no special new tax rate for hair and beauty services. The real change is clearer guidance on employment status and VAT treatment.

This matters because the wrong setup can affect the following:

AreaWhy it matters
Employment statusIt affects who pays Income Tax and National Insurance.
Chair rentalIt can create VATable income for the salon.
Client paymentsIt affects who reports sales and VAT.
Self-AssessmentFreelancers may need to file tax returns.
Making Tax DigitalSome sole traders now need digital records.

The main lesson is simple. A business model must match daily working practice.

HMRC employment status guidance for the hair and beauty industry – employment or self-employed

Employment status is one of the biggest tax issues in hair and beauty.

A person may be called ‘freelance’, ‘self-employed’ or a ‘chair renter.’ That label is not enough. The actual working pattern must support it.

The contract and the daily setup both matter.

Working pointMore like employedMore like self-employed
HoursSalon sets hoursWorker chooses hours
Days workedSalon decidesWorker decides
ClientsSalon provides clientsWorker finds own clients
ProductsSalon provides productsWorker buys or chooses products
TasksSalon controls dutiesWorker manages own work
PayFixed wage or rateWorker sets own prices
Time offSalon controls leaveWorker chooses leave

When a worker is likely to be employed

A worker is more likely to be employed if the salon controls their working day.

This may include:

  • setting start and finish times
  • deciding which days they work
  • booking clients for them
  • setting prices
  • providing products
  • assigning tasks
  • monitoring performance
  • paying a fixed hourly rate or salary

Employees have income tax and national insurance deducted through PAYE. Apprentices in salons will normally fall into this employed category.

When a worker is likely to be self-employed

A worker is more likely to be self-employed if they run their work like their own business.

This may include:

  • choosing when and where they work
  • finding their own clients
  • keeping their own client records
  • buying products and equipment
  • setting their own prices
  • taking payments from clients
  • paying rent or commission to the salon
  • working at more than one salon
  • only earning money when they have appointments

Chair renters, mobile stylists, and beauty therapists who visit clients at home can fall into this category, but only where the facts support it.

Mixed work is common

Some people work in more than one way.

For example, a stylist may be employed by a salon during the week and also have private clients outside those hours. In that case, they may have employment income and self-employed income.

This means the tax treatment may be split.

The PAYE income is handled by the employer. The private client income may need to be reported through self-assessment.

Why getting employment status wrong is risky

Wrong status can lead to unpaid tax, National Insurance, interest, and penalties.

The risk is higher where a salon treats someone as self-employed but still controls their work like an employee.

Salon owners should review:

  • contracts
  • rotas
  • pricing control
  • client ownership
  • product supply
  • booking systems
  • payment handling
  • rent or commission agreements

The aim of the HMRC employment status guidance for the hair and beauty industry is to make the paperwork match the business model.

VAT rules for chair rental

Chair rental is one of the most important VAT areas for salons.

Where a salon rents chair space to self-employed stylists, the supply to those stylists is subject to VAT. This rule can apply even if the stylist has a licence to occupy the chair space.

This is because chair rental often includes more than space. It may include access to washbasins, reception areas, waiting areas, and other salon facilities.

A VAT-registered salon must treat this income correctly on its VAT return.

Read: Zero-Rated VAT on Hair Loss Treatments: Mark Glenn Ltd v HMRC Explained

Who accounts for VAT on client takings

VAT treatment depends on who supplies the service to the client.

Business modelVAT treatment
Stylists are employeesThe salon supplies the service and accounts for VAT on gross takings.
Self-employed stylists supply services to the salonThe salon accounts for VAT on gross takings. The stylist may also have VAT duties if registered or required to register.
Stylists supply services direct to their own clientsVAT depends on the stylist’s own takings and VAT position. Payments passed to the salon are payment for the salon’s own supplies, such as chair rent.

This is why the payment flow matters. The answer changes depending on whether the client belongs to the salon or the self-employed worker.

Signs that a stylist supplies clients directly

A self-employed model is stronger when the stylist is genuinely trading on their own account.

Useful indicators include:

  • Stylists keep their own books and records
  • they set their own prices
  • they have their own clients
  • client pays the stylist
  • stylist handles complaints
  • the stylist controls bookings
  • stylist carries business risk
  • salon charges rent or commission
  • the written agreement reflects the real setup

If the salon controls the client relationship, prices, and payments, the tax position may be different.

VAT registration for salons and beauty businesses

A beauty and hair business must register for VAT if taxable turnover goes over £90,000 in the last 12 months.

Registration is also needed if taxable turnover is expected to go over £90,000 in the next 30 days.

For salons and beauty businesses, taxable turnover may include:

  • hair services
  • beauty treatments
  • nail services
  • barbering
  • product sales
  • chair rental income
  • room rental income
  • commission from self-employed workers

A business can also register voluntarily if turnover is below £90,000. Once registered, VAT must be charged on taxable supplies from the date of registration.

Also Read: Do Hairdressers Charge VAT in the UK?

Flat Rate Scheme for Hair and Beauty

Some smaller VAT-registered businesses may use the Flat Rate Scheme.

For hairdressing or other beauty treatment services, the flat rate percentage is 13%. A business may pay 16.5% if it is classed as a limited-cost business. This scheme can be useful, but it is not always the best choice.

Before using it, salon owners should check:

  • expected turnover
  • product costs
  • equipment costs
  • VAT on purchases
  • chair rental income
  • whether the limited cost business rule applies

A quick VAT review can help avoid choosing a scheme that costs more than expected.

Self-Assessment for freelancers

Self-employed stylists, barbers, nail technicians, and beauty therapists may need to file a tax return.

A sole trader must usually send a self-assessment tax return if they earn more than £1,000 before deducting expenses. Untaxed tips and commission can also create a filing requirement.

Self-employed workers should keep records of:

  • client payments
  • chair rent
  • room rent
  • stock and product costs
  • equipment costs
  • travel costs
  • training costs
  • insurance
  • phone and booking software costs
  • business bank transactions

Tax is paid on profit, not sales. Good records help show the real profit figure.

Tips in hair and beauty

Tips need careful handling. Income tax applies to tips. Whether National Insurance applies depends on how the tips are paid and managed.

Tip typeTax treatment
Direct tip kept by the workerThe worker must report it. Income Tax applies. National Insurance is not usually due.
Tip paid through the employerTax is deducted through wages. National Insurance may apply depending on the setup.
Tips paid through a troncTax is handled through the Tronc system. National Insurance depends on employer involvement.
Compulsory service chargeTreated like wages if paid to the worker.

Cash tips should not be ignored. They still form part of taxable income.

Under the Employment (Allocation of Tips) Act 2023, which took effect on 1 October 2024, employers must allocate qualifying tips, gratuities and service charges fairly and transparently between workers and may not make any deductions from them except those required or permitted by law (for example, income tax). Workers can request access to the employer’s written tipping policy and to their own tipping records, and employers must keep those records for three years and respond within four weeks. 

For tax, HMRC’s guidance (Booklet E24) explains that cash tips paid directly by a customer to a worker belong to that worker and are taxable on them, but no PAYE or NICs are due via the employer. 

Tips distributed via a genuinely independent tronc are subject to PAYE by the troncmaster but normally have no NICs, whereas tips received and paid out by the employer are treated as earnings subject to both PAYE and employee and employer NICs. In all cases, tips are taxable income to the worker who ultimately receives them. 

Making Tax Digital for Income Tax

Making Tax Digital for Income Tax now affects some sole traders.

It applies in stages based on qualifying income from self-employment and property:

Qualifying incomeStart date
Over £50,000 in 2024 to 20256 April 2026
Over £30,000 in 2025 to 20266 April 2027
Over £20,000 in 2026 to 20276 April 2028

This can affect freelance stylists, mobile beauty therapists, nail technicians, and barbers who trade as sole traders.

Those in scope need compatible software and digital records.

This is important because many hair and beauty businesses still use notebooks, spreadsheets, or booking apps that are not linked to tax records.

Business rates for salon premises

Physical salons in England may also need to review business rates.

Retail, hospitality, and leisure relief can no longer be newly claimed. From 1 April 2026, business rates are calculated using rate multipliers.

Hair and beauty salons are listed among service businesses that can fall within the retail, hospitality, and leisure multiplier rules, where the property meets the conditions.

This can affect:

  • hair salons
  • nail bars
  • beauty salons
  • tanning shops
  • salons offering non-surgical cosmetic procedures
  • piercing salons

This applies to England only.

Common mistakes to avoid

Hair and beauty businesses should avoid these errors:

  • treating all freelancers as self-employed without checking the facts
  • using chair rental agreements that do not match daily practice
  • missing VAT on chair or room rental
  • counting only profit when checking VAT registration
  • ignoring cash tips
  • mixing personal and business payments
  • failing to keep client payment records
  • waiting too long to prepare for Making Tax Digital
  • assuming a contract is enough on its own

Good tax compliance in this sector starts with clear records and a working model that makes sense.

How We Help Businesses Stay Compliant with HMRC’s New Tax Guidance for Hair and Beauty Services

At Apex Accountants, we support hair and beauty businesses with practical tax and accounting advice.

Our services include:

  • employment status reviews for salons and barbershops
  • chair rental and room rental tax checks
  • VAT registration advice
  • VAT return support
  • Self-assessment for stylists and beauty therapists
  • bookkeeping for salons and freelancers
  • payroll for salon employees
  • Making Tax Digital setup
  • year-end accounts
  • business structure advice

We help salon owners and freelancers build a tax setup that reflects how they actually work.

Conclusion

Hair and beauty tax rules are not just about filing returns on time. The real risk sits in the business model.

Salon owners need to know whether workers are employed or self-employed. They also need to check VAT on chair rental, client takings, tips, self-assessment, and digital reporting.

Freelancers need to know when to register, what records to keep, and how their income should be reported.

Apex Accountants can help hair and beauty businesses review their contracts, VAT position, payment flows, and tax records so the business stays compliant and is easier to manage.

Frequently Asked Questions About Hair and Beauty Tax Rules 

Am I self-employed if I rent a chair?

Renting a chair does not automatically make you self-employed for UK tax purposes. Your status depends on whether you control clients, prices, hours, bookings, and payments and operate independently. HMRC’s CEST tool and hair-and-beauty guidance should be used to confirm status.

Does chair rental include VAT?

If the salon is VAT-registered, chair rental to self-employed stylists is normally standard-rated for VAT, especially when facilities like reception, washing, or bookings are included. Pure land/property rent can be exempt, but most salon “chair rentals” are included as taxable.

Do beauty therapists need to register for VAT?

Beauty therapists must register for UK VAT if their taxable turnover exceeds £90,000 in any rolling 12-month period or if they expect to exceed it. Voluntary registration is allowed below the threshold and may help a month-long period reclaim input VAT on business costs.

Do mobile hairdressers need a tax return?

Self-employed mobile hairdressers must file a self-assessment tax return if their gross trading income exceeds £1,000 in a tax year, after using the £1,000 trading allowance. Below this, no return is needed unless they have other reportable income or gains.

Are tips taxable?

All tips and gratuities are subject to UK Income Tax. How they are reported depends on whether customers pay you directly or via the salon; National Insurance may also be due where the employer allocates or manages the tips under PAYE or a tronc.

Does Making Tax Digital apply to beauticians?

MTD for Income Tax applies to self-employed beauticians with qualifying business or property income over £50,000 from April 2026, with the threshold falling to £30,000 in 2027 and £20,000 in 2028. They must use compatible software and send quarterly updates to HMRC.

Do hairdressers pay tax on tips? 

Yes — tips are taxable income for whoever ends up receiving them, whether they come in cash, by card or through a tronc. Cash tips handed straight to a stylist are declared by the stylist on their Self Assessment or through payroll, while tips distributed through a tronc are taxed through PAYE when the troncmaster allocates them. Since October 2024, employers must also allocate tips fairly and keep tipping records that workers can ask to see. 

What can a hairdresser claim on tax?

Self‑employed hairdressers can deduct the ordinary costs of the trade so long as they are incurred wholly for the business: scissors, clippers, electricals and other tools, products and colours, insurance, chair rent, continuing professional development, laundry of towels and gowns, business use of a mobile phone, and travel between salons or to clients — but not ordinary commuting. If you work from home, you can claim a reasonable proportion of utilities or use HMRC’s simplified working‑from‑home rates; alternatively, if your costs are small, you may use the £1,000 trading allowance instead of itemising actual expenses.

When does Making Tax Digital apply to salon owners?

Making Tax Digital for Income Tax starts on 6 April 2026 for sole traders and landlords with qualifying annual income over £50,000 (based on the 2024/25 tax year), followed by a threshold of over £30,000 from 6 April 2027 (based on 2025/26). Affected salon owners must keep digital records and send quarterly income and expense updates through MTD‑compatible software, alongside an end‑of‑period statement, instead of only filing one annual Self Assessment return. Limited companies and employers are unaffected — MTD for VAT already applies to VAT‑registered businesses.

British Retailers Call for Action on Small-Parcel Import Tax Loophole

British retailers are calling on the government to accelerate plans to close the loophole for small parcel import taxes, which allows overseas sellers to ship low‑value parcels into the UK without paying customs duty. Their appeal comes after the 2025 Autumn Budget confirmed that the longstanding low-value import (LVI) relief will be abolished by March 2029 at the latest. For companies competing with online marketplaces that ship millions of parcels valued at £135 or less, the wait for reform feels too long. Accelerating the closure of the loophole for small parcel import taxes would align the UK with reforms in the United States and European Union, helping restore a level playing field for domestic retailers.

A loophole that has grown too large to ignore

Under current rules, individual consignments valued at £135 or less can enter the UK duty‑free. The relief was originally designed for infrequent and low‑value transactions, but it has become a fundamental part of cross‑border e‑commerce. Parcel operators and customs intermediaries submit simplified declarations using a Bulk Import Reduced Data Set (BIRDS), which allows them to clear multiple consignments at once. This simplification has helped overseas sellers to flood the UK market with very cheap goods. 

HMRC estimates that the number of consignments imported using BIRDS more than tripled between 2021 and 2024, reaching around 600 million parcels a year. During the same period, the value of low-value imports recorded in BIRDS rose from £3.8 billion to £5.9 billion.

Removing customs duty from these parcels made sense when cross-border parcel volumes were low, but the low-value import relief the UK now offers distorts competition. UK‑based retailers import goods in bulk and pay duties at standard tariff rates, while overseas sellers shipping individual parcels valued under £135 effectively avoid customs duty. The government acknowledges that this situation undermines fair competition and has committed to reforms that will require all sellers, regardless of their location, to pay duties on goods sold to UK consumers.

What the government proposes and why it matters

The 2025 Autumn Budget signposted an end to low-value import relief in the UK, describing it as an “unfair customs arrangement” that allows some online retailers to import goods duty-free. HM Treasury and HM Revenue & Customs have since published a detailed consultation outlining UK customs duty changes for parcels and the broader low-value import regime. The document proposes that the new arrangements take effect by March 2029. For UK high street chains, that timetable feels far away, particularly now that the US has removed its $800 de minimis threshold, and the EU plans to eliminate duty relief on consignments under €150 by 2028.

The government’s consultation suggests three key changes:

  • Duty liability shifts to sellers and online marketplaces

Under the proposed LVI customs arrangements, sellers and the operators of online marketplaces will be responsible for paying customs duty on consignments of £135 or less. This mirrors the existing VAT model, where marketplaces must charge and remit UK VAT on low‑value sales. By consolidating liability, duty could be collected through quarterly payments away from the border. That would reduce disruption at ports and ensure duty is visible at the point of sale, improving price transparency.

Potential introduction of an administrative fee

The government is considering a flat fee on low‑value imports to fund the extra customs and border costs associated with processing millions of parcels. This fee would be limited to the cost of services rendered and would be paid by sellers or the platforms facilitating sales. Similar fees have been proposed or introduced in other jurisdictions.

A simplified tariff schedule

To help sellers and marketplaces apply the correct duty without having to assign full commodity codes to every item, officials are exploring a “tariff bucket” system – effectively grouping products into bands with set duty rates. Simplifying classification could make compliance more manageable for overseas sellers unfamiliar with the UK Global Tariff schedule.

The consultation also proposes that overseas sellers without a UK presence appoint a fiscal representative in the UK who would be jointly liable for customs debts. The government intends to maintain the existing relief on gifts valued at £39 or less sent between individuals.

Why retailers want reform sooner

Retailers pressing for change argue that waiting until 2029 will allow overseas platforms to cement an even larger presence in the UK. The consultation notes that low‑value import volumes are already substantial, with an estimated 1.6 million parcels arriving every day. Since the United States abolished duty relief for imports under $800 in 2025 and the EU is moving to scrap its €150 exemption, the UK has become an outlier. Industry groups worry that global sellers will increasingly divert their parcels to UK consumers to exploit the remaining duty relief, further eroding domestic market share. They also highlight product safety concerns; when goods circumvent import duties, they often bypass quality checks.

From a revenue perspective, the low‑value import relief is becoming expensive. Once goods are subject to duty, receipts could help fund public services. Introducing an administrative fee of around £2.60 per parcel, as suggested by some retailers, could raise over £1 billion annually. However, designing and implementing new systems will take time, and businesses need certainty. HM Treasury has therefore signalled that reforms must balance fairness with the practicalities of collecting duty and data at scale.

Practical steps for businesses

Although the new regime and UK customs duty changes for parcels may be several years away, businesses should not wait to prepare. Overseas sellers and marketplace operators should review their supply chains, ensure that systems can capture and report product data, and prepare for quarterly customs duty payments. 

Those not established in the UK may need to appoint a fiscal representative and budget for administrative fees. UK retailers should assess how the changes could affect pricing and inventory strategies; some imports currently shipped under the £135 threshold may become subject to duty and higher costs. 

All stakeholders can respond to the government consultation, which runs until March 2026, and help shape the final design of the new customs arrangements.

The abolition of LVI relief also interacts with VAT. Since January 2021, the UK has abolished the VAT exemption for goods under £15 and requires sellers dispatching goods valued at £135 or less to register for UK VAT and charge it at the point of sale. Businesses must continue to account for VAT correctly while preparing for future customs duties.

How Apex Accountants & Tax Advisors can help

Navigating cross‑border trade rules is complex. Apex Accountants & Tax Advisors works with retailers, online marketplace operators and logistics firms to interpret the evolving customs and VAT landscape. Our team can help you:

  • Analyse how the removal of the LVI relief and the potential small parcel import tax loophole closure will affect your cost base and pricing.
  • Register for UK VAT and design systems to collect customs duty and VAT on low‑value consignments.
  • Prepare for quarterly duty payments and develop processes for appointing fiscal representatives if you do not have a UK establishment.
  • Model the financial impact of possible administrative fees and simplified tariff schedules.

We collaborate closely with clients to ensure compliance with HMRC guidance, integrate duty calculations into accounting systems and plan for changes well ahead of the March 2029 target. Contact Apex Accountants today to discuss tailored strategies for your supply chain and e‑commerce operations.

Frequently asked questions

What is the low-value import relief, and why is it being removed? 

The LVI relief allows consignments of goods valued at £135 or less to enter the UK without paying customs duty. The government plans to abolish it by March 2029 because the relief has been exploited by overseas sellers, distorting competition and undermining tax fairness.

When will the new customs arrangements come into force?

HM Treasury intends the new LVI customs arrangements to take effect by March 2029, but British retailers are urging the government to implement changes sooner.

Who will pay customs duty under the new regime? 

The consultation proposes making sellers and online marketplace operators responsible for paying duty on low‑value consignments, aligning with existing VAT rules.

Will there be any exemptions? 

The government plans to retain the relief for non‑commercial gifts valued at £39 or less sent between private individuals. All other consignments will be subject to customs duty and potentially an administrative fee.

What is the proposed administrative fee and why? 

Officials are considering a flat fee on low‑value imports to cover the cost of processing millions of parcels. Retailers have suggested a fee of about £2.60 per parcel, but the government is still gathering views through its consultation.

How should businesses prepare? 

Companies should ensure they are compliant with VAT rules, plan for quarterly customs duty payments and monitor the consultation. Overseas sellers without a UK presence may need to appoint a fiscal representative. Engaging with advisers, such as Apex Accountants, can help businesses adapt their systems and minimise disruption.

HMRC v M R Currell Ltd [2026] – Genuine Loan via EBT Not Taxable as Salary

In HMRC v M R Currell Ltd [2026] EWCA Civ 445, the Court of Appeal held that an £800,000 payment routed through an Employee Benefit Trust (EBT) was a genuine loan, not taxable employment income, because it carried a real obligation to repay. In April 2026, the court confirmed that Mr Currell received a loan, not extra pay, so he did not gain taxable earnings from the transaction. This clarifies that simply using a trust to channel funds does not automatically turn money into a salary – the substance of the transaction matters.

Disguised remuneration (DR) rules have long targeted schemes that shift pay into loans or benefits via third parties. In 2011 the government enacted Part 7A of ITEPA 2003 to catch such schemes involving intermediaries. Later, the controversial Loan Charge (2019) aimed to tax old loan arrangements. However, under general law, a payment is only taxed as earnings if it arises “from the employment”. As HMRC’s own manuals note, a profit or payment “arose from something else” than employment if it did not truly come as a reward for services. In Currell’s case, the money was a loan – a debt Mr Currell had to pay back – not an additional salary.

Background: Disguised Remuneration & EBT Loans

Disguised Remuneration Rules (Part 7A ITEPA 2003): 

Introduced in 2011 to target third-party schemes avoiding income tax. They tax “relevant steps” (like making a loan through a trust) as if they were paid.

Loan Charge (2019): 

Further rules will tax old disguised remuneration loans. Importantly, changes after a 2025 review limit the charge to loans made on/after 9 Dec 2010.

General Tax Law: 

Under s.62 ITEPA (formerly s.19 ICTA), only payments “from the employment” are earnings. Courts ask, ‘Did the benefit come in return for work or from some other source?’

Example: HMRC’s own guidance says that a gift (e.g., a wedding present) from an employer is not taxed because it’s not “from the employment” but from a personal occasion. By analogy, a genuine loan made to an employee – especially through a trust – may not be “from” the job and thus not automatically considered earnings.

Facts of the Currell Case

DateEvent
Nov 2010Company Contribution: M R Currell Ltd (a small painting business) pays £800,000 into a newly created EBT.
Nov 2010 (same day)Loan to Director: The EBT trustees immediately lend £800,000 to Mr M. Currell (a director) at 0% interest for 5 years, secured on the company shares he buys.
2010 (shortly after)Share Purchase: Mr Currell uses the loan to buy shares (A shares) from his wife. Mrs Currell then loans the money back to the Company.
2011 onwardsTax Challenge: HMRC investigates and assesses the £800k as if it were Mr Currell’s earnings, seeking income tax and NICs.

The key points of the arrangement were that the loan was fully documented, secured by Mr Currell’s shareholding, and he clearly intended (and was able) to repay it. The First-tier Tribunal (FTT) initially treated the payment to the trust as taxable pay, essentially calling it a reward for Mr Currell’s services. On appeal, the Upper Tribunal (UT) found the opposite: the contribution to the EBT was made solely to enable the loan, and since the loan had a real repayment obligation, the payment was not considered earnings.

FTT (201X): 

Viewed the £800k contribution (the “Payment”) as remuneration for Mr Currell’s work, relying on previous cases like RFC 2012 Plc v Advocate General for Scotland (“Rangers”) that held payments to a trust could be earnings when they were agreed upon as part of salary.

UT (2024): 

Ruled that the FTT made an error. It held that the loan itself was genuine and repayable, so the contribution was not Mr Currell’s pay. The UT “remade” the decision in HMRC’s favour (legally speaking) and concluded that the £800k was not taxable as earnings because of the loan’s bona fide nature.

Court of Appeal Decision

The Court of Appeal (CA) upheld the Upper Tribunal. It firmly agreed that the loan was genuine and properly characterised. Key principles from the judgement include the following:

Characterisation Over Purpose: 

The court stressed that the character of a payment must be determined before applying tax law. Money spent on employee benefits does not automatically become “earnings” simply because of the purpose. In Currell’s case, the money went into the trust and then became a loan. The CA emphasised that one must look at what the transaction actually was, not just at why it happened.

Genuine Loan ≠ Earnings: 

A loan with a real promise to repay is not earnings. The court noted that an employee receiving a genuine loan with repayment terms is not getting a benefit worth money in the sense of pay. Instead, any fiscal “benefit” (like zero interest) is taxed under the special loan/beneficial loan charge rules, not as salary. As the CA aptly put it, “In truth, what Mr Currell got was the loan. This was not a case of diverting remuneration to the EBT.”

Read: Everything You Need to Know About Director’s Loan Write-Off and the Douglas Boulton Case

Distinguishing Rangers: 

In Rangers (the 2017 Supreme Court case), it was already common ground that the monies were remuneration; the only question was whether a trust could receive them. Here, by contrast, the very nature of the payment was in dispute. The CA highlighted a “fundamental distinction”: unlike Rangers, in Currell it was not agreed the money was due as salary in the first place. Because the loan was secured and had to be repaid, the Court found it was incorrect to equate it with Mr Currell’s pay.

Limited Circumstances for Taxing Loans: 

The Court noted that only in limited cases – for example, a sham loan or arrangement – could a loan be treated as earnings. On Currell’s facts, there was no sham. The suggestion that a borrower’s control over a lender (e.g., via share ownership) could turn the loan into pay was dismissed; no legal authority supported that idea.

Caution Against Overreach: 

In its concluding remarks, the CA warned that HMRC’s broad approach could have unintended consequences. It gave examples: if every loan through a third party were taxed as pay, ordinary loans (like directors withdrawing loan account balances or loan season-ticket schemes via payroll) might wrongly be caught. This “close inspection of the trees” could miss the bigger picture. The court thus signalled that normal commercial loans should not be swept up as disguised salaries.

In summary, the Court of Appeal agreed that the Upper Tribunal’s conclusion “was the only one that could have been reached” and expressly adopted its view that the £800k was not part of Mr Currell’s earnings.

Practical Implications for Businesses and Advisers

The Currell ruling offers important guidance for businesses, directors and accountants dealing with trust-based benefits.

Genuine loans must be clear: 

Any loan from a company (even via a trust) should be well-documented, with a realistic repayment schedule and security. The court noted Mr Currell’s loan was properly secured on his shares and he had independent means to repay them. Companies should “confirm loans from EBTs/trusts are properly documented, secured, and carry a realistic repayment obligation”.

Characterise the transaction: 

Focus on the substance over the formal route. If an employee receives money that they must repay, it is more logically a loan than extra salary. As HMRC’s rules (and this case) emphasise, one must decide if the benefit came “from the employment”. In practice, explain in writing that the payment is a loan for a commercial purpose (e.g., a share purchase), not a payment for work.

Trustees’ independence: 

Ensure that trustees genuinely make trust decisions, rather than merely rubber-stamping them as the company or director would. The CA pointed to the importance of true trustee control. If trustees simply do what the employer directs, HMRC may argue the trust is a sham conduit.

Use Currell in disputes: 

If HMRC challenges a loan from EBT as disguised remuneration, this case is strong authority (for pre-2011 schemes) to insist the loan is taxed as such, not as salary. Advisers should request that HMRC confirm the character of the payment (loan vs remuneration) and cite Currell’s reasoning on s.62 analysis.

Beware modern DR rules: 

Currell was a pre-2011 loan (Part 7A came into force in Oct 2011) and a pre-loan charge. After 2011, the law expanded to treat many third-party loans as income immediately. The Court acknowledged that Parliament later closed this gap. So do not assume that post-2011 or Loan Charge-era loans can avoid tax; new anti-avoidance rules will often apply. In short, Currell vindicates older arrangements, but “for post-2011 structures, Currell does not provide a free pass.”

Review legacy schemes: 

This decision is an opportunity to re-check any old EBT or loan arrangements. Where a loan was truly made and intended to be repaid (even if it was tax-advantaged), Currell suggests it was not income at the time. Conversely, any sham or purely circular schemes should be unwound or settled.

Seek expert advice: 

The line between a legitimate loan and a disguised salary can be fine. Specialist tax advice (or even HMRC clearance) is prudent for complex arrangements. The Currell judgement itself recommends getting professional opinions and structuring “defensively” under Part 7A rules.

How We Help

As chartered accountants and tax specialists, Apex Accountants can help you navigate EBT schemes and employee tax:

  • Tax planning & compliance: We advise on structuring loans, share purchases or benefits so they meet legal requirements and minimise tax risk.
  • Disguised remuneration & EBT advice: Our team stays up to date on cases like Currell. We can review any trust-based arrangements and ensure they pass the correct legal tests.
  • HMRC dispute support: If you face an enquiry or need to appeal an HMRC decision, we can help develop your case (for example, using Currell to argue your loan was not taxable earnings).
  • Loan Charge guidance: We assist clients with historic loan schemes to check if and how the Loan Charge or new rules apply.
  • Tailored accounting services: From company accounts to payroll taxes and beyond, we provide practical support to UK businesses of all sizes.

With our expertise, you’ll get clear, practical advice grounded in the latest laws and court decisions. We aim to protect your interests and help you stay compliant without paying more tax than necessary.

Conclusion

The HMRC v M R Currell Ltd [2026] case is a reminder to look at the true nature of payments. A bona fide loan – even one routed through an EBT – should be treated as a loan for tax purposes, not as hidden earnings. This means thorough documentation and honest substance are vital. While later legislation (Part 7A, Loan Charge) has tightened the rules, Currell restores balance for older arrangements. It shows that legitimate trust arrangements with real loans won’t automatically trigger income tax just because a trust is involved. For specific situations, always seek tailored advice.

Contact Apex Accountants for expert support on employment taxes, EBT schemes and any HMRC issues. We’ll help you understand how cases like HMRC v Currell Ltd may affect your affairs and ensure you comply with tax law.

FAQs About HMRC v M R Currell Ltd [2026]

What was the main point of the Currell judgement?

The Court of Appeal confirmed that when a company’s contribution to a trust is used to fund a loan to an employee, this loan – if genuine and repayable – is not automatically taxable as earnings. In Currell’s case, the £800k he received was treated as a loan (with a real obligation to repay), not as salary.

How is this different from the Rangers’ case?

Rangers (2017) held that if an employee contracts to have part of their salary paid to a trust, it is taxable when it enters the trust. In Currell, by contrast, the court found that the parties disputed whether any salary was ever deferred; here, the arrangement was purely a loan. The Court emphasized that, unlike Rangers, it did not agree that Mr Currell had earned this money as pay.

Does this mean EBT loans are tax-free?

Not always. Currell specifically involved a loan made in 2010, before new anti-avoidance rules (Part 7A ITEPA, Loan Charge) took effect. The Court’s logic focused on that time. Today, many loans via trusts fall under strict DR legislation. However, Currell shows that if a loan was genuinely commercial and was entered into before 2011, it may not have been considered “earnings,” even if it was routed through a trust.

What should employers do now?

Companies should ensure any employee loans (direct or through trusts) are bona fide: documented, secured, and repaid. If using an EBT or similar vehicle, trustees must act independently. In case of HMRC enquiries, use the Currell case to argue that the loan should be taxed under the loan rules, not as salary, by highlighting the legal distinction. Always keep clear records of the purpose (e.g., a share purchase) to show the commercial rationale.

Will this case affect employees and tax appeals?

Yes. Individuals or employers who took loans from trusts (especially before 2011) can reference this ruling. It may overturn earlier assumptions that “trust = tax avoidance”. For appeals, lawyers and accountants will likely cite Currell when challenging HMRC assessments on genuine loans.

VAT Evasion Penalties in the UK: Cunningsburgh Man Who Evaded £166,000 in Tax Ordered to Pay Just £1

A recent case in Shetland has put the spotlight on VAT fraud and confiscation orders in the UK. A businessman from Cunningsburgh, who fraudulently claimed £166,000 in VAT refunds, was sentenced to 18 months in prison, highlighting the severe VAT evasion penalties in the UK, and ordered to pay only £1 under the Proceeds of Crime Act. The man, a company director in his forties, exploited the VAT system by inflating invoices, claiming input tax on personal purchases, and submitting falsified bank statements to HM Revenue & Customs (HMRC). Despite the significant financial wrongdoing, the court was only able to enforce a token confiscation order due to the man’s lack of assets to seize.

This case highlights the risks of VAT fraud and raises concerns for UK businesses about the consequences of such offences. With the tax authorities pursuing strict punishments for fraudsters, this case serves as a reminder to businesses about the importance of VAT compliance and the consequences of evading tax responsibilities.

How the fraud was carried out

Evidence presented in court suggested that the Cunningsburgh director used a mix of fraudulent techniques:

  • Falsified paperwork – he created or edited invoices and bank statements to inflate the value of purchases or to show that personal expenses were legitimate business costs. Under the VAT system, businesses can reclaim the tax paid on goods and services used in their trade; by doctoring documents, he increased his input tax claims.
  • Misuse of personal purchases – personal items such as vehicles and household goods were bought at the normal VAT-inclusive price and then claimed as business expenses. HMRC considers such behaviour fraudulent VAT evasion because the input tax is not attributable to taxable supplies.
  • Sustained deception – local reports indicate that the fraud continued for almost two years before HMRC identified irregularities. The sentencing judge at Lerwick Sheriff’s Court described the behaviour as “devious” and “calculated.”

The fraudulent scheme was uncovered after VAT compliance services for businesses flagged inconsistencies between VAT returns and underlying records. This case further highlights the importance of UK VAT fraud risk management to help businesses avoid such risks and ensure proper VAT compliance. During the sentencing hearing, the judge mentioned the need for a deterrent sentence and stressed that VAT fraud harms the public purse. The 18‑month custodial term is consistent with the Sentencing Council’s guidelines, which state that fraudulent evasion of VAT under section 72 of the Value Added Tax Act 1994 can result in custodial sentences of up to 14 years and that offence ranges span from a band C fine to 13 years’ custody.

Fraudulent evasion of VAT is a criminal offence under section 72 of the Value Added Tax Act 1994. The legislation provides for serious penalties. Where a person is knowingly involved in the fraudulent evasion of VAT, they are liable:

  • On summary conviction – to a penalty up to the statutory maximum of £20,000, or three times the amount of VAT evaded, whichever is greater, and up to six months’ imprisonment.
  • On conviction on indictment – to an unlimited fine or imprisonment for up to 14 years, or both. The Sentencing Council notes that the maximum sentence for offences committed on or after February 22, 2024, is increased from seven to fourteen years.

HMRC also has civil penalties for participating in transactions connected with VAT fraud. Company officers may be jointly liable if their actions facilitated the fraud. HMRC’s compliance‑checks factsheet states that when HMRC denies input tax under the ‘knowledge principle’ (where a trader knew or should have known the transaction was fraudulent), the penalty is fixed at 30% of the VAT denied, emphasising the importance of UK VAT fraud risk management.

Confiscation orders and the £1 payment

After criminal convictions, courts can make confiscation orders under the Proceeds of Crime Act 2002. These orders require offenders to repay the benefit from their crime. Where no recoverable assets are available, the court may impose a nominal order, often £1. The token order does not wipe out the debt – if assets are discovered later, the full sum can be recovered, and failure to pay can lead to further imprisonment. The Cunningsburgh case thus illustrates a paradox: although the offender stole more than £166,000, he currently has no assets, so he is only ordered to repay a pound. The debt remains enforceable for life and will be revisited if he acquires assets in future.

Implications for UK businesses

This case underscores several broader themes for businesses:

  1. VAT is a trust-based tax – HMRC relies on businesses to submit accurate returns, and VAT compliance services for businesses can help ensure compliance and avoid costly mistakes. Fraudulent claims directly deprive the Treasury of revenue, and HMRC invests significant resources in compliance checks and data analytics. Finding irregularities can lead to civil penalties, public naming, and criminal prosecution.
  2. Directors can be personally liable – under HMRC’s guidance, company officers may be liable for penalties when they knew or should have known that transactions were connected with VAT fraud. Directors should ensure robust controls over invoicing, record‑keeping and VAT calculations.
  3. Fines and prison terms are severe – VAT fraud is not a minor offence. The Value Added Tax Act allows fines up to three times the tax evaded and imprisonment for up to 14 years. Sentences vary according to culpability and harm, but courts take sustained deception seriously, as shown by the 18‑month term in this case.
  4. Confiscation orders persist – nominal orders do not absolve the offender. Businesses and individuals tempted to hide assets should note that the Proceeds of Crime Act enables recovery years after conviction.

Practical steps to prevent VAT fraud

Businesses can mitigate risk and avoid unintentional involvement in VAT fraud by adopting good practices:

  • Strengthen internal controls: implement checks on invoicing and purchasing processes to improve HMRC VAT audit support and help prevent VAT fraud for companies. ensure that all expenses claimed for VAT recovery are wholly and exclusively for business purposes.
  • Keep accurate records: maintain digital and physical records that support VAT claims. HMRC’s Making Tax Digital rules mandate the electronic storage of VAT records.
  • Conduct due diligence on suppliers: if you buy from missing traders or carousel fraudsters, HMRC can deny your input tax claim and charge a 30 % penalty. Verify that suppliers are genuine and VAT‑registered.
  • Seek professional advice early: consult tax advisers before embarking on complex transactions; disclosure of errors to HMRC can reduce penalties.
  • Train staff: ensure finance and procurement teams understand the VAT rules and the difference between business and personal expenditure.

How Apex Accountants & Tax Advisors can help

Apex Accountants & Tax Advisors offers specialist support to prevent VAT abuses like those seen in the case of the Cunningsburgh man who evaded £166,000 in VAT. Our chartered tax advisers assist clients with:

  • Compliance reviews – assessing whether your VAT returns and systems meet HMRC standards.
  • VAT planning: structuring transactions to maximise legitimate relief while avoiding the pitfalls of fraudulent schemes.
  • Representation in HMRC investigations – if HMRC opens a compliance check, we provide expert advocacy and negotiate on your behalf.
  • Training and governance – designing internal controls and staff training to minimise the risk of errors or fraud and enhance HMRC VAT audit support for businesses.

With the tax authority increasingly using sophisticated analytics and the courts imposing severe penalties, expert advice has never been more important. Contact Apex Accountants today to arrange a confidential consultation and ensure your business stays on the right side of the law.

Frequently asked questions

What constitutes VAT fraud?

VAT fraud involves deliberately misstating or concealing information to reduce VAT liabilities. Examples include failing to register for VAT when required, submitting false invoices, claiming input tax on personal expenses, and participating in missing trader carousel schemes. Section 72 of the Value Added Tax Act 1994 criminalises fraudulent VAT evasion.

What penalties can HMRC impose without a criminal prosecution? 

HMRC can deny input tax and levy civil penalties. Under the knowledge principle, the penalty is 30 % of the VAT denied. HMRC may also publish the names of businesses and directors involved in serious VAT fraud.

When must a business register for VAT?

 A UK business must register if its taxable turnover exceeds the registration threshold (currently £90,000 per annum). Deliberate failure to register when required is treated as tax evasion and can lead to penalties or criminal charges.

Can directors be personally liable for VAT fraud committed by their company? 

Yes. HMRC guidance states that company officers who knew or should have known about fraudulent transactions can be liable for all or part of the penalty. Criminal prosecution is also possible under section 72 of the VAT Act.

What happens if someone cannot pay a confiscation order? 

The court may impose a nominal order, often £1, if there are no recoverable assets. However, the full amount remains due, and authorities can recover assets later. Failure to pay confiscation orders can result in additional prison sentences.

How Company Car Tax Bands Work and What You Will Pay in 2026/27

In the UK, company cars available for private use normally create a benefit-in-kind tax charge. The value is based largely on the vehicle’s list price, while the applicable percentage is determined through company car tax bands based on CO₂ emissions, fuel type and, for some plug-in hybrids, electric-only range.

In practice, HMRC publishes percentage bands for each tax year. You multiply the car’s taxable list price by the relevant percentage to calculate the taxable benefit. Low-emission vehicles attract much lower percentages, while higher-emission cars can reach 37% in 2026/27.

The amount can also be affected by qualifying employee capital contributions, payments specifically required for private use, or periods of at least 30 consecutive days when the car is unavailable. HMRC provides official guidance on calculating company car benefits.

How Company Car Tax Bands Are Calculated

Benefit Calculation

Company car BIK is generally calculated using the car’s original list price, including VAT and taxable accessories, multiplied by the appropriate HMRC percentage.

For example, a petrol car emitting 145 g/km falls into a 35% band in 2026/27, while a fully electric car attracts a much lower 4% rate.

Emission Bands

Cars are grouped by CO₂ emissions measured in grams per kilometre. For cars emitting between 1g/km and 50g/km, electric-only range can also affect the percentage.

The following table summarises the 2026/27 company car tax rates alongside 2025/26:

CO₂ emissions (g/km) & electric range2025/26 rate (%)2026/27 rate (%)
Zero emission (fully electric)3%4%
1–50 (130+ mile electric range)3%4%
1–50 (70–129 mile range)6%7%
1–50 (40–69 mile range)9%10%
1–50 (30–39 mile range)13%14%
1–50 (under 30 mile range)15%16%
51–5416%17%
55–5917%18%
60–6418%19%
65–6919%20%
70–7420%21%
75 and above21%–37%21%–37%

Company car BIK rates for 2025/26 and 2026/27 by CO₂ emissions and electric range.

How to Calculate Company Car Tax

To work out the tax on company cars, you generally:

  1. Find the car’s taxable list price, including relevant accessories.
  2. Apply the appropriate BIK percentage.
  3. Multiply the resulting taxable benefit by the employee’s marginal Income Tax rate.

Example: A £30,000 fully electric company car has a 4% BIK rate in 2026/27.

£30,000 × 4% = £1,200 taxable benefit

A 20% taxpayer would therefore pay approximately £240 a year, while a 40% taxpayer would pay approximately £480 a year, assuming the car is available for the full tax year and no other adjustments apply.

You can also use HMRC’s company car and car fuel benefit calculator to calculate the taxable value for a specific vehicle.

Why Electric Cars Have the Lowest Tax Rates

Fully electric cars sit at the lowest end of the company car tax scale.

For 2025/26, the appropriate percentage is 3%. This rises to 4% for 2026/27.

Plug-in hybrids emitting between 1 g/km and 50 g/km with an electric range of at least 130 miles currently receive the same 4% rate in 2026/27.

This continues to make low-emission vehicles significantly more tax-efficient than many petrol and diesel company cars.

If your business is deciding whether to lease or purchase a vehicle, the VAT treatment can also affect the total cost. Our guide to VAT recovery on business cars explains the different rules for leased and purchased vehicles.

How Plug-in Hybrids and Mid-Range Cars Are Changing

Plug-in hybrids are also seeing increases in their appropriate percentages.

For 2026/27:

  • 1–50 g/km with a 70–129 mile electric range is taxed at 7%.
  • 1–50 g/km with a 40–69 mile range is taxed at 10%.
  • 1–50 g/km with less than 30 miles of electric range is taxed at 16%.
  • Cars emitting 65–69 g/km move from 19% in 2025/26 to 20% in 2026/27.

A plug-in hybrid with an electric-only range of around 100 miles therefore falls into the 7% band for 2026/27.

When These Changes Came Into Effect

The current rates apply from:

  • 6 April 2025 for the 2025/26 tax year
  • 6 April 2026 for the 2026/27 tax year

The changes form part of a gradual increase in company car appropriate percentages.

What to Expect in the Coming Years

Tax rates for zero-emission company cars will continue to rise gradually.

The currently legislated rates are:

  • 5% in 2027/28
  • 7% in 2028/29
  • 9% in 2029/30

The increases remain designed to preserve a significant tax advantage for zero-emission cars compared with conventional petrol and diesel vehicles.

HMRC has published the future company car tax rates for 2028 to 2030.

The Highest Tax Rates for Petrol and Diesel Cars

Petrol and diesel vehicles continue to sit at the upper end of the scale.

For 2026/27:

  • The maximum appropriate percentage is 37%.
  • The 37% maximum is reached at 155 g/km and above for standard petrol-powered cars.

In simple terms, higher emissions generally mean a higher taxable company car benefit.

Special Cases

The standard calculation can be adjusted in certain circumstances:

  • Capital contributions: qualifying employee contributions towards the cost of the car or accessories can reduce the price used in the benefit calculation, up to a maximum deduction of £5,000.
  • Periods of unavailability: the benefit can be reduced where the car is unavailable to the employee for at least 30 consecutive days.
  • Payments for private use: qualifying payments that the employee is required to make specifically for private use can reduce the taxable benefit.
  • Private fuel: employer-funded fuel for private journeys normally creates a separate fuel benefit charge. For 2026/27, the company car fuel benefit multiplier is £29,200.

Electricity is not treated as fuel for the company car fuel benefit charge.

Advisory Fuel Rates From September 2026

HMRC updates advisory fuel rates quarterly. The latest rates took effect on 1 September 2026 and apply when employers reimburse employees for business travel in company cars or when employees repay the cost of private fuel.

The current HMRC advisory fuel rates are:

Vehicle / engine sizeRate per mile
Petrol – 1400cc or less14p
Petrol – 1401cc to 2000cc17p
Petrol – over 2000 cc27p
Diesel – 1600cc or less15p
Diesel – 1601cc to 2000cc16p
Diesel – over 2000 cc22p
Electric – home charging7p
Electric – public charging15p

Hybrid cars are treated as petrol or diesel cars for advisory fuel-rate purposes. HMRC also allows employers to continue using the previous rates for up to one month after new rates take effect.

Key Points on Low-Emission Vehicles

  • Electric cars: Zero-emission cars have a 4% appropriate percentage in 2026/27, compared with 3% in 2025/26.
  • Plug-in hybrids: Cars emitting 1–50 g/km are taxed according to both CO₂ emissions and electric-only range.
  • Future changes: The zero-emission rate rises to 5% in 2027/28, 7% in 2028/29 and 9% in 2029/30.
  • List price matters: The benefit is calculated from the car’s tax value rather than its current second-hand value.

The relatively low 2026/27 company car tax rates for electric vehicles mean they continue to offer a considerable BIK advantage over many higher-emission alternatives.

How We Help Businesses Manage Tax on Company Cars

At Apex Accountants, we help businesses and employees navigate company car taxation and other taxable benefits. Our services include:

  • Tax planning for company cars: Advice on vehicle choices, salary sacrifice arrangements and calculating company car BIK.
  • Payroll and benefits administration: Managing P11D reporting, payroll adjustments and car-benefit reporting through our payroll services.
  • Company tax and VAT advice: Ensuring leasing, maintenance and other vehicle costs receive the correct tax and VAT treatment.
  • Employee tax support: Helping individuals understand the personal tax on company cars and how benefits affect their tax position.

Whether you are an employer arranging a fleet or an employee reviewing a company car package, our team can help you calculate the costs and apply the correct HMRC treatment.

Frequently Asked Questions About Tax on Company Cars

How is company car tax calculated in 2026/27?

Company car tax is generally calculated by multiplying the car’s taxable list price by the appropriate HMRC percentage based on its CO₂ emissions, fuel type and, where relevant, electric range. The resulting benefit is then taxed at the employee’s marginal Income Tax rate.

When do company car tax rates change?

Company car BIK percentages normally apply for each tax year beginning on 6 April. The current rates took effect on 6 April 2026. Advisory fuel rates are separate and are reviewed quarterly by HMRC.

How do I know which CO₂ figure to use for my car?

Use the vehicle’s officially approved CO₂ emissions figure. HMRC’s company car guidance and calculator use the relevant WLTP or applicable approved emissions information for the vehicle.

How much tax do you pay on an electric company car?

A fully electric company car has a 4% BIK rate in 2026/27. A £40,000 electric car therefore creates a £1,600 taxable benefit. That equates to approximately £320 a year for a 20% taxpayer or £640 for a 40% taxpayer, assuming full-year availability and no other adjustments.

What about tax on fuel costs?

If an employer provides fuel for private journeys, a separate fuel benefit may arise. The car fuel benefit multiplier is £29,200 for 2026/27. Electricity is not treated as fuel for this particular benefit charge.

What are the advisory fuel rates for electric cars from September 2026?

From 1 September 2026, HMRC’s advisory electricity rates for fully electric company cars are 7p per mile for home charging and 15p per mile for public charging.

Can I reduce my company car tax?

Potentially. Choosing a lower-emission or lower-list-price vehicle can reduce the taxable benefit. Qualifying employee capital contributions of up to £5,000 and payments specifically required for private use can also reduce the benefit in certain circumstances.

Simply paying for insurance does not automatically reduce the company car benefit, and an older car does not necessarily create a lower benefit because the calculation normally starts with its original list price.

Where can I find official information about company car tax?

HMRC publishes company car appropriate percentages, advisory fuel rates and its company car calculator on GOV.UK.

What Businesses Need to Know About Tax Changes in UK 

In the United Kingdom, “new financial year” can mean two things. The government’s financial year typically runs from 1 April, while the personal tax year runs from 6 April to 5 April. For 2026/27, the tax year started on 6 April 2026.  This matters because a lot of the practical tax changes in UK (PAYE, National Insurance, dividend tax rates, capital gains tax relief rates, and the rollout of Making Tax Digital for Income Tax) start from 6 April. 

Key dates at the start of the year

DateWhat it means in practice
1 April 2026Start of the Corporation Tax “year” (financial year) for rates that apply to companies’ profits (depending on accounting period start dates). 
6 April 2026Start of the 2026/27 tax year (Income Tax and National Insurance settings apply from this date, and several targeted changes take effect). 
5 April 2026Cut-off to register for voluntary payrolling of benefits in kind for the 2026/27 tax year (if you want to payroll benefits instead of using P11Ds). 

Personal tax changes for 2026/27

Most headline Income Tax rates are unchanged, but allowances and thresholds still drive what you actually pay. 

Income Tax bands and thresholds

For most people in England, Wales and Northern Ireland, the standard Personal Allowance remains £12,570, and the basic/higher/additional rate structure is unchanged. 

Read: How to Increase Your Tax-Free Personal Allowance to £20,070 Through HMRC Rent-a-Room Scheme

If your adjusted net income is over £100,000, your personal allowance is tapered away at £1 for every £2 over £100,000, reaching zero at £125,140. 

AreaBand (2026/27)Taxable incomeRate
England, Wales, Northern IrelandPersonal AllowanceUp to £12,5700%
Basic rate£12,571 to £50,27020%
Higher rate£50,271 to £125,14040%
Additional rateOver £125,14045%

These bands are set out in government guidance for the 2026/27 tax year. 

Tax changes for Scottish taxpayers

If you live in Scotland, you pay Scottish income tax rates on wages, pensions and most other non-savings, non-dividend taxable income. Dividends and savings interest remain taxed at UK-wide rates. 

AreaBand (2026/27)Taxable incomeRate
ScotlandPersonal AllowanceUp to £12,5700%
Starter rate£12,571 to £16,53719%
Basic rate£16,538 to £29,52620%
Intermediate rate£29,527 to £43,66221%
Higher rate£43,663 to £75,00042%
Advanced rate£75,001 to £125,14045%
Top rateOver £125,14048%

The tax changes for Scotland taxpayers in the 2026/27 financial year include updated income tax bands and rates, reflecting changes that affect both higher and lower earners across Scotland.

Dividend tax rises from 6 April 2026

A clear “start of tax year” change for investors and owner-managed businesses is dividend taxation. From 6 April 2026:

  • the dividend ordinary rate rises to 10.75%
  • the dividend upper rate rises to 35.75%
  • the dividend additional rate stays at 39.35% 

The dividend allowance remains £500 for 2026/27 (so you only pay dividend tax on dividends above this allowance, after considering how the allowance interacts with your wider Income Tax position). 

For close companies, it is also worth noting that the “loans to participators” charge is linked to the dividend upper rate and therefore moves in line with that increase. 

Capital Gains Tax and relief rates

The Capital Gains Tax Annual Exempt Amount for individuals remains £3,000 for 2026/27 (with a lower allowance of £1,500 for most trustees). 

For many disposals in 2026/27, government guidance shows CGT rates at 18% and 24% for individuals (depending on whether you are a basic rate or higher/additional rate Income Tax payer), with trustees and personal representatives generally at 24% (subject to the detailed rules). 

Business Asset Disposal Relief goes to 18%

If you are selling a business (or qualifying shares), the rate under Business Asset Disposal Relief increases again.

Business Asset Disposal Relief means you pay:

  • 18% on qualifying gains for disposals on or after 6 April 2026
  • 14% for disposals between 6 April 2025 and 5 April 2026 (and 10% for earlier disposals) 

This change is also reflected in wider official CGT policy material. 

Investors’ Relief similarly moves to 18% for disposals on or after 6 April 2026. 

Inheritance Tax changes affecting farms and family businesses from 6 April 2026

Another major change that takes effect from 6 April 2026 is a reform to 100% Agricultural Property Relief and 100% Business Property Relief.

Official guidance confirms that, for deaths on or after 6 April 2026, the combined value of qualifying agricultural or business property that can receive 100% relief is capped at £2.5 million. 

Where qualifying value exceeds £2.5 million, relief at the lower rate (50%) applies to the excess. 

The allowance can also be transferable between spouses and civil partners if a claim is made, and rules also apply for trusts. 

Business and employer changes for 2026/27

For employers, the start of the tax year is primarily a payroll event. Rates, thresholds, and employer reliefs need to be correct from the first pay run after 6 April. 

National Insurance rates and thresholds

For 2026/27, published National Insurance contribution rates show:

  • employees in the main category (A) pay 8% on earnings above the Primary Threshold up to the Upper Earnings Limit, and 2% above that 
  • employers pay 15% on earnings above the Secondary Threshold (with modified treatment for specific categories such as under-21s and apprentices) 
  • Class 1A and Class 1B National Insurance on expenses and benefits is 15% for 2026/27 

The key thresholds that align strongly with payroll for 2026/27 include:

  • Primary Threshold: £242 per week (£12,570 per year)
  • Secondary Threshold: £96 per week (£5,000 per year)
  • Upper Earnings Limit: £967 per week (£50,270 per year) 

Employment Allowance remains a key employer offset

The employment allowance can reduce eligible employers’ annual employer (secondary) Class 1 National Insurance liability by up to £10,500. 

HMRC guidance also confirms that the previous restriction linked to having more than £100,000 of secondary Class 1 NIC liability (in the prior year) ceased from 6 April 2025 onwards. 

Corporation Tax for financial years starting 1 April

Corporation Tax rates depend on profits, and the published table for Corporation Tax years starting 1 April shows:

  • 19% small profits rate for companies with profits under £50,000
  • 25% main rate for companies with profits over £250,000
  • marginal relief applies between those limits (with published limits and fraction). 

VAT thresholds and registration

The VAT registration threshold is more than £90,000 of taxable turnover (rolling 12-month test). The voluntary deregistration threshold is £88,000. 

If you exceed the threshold, government guidance explains that you must register within 30 days of the end of the month when you went over the threshold. It also sets out the “effective date of registration” as the first day of the second month after you go over. 

Making Tax Digital for Income Tax begins for many from April 2026

For sole traders and landlords, the biggest operational change at the start of 2026/27 is the move into Making Tax Digital for Income Tax.

Who must comply from 6 April 2026

Government guidance confirms Making Tax Digital for Income Tax becomes mandatory from 6 April 2026 for individuals with qualifying income over £50,000 from self-employment and property. 

It is being phased in, with published thresholds showing:

  • qualifying income over £50,000 → mandatory from 6 April 2026
  • qualifying income over £30,000 → mandatory from 6 April 2027
  • qualifying income over £20,000 → mandatory from 6 April 2028 

What it changes day-to-day

HMRC guidance states that you (or your agent) will need compatible software to keep digital records and send quarterly updates, and then submit your tax return and pay tax due by 31 January after the end of the tax year. 

There is also a published first-year “soft landing” on quarterly update penalties: where you are required to use MTD from 6 April 2026, HMRC will not apply penalty points for late quarterly updates in the first year (2026/27), though penalties still apply for late tax returns and late payment. 

Start-of-year checklist

A clean start in April saves time (and usually stress) later in the year.

Individuals and families:

  • Check your tax bands and Personal Allowance position, especially if your income is around £100,000 (Personal Allowance taper) or close to £125,140. 
  • If you receive dividends outside ISAs and pensions, update your 2026/27 dividend tax estimates for the rate rise. 
  • If you are planning a business sale or exit, factor in the Business Asset Disposal Relief rate now being 18% for disposals on or after 6 April 2026. 
  • If you have significant farm or business assets, review Inheritance Tax exposure under the new £2.5 million cap on 100% relief for deaths on or after 6 April 2026. 

Employers:

  • Confirm payroll software has the correct 2026/27 PAYE and National Insurance settings. 
  • Check Employment Allowance eligibility and ensure it is being claimed correctly (up to £10,500). 
  • If you want to payroll benefits in kind for 2026/27, registration needed to be completed by 5 April 2026. 

Sole traders and landlords:

  • Use HMRC’s eligibility guidance to confirm if you must join Making Tax Digital from 6 April 2026 and choose compatible software early. 

How We Help You Deal With the Recent UK Tax Updates

At Apex Accountants, we help you translate the rules into practical decisions.

We support clients with:

  • personal tax planning (income tax bands, dividends, CGT planning, and reliefs)
  • director remuneration reviews in light of the 2026/27 dividend tax rates
  • payroll compliance, including correct NIC settings and Employment Allowance claims
  • VAT registration planning and ongoing VAT returns
  • Making Tax Digital for Income Tax readiness: eligibility checks, software setup, and quarterly update workflows
  • exit planning (including Business Asset Disposal Relief considerations) and succession planning where Inheritance Tax relief rules have changed from 6 April 2026

Conclusion

The new 2026/27 tax year brings fewer “headline” rate changes, but several impactful shifts are now live: higher dividend tax rates, an 18% rate under Business Asset Disposal Relief, new Inheritance Tax limits on 100% relief for qualifying farm and business assets, and the first mandatory phase of Making Tax Digital for Income Tax. 

FAQs About 2026 Tax Changes in UK

When does the UK tax year run?

The 2026/27 tax year runs from 6 April 2026 to 5 April 2027. 

What are the recent tax changes in the UK?

Recent tax changes include the Corporation Tax main rate remaining at 25% (unchanged since 2023), with dividend tax rates increasing to 10.75%/35.75% and Business Asset Disposal Relief rising to 18% from April 2026.

Are taxes going up in 2026 in the UK?

Corporation Tax remains at 25% for profits over £250,000 (unchanged since 2023). However, dividend tax rates will rise significantly from 6 April 2026, impacting many taxpayers.

Have Income Tax rates changed for 2026/27?

The main Income Tax rates remain 20%, 40% and 45% for England, Wales and Northern Ireland, with published bands as per government guidance.
If you live in Scotland, the Scottish Income Tax bands and rates apply to most non-savings, non-dividend income and differ from the rest of the UK. 

What are the dividend tax rates for 2026/27?

From 6 April 2026, the dividend ordinary rate is 10.75% and the dividend upper rate is 35.75% (additional rate remains 39.35%), with a £500 dividend allowance. 

What is Business Asset Disposal Relief in 2026/27?

Business Asset Disposal Relief applies a reduced CGT rate to qualifying disposals, and the rate is 18% for disposals on or after 6 April 2026 (compared with 14% in 2025/26). 

What is the VAT threshold in April 2026?

The VAT registration threshold is more than £90,000 of taxable turnover, with an optional deregistration threshold of £88,000. 

Do I need to use Making Tax Digital from April 2026?

Making Tax Digital for Income Tax becomes mandatory from 6 April 2026 if your qualifying income from self-employment and property is over £50,000, with phased expansion in later years. 

Can I just gift 100k to my son?

You can gift £100,000 to your son, but it may be subject to inheritance tax if you pass away within seven years, following the Potentially Exempt Transfer (PET) rule and taper relief.

Who pays 40% tax in the UK?

The 40% higher rate applies to taxable income between £50,271 and £125,140 after the £12,570 Personal Allowance. The Personal Allowance tapers from £100,000, reducing by £1 for every £2 earned over that threshold.

Tax Defaulting in Croydon: HMRC’s Crackdown on Non-Compliant Businesses

Tax defaulting in Croydon has moved back into focus following an update to HM Revenue & Customs’s (HMRC) “current list of deliberate tax defaulters” on GOV.UK. The list was updated on 26 March 2026 and publishes details where HMRC has charged penalties for deliberate defaults involving more than £25,000 of tax and where the taxpayer did not secure the maximum penalty reduction by fully disclosing the defaults. 

In the latest publication, several entries are linked to Croydon addresses, including a BOXPARK-linked food business: WTP Croydon Ltd (formerly trading as What the Pitta). HMRC’s published figures for that entry show £146,629.43 of tax on which penalties were based and a £64,150.37 penalty for a period of default from 1 July 2017 to 31 January 2023. 

HMRC’s deliberate defaulters list really means

HMRC’s deliberate defaulters publication is not a general “late payment” list. It is a specific legal regime that allows HMRC to publish identifying details after an investigation, after deliberate-default penalties are charged, and once those penalties are final (for example, once an appeal window has passed, an appeal is determined, or a contract settlement is agreed). 

Publication is permitted where the penalties involve tax of more than £25,000 and the person did not achieve the maximum reduction available through full disclosure. In other words, disclosure behaviour matters: people can keep their details off the list by cooperating and fully disclosing from the outset of a compliance check. 

A few points that are easy to miss but crucial for reading the list correctly:

  • Addresses are time-specific. HMRC explicitly warns that the address shown is the one associated with the person or business at the time of the default—and that current occupants at that address may have no connection to the published person/business. 
  • The figures are not “total debt”. HMRC notes the amounts shown relate to the tax/duty on which penalties are based, and the list “does not necessarily represent the full default of the taxpayer”. 
  • Publication is time-limited. Details remain on GOV.UK for a maximum of 12 months, with HMRC typically reviewing and updating the list quarterly to keep within that legal limit. 

HMRC also makes clear that the list itself is time-bounded and not archived for the National Archives, reinforcing that it is designed as a deterrent mechanism rather than a permanent record. 

Tax defaulting in Croydon – The BOXPARK case study

The BOXPARK-linked entry matters because BOXPARK is not just another high street unit—it is a highly visible venue. BOXPARK Croydon was developed as a container-based food and drink destination beside East Croydon station, with the council publicly backing the regeneration narrative around a “gateway” location. 

Council-backed launch and funding context

Croydon Council published its intention to support bringing a Boxpark marketplace to Ruskin Square, explicitly describing the stripped and refitted shipping-container design and the aim of creating a year-round events courtyard. 

A council key-decision document (April 2015) records approval of a £3,000,000 loan to support delivery, alongside references to a programme of council-backed activity and operational support (including a five-year pop-up programme and a viability grant). 

Later local reporting also describes the council redirecting an “Ambition Festival” budget towards BOXPARK-related launch/event activity and refers to additional subsidies in the first years of operation. 

Vendor pressures in the early years

It is important to separate venue trading conditions from tax conclusions. HMRC’s listing is about deliberate defaults and closed penalty positions; it does not, by itself, explain why a business got into difficulty or how cash flow was managed.

That said, contemporary reporting from 2018–2019 describes pressure points commonly faced by street-food operators in container venues: significant fixed costs, footfall volatility, and churn among traders. For example, one report described monthly rents and service charges totalling £2,750 (£2,000 rent plus £750 service charge) for a trader at the time and noted a sharp reduction in listed outlets between late 2016 and early 2018. 

A later report quoted tenants discussing typical combined rent/service-charge costs of around £3,000 per month (plus electricity), alongside complaints about footfall and event-day disruption. 

Croydon entries on the HMRC list updated 26 March 2026

The table below summarises the Croydon-linked (address-associated) entries visible on HMRC’s current list updated 26 March 2026, including the BOXPARK-linked takeaway and other sectors (commercial vehicle sales, property development, care, and property income). 

Listed name (as published by HMRC)Trade/occupation (HMRC description)Address context (HMRC wording)Period of defaultTax on which penalties are basedPenalty chargedPenalty as % of tax (calculated)
WTP Croydon Ltd (formerly trading as ‘What the Pitta’)TakeawayFormerly of Unit 9, Boxpark, 99 George Street, Croydon, CR0 1LD1 Jul 2017 to 31 Jan 2023£146,629.43£64,150.37~43.8%
J-Mech Waste Solutions LtdCommercial vehicle salesFormerly of 93 Southbridge Road, Croydon, CR0 1AJ1 Mar 2022 to 30 Sep 2022£598,945.00£568,997.7595.0%
Lionwood LtdBuilding developerFormerly of 29 Banstead Road, Purley, CR8 3EB1 Aug 2023 to 31 Dec 2023£50,258.21£42,719.45~85.0%
Leiston Old Abbey LtdResidential care homeFormerly of 4 Arkwright Road, Sanderstead, CR2 0LD1 Apr 2019 to 31 Mar 2021£44,410.75£31,087.52~70.0%
Maria Jose De Souza CamposProperty incomeFormerly of 31 Hardcastle Close, Croydon, CR0 6XQ (and another address)6 Apr 2017 to 5 Apr 2020£34,940.40£20,178.06~57.8%

Two practical cautions are worth repeating when an address is high-profile (like BOXPARK):

HMRC states that the address is the one associated at the time of the default, and current businesses trading at the same site may be unrelated. 

Underpaid tax, penalties, and what the published figures do not tell you

The “nearly £150k” framing seen in local discussion is consistent with the published tax figure for WTP Croydon Ltd: £146,629.43 is close to £150,000, and that can be enough to trigger strong public reaction because publication is designed to deter deliberate non-compliance. 

But there are three important technical limits to what you can conclude from the published table:

HMRC Publishes Only the Tax and Penalty Figures

HMRC releases two key numbers in each entry:

  • The amount of tax or duty on which the penalty is based
  • The penalty charged by HMRC

However, the list does not explain the underlying issue. For example, it does not state whether the case involved the following:

  • VAT underpayments
  • Corporation Tax errors
  • PAYE or payroll failures
  • A combination of several tax issues

This means the published entry gives only a financial snapshot rather than a detailed narrative of the compliance failure.

The Published Tax Figure May Not Reflect the Full Default

Another important clarification is that the amount labelled as “tax” in the list does not necessarily represent the total liability discovered during HMRC’s investigation.

HMRC explicitly notes that:

  • The figures shown relate only to the tax on which the penalty calculation is based.
  • The actual amount owed to HMRC may be higher.
  • Additional liabilities may have been settled separately during the investigation process.

Because of this, readers should not assume that the tax figure shown equals the full underpayment identified in the case.

Penalty Percentages Can Vary Widely

The relationship between the tax amount and the penalty can differ significantly across cases.

For example, Croydon-linked entries on the March 2026 list show penalties ranging from around 44% to 95% of the tax involved.

This variation occurs because HMRC calculates penalties based on several factors, including:

  • The behaviour of the taxpayer (careless vs deliberate actions)
  • Whether the taxpayer disclosed the issue voluntarily
  • The level of cooperation during the investigation
  • The timing of disclosure and corrective action

Businesses that make an early disclosure and cooperate with HMRC often receive lower penalties and may avoid public naming altogether.

If you are checking the list for due diligence (suppliers, landlords, franchise partners), here is the approach we recommend in practice:

  • Treat the list as a risk flag, not a complete case file. 
  • Cross-check publication timing. HMRC only keeps details up for 12 months and updates regularly (often quarterly). A person may disappear because the legal time limit expired, not because the situation “improved”. 
  • Remember there is no right of appeal against the decision to publish (separate from appeal rights on tax/penalty decisions), so the correct moment to manage exposure is early—before penalties become final and publication criteria are met. 

How We Help Businesses in Croydon Stay Tax Compliant

At Apex Accountants, we help Croydon businesses reduce the risk of painful compliance surprises and reputational damage.

We typically support clients with:

  • Tax compliance health checks (VAT, PAYE, and CIS where relevant) to spot weaknesses before HMRC does.
  • Bookkeeping clean-ups so returns are supported by reliable records and the right evidence trail.
  • Disclosure support where errors are discovered, focusing on early, complete, and well-structured disclosure in line with HMRC expectations. 
  • Penalty and appeal support by working with your legal/tax advisers on the evidence and timeline behind HMRC decisions (especially where deliberate behaviour is alleged). 
  • Cashflow planning around tax liabilities, including support preparing information that can help with HMRC engagement when a business is under pressure.

Conclusion

The March 2026 HMRC publication puts a sharper lens on tax defaulting in Croydon, not because the borough is unique, but because the list makes deliberate compliance failures visible—often with headline figures that are easy to misunderstand without context. 

For local readers, the BOXPARK-linked entry is a reminder of two parallel truths: high-profile venues can amplify reputational fallout, and the published figures are still a narrow slice of a wider compliance story (time-bounded, address-specific, and not necessarily the full amount owed). 

FAQs about the HMRC deliberate tax defaulters list

1. What is the HMRC deliberate defaulters list?

It is a GOV.UK publication where HMRC can publish identifying details of people or businesses that have been charged penalties for deliberate defaults involving more than £25,000 of tax, once penalties are final. 

2. How often does HMRC publish or update the list?

HMRC reviews the list regularly and says changes are usually made on a quarterly basis, partly to ensure entries are not published longer than the 12‑month legal maximum. 

3. How long do names stay on the list? 

A defaulter’s details are held on GOV.UK for a maximum of 12 months from the date first published. 

4. Can you avoid being named and shamed?

HMRC advises taxpayers involved in a compliance check to disclose errors early, cooperate, and resolve the check promptly—because that affects penalty reductions and publication risk. 

5. Can you go to jail for tax evasion in the UK?

Being on the deliberate defaulters list relates to civil penalties and is not the same as a criminal conviction.  Separately, serious tax fraud offences can be prosecuted and can carry substantial custodial sentences, with the Sentencing Council noting maximums that include 14 years’ custody for certain fraudulent evasion offences, and life imprisonment for “cheat the public revenue.” 

Everything About UK Non‑Dom Tax Changes in April 2026

What changed in non-dom tax from April 2025

From 6 April 2025, the long‑running remittance basis ended. In practical terms, the UK no longer taxes most “non‑dom” individuals on foreign income and gains only when money is brought into the UK. Instead, UK tax residence is now the main driver, with a new relief aimed at genuinely new arrivals. 

What that means day‑to‑day: from 6 April 2025, UK residents are generally taxed on worldwide income and gains as they arise, unless they qualify for and claim the new Foreign Income and Gains regime for new/returning residents. 

TopicUp to 5 April 2025 (remittance basis era)From 6 April 2025 (current rules)
Main “gateway”Domicile + a remittance basis claim (and related rules)Residence‑led: worldwide taxation on the arising basis, unless it is in the new regime 
Foreign income & gains (newly arising)Often taxed only if remitted (subject to conditions)Taxed as they arise for most UK residents; relief available for qualifying new residents 
Bringing foreign funds to the UKCould trigger UK tax if the funds were untaxed FIGFor eligible FIG under the new regime, remitting does not create a UK charge; for historic FIG, old remittance concepts still matter 

The Foreign Income and Gains regime for new residents

The cornerstone of the reform is a four‑tax‑year “Foreign Income and Gains” relief for people who are genuinely new (or returning) to the UK tax net.

Who can claim foreign income and gains relief

You can claim foreign income tax and gains relief if you are a UK tax resident under the Statutory Residence Test and are still within your first four tax years of UK residence after at least ten consecutive tax years of non-UK residence. 

A key point many people miss is that if your UK residence started before 6 April 2025, you may still be able to use the regime from 2025/26 onwards for whatever part of your four‑year window remains (there is no “reset” unless you have a further ten‑year non‑resident period). 

What relief you get

If you make a valid claim, you do not pay UK tax on eligible foreign income and foreign gains for the sources you claim, and remitting those relieved amounts to the UK does not create a tax charge. 

Eligible foreign income includes, for example, overseas trade profits, overseas property business profits, non‑UK dividends and foreign interest. 

The trade-offs: what you give up

Claiming comes with a cost. If you claim under the regime, you lose key UK allowances for that tax year, including income tax and capital gains tax allowances and certain marriage‑related allowances. 

Also, even where relief applies, foreign income and gains typically still need to be reported (the old “leave it offshore and don’t report it” mindset is no longer a safe default). 

Transitional rules for former remittance basis users

The reform did not wipe the slate clean for earlier years. Historic offshore funds still need careful handling, and this is where many accidental tax bills arise.

Historic foreign income and gains are still “historic”: 

Where someone used the remittance basis before 2025/26, the remittance basis can still apply to income and gains that arose in those earlier tax years. In simple terms, those historic amounts can still become taxable if and when they are remitted, unless you use a specific transitional facility. 

The Temporary Repatriation Facility:

The main transition tool is the Temporary Repatriation Facility. It runs for a fixed three‑tax‑year period and is designed to let former remittance basis users bring pre‑6 April 2025 offshore income and gains to the UK at a flat, reduced charge by designating amounts and paying the TRF charge. 

TRF designation yearFlat TRF charge on designated “qualifying overseas capital”
2025/26 or 2026/2712% 
2027/2815% 

Two practical points matter in real life:

  • You do not have to remit the designated amount during the TRF window to benefit from the reduced rate; designation can be done and funds brought over later without further UK tax on that designated amount. 
  • If you remit an amount in a tax year but fail to designate it in that same year’s return, you can be exposed to the normal remittance taxation (designating later will not “fix” a prior remittance). 

CGT rebasing for certain foreign assets:

A separate transitional relief allows some former remittance basis users to rebase certain personally held foreign assets to their market value at 5 April 2017, so that only post‑rebasing growth is taken into account for UK capital gains tax on a later disposal. The government’s published design includes conditions such as holding the asset at 5 April 2017 and disposing of it on or after 6 April 2025. 

Payroll support for mobile employees:

For globally mobile employees, employers can notify HM Revenue & Customs that they will operate PAYE on only the proportion of earnings related to UK duties (the mechanism previously associated with “section 690”). The current guidance also covers split‑year cases and employees eligible for Overseas Workday Relief. 

Inheritance tax becomes residence-based

Inheritance tax is now aligned with residence history, not domicile labels.

From 6 April 2025, the domicile and deemed‑domicile framework for bringing non‑UK assets into inheritance tax was replaced by a long‑term UK resident test. If you are long‑term resident, your overseas assets can fall within UK inheritance tax on death or on certain lifetime transfers. 

Who is a “long-term resident”

You are generally a long‑term resident if you have been UK tax resident for at least ten out of the prior twenty tax years. There is also a rule set that can treat you as long‑term resident after ten consecutive years. 

The “tail” after leaving the UK

Leaving the UK does not necessarily end exposure immediately. The inheritance tax manual sets out a tail that can run from three up to ten tax years, depending on how many years of UK residence you have in the look‑back period. 

Trusts are directly in scope

The long‑term residence framework also affects trusts. The official guidance states that inheritance tax can be charged on overseas assets in a trust you set up or added to, with specific conditions and exceptions depending on when assets were settled and their location at key dates. 

How We Help Clients Navigate UK Non-Dom Tax Changes

At Apex Accountants, we focus on the practical work clients need to stay compliant and avoid avoidable tax costs under the post‑April 2025 rules.

We typically help with:

  • Residence and eligibility reviews to confirm whether the Foreign Income and Gains regime is available and which claims are worth making.
  • TRF planning and designation support, including fund tracing, mixed-fund cleanup strategy, and ensuring designations align with remittance timelines.
  • CGT modelling and rebasing support, including “before and after” disposal scenarios and valuation requirements.
  • Inheritance tax exposure mapping, particularly around long‑term resident status, tail periods, and trust interaction.
  • Employer and payroll guidance for globally mobile employees, including PAYE proportion notifications and split‑year considerations.

Conclusion

The abolition of the remittance basis from 6 April 2025 has shifted the UK to a residence‑led approach: worldwide taxation is now the default for UK residents, with a tightly defined new‑arrival relief, specific transitional tools for historic offshore funds, and a major reset for inheritance tax based on long‑term residence. 

FAQs

1. Can I still use the remittance basis?

Not for new income and gains from 6 April 2025. However, the remittance concept remains relevant for pre‑6 April 2025 foreign income and gains that arose while you were on the remittance basis. 

2. Do I get four years completely tax‑free in the UK?

You can receive 100% UK relief on eligible foreign income and gains during your qualifying period, but only if you qualify and make a claim. You may also lose UK allowances in the year(s) you claim. 

3. If I claim the new regime, do I still have to report foreign income and gains?

In most cases, yes. The reporting position has tightened, and many more UK residents now need to report foreign income and gains even when relief applies. 

4. Can I bring historic offshore income to the UK tax‑free during the transition window?

No “amnesty” applies. The transition tool is the TRF, which offers a reduced flat charge (not a zero rate) if you designate correctly. 

5. What happens after the qualifying period ends?

Once your qualifying period ends, your default position is the normal UK arising‑basis taxation on worldwide income and gains. 

6. When does inheritance tax start applying to overseas assets?

From 6 April 2025, overseas assets can be within UK inheritance tax if you meet the long‑term resident test, with a tail that can continue after departure.

UK Tax System for Expats Explained – Who Must Still Pay UK Tax?

Many people move abroad and assume that ends their UK tax position. In practice, it often does not. The UK tax system for expats can still apply in several situations. At Apex Accountants, we regularly see expats caught by UK tax rules because they still have UK income, return to the UK too often, keep a home here, sell UK property, or come back after a short period overseas. UK tax is driven mainly by residence status and specific UK connections, not by where you feel permanently settled.

The key point is simple. You can live abroad and still be drawn into the UK tax system in several different ways. You might become a UK tax resident again under the Statutory Residence Test. You might stay non-resident but still have to pay UK tax on rental income, wages for UK workdays, or gains on UK property. You might also face extra rules if you return to the UK after a short spell overseas.

Understanding the UK Tax System for Expats

Why many people still get caught by UK tax for expats

The most common mistake is thinking there is one simple “day count” that keeps you safe. There is not. The UK uses the Statutory Residence Test, which looks at automatic overseas tests, automatic UK tests and then the sufficient ties test. Your position is tested tax year by tax year. That means someone can be non-resident one year and resident the next, even if their lifestyle feels broadly the same.

The first route: becoming UK tax resident again

For many expats, the biggest risk is drifting back into UK residence without realising it. HMRC says non-residents only pay UK tax on their UK income, while residents normally pay UK tax on all their income, whether it comes from the UK or abroad. That is why residence status matters so much.

A quick guide to the residence rules for expats

Rule areaWhat it means
Automatic overseas testsThese can keep you non-resident if you meet strict day and work limits
Automatic UK testsThese can make you resident automatically
Sufficient ties testIf no automatic test applies, your UK ties and UK day count decide the outcome

HMRC’s automatic overseas tests include two headline day limits that expats often rely on. If you were a UK resident in one or more of the previous 3 tax years, you usually need to spend fewer than 16 days in the UK to meet the first automatic overseas test. If you were not a UK resident in any of the previous 3 tax years, the second automatic overseas test usually requires fewer than 46 days in the UK. There is also a third overseas test for people working sufficient hours overseas, provided UK workdays stay below 31 and total UK days stay below 91.

On the UK side, the clearest trigger is 183 days or more in the UK in the tax year. There is also a home test. HMRC says you may become a resident if there is at least one 91-day period in which you have a UK home and spend enough time there, while spending fewer than 30 days in any overseas home.

Also Read: Could Returning to the UK Trigger a Returning Expatriates UK Tax Bill? What You Need to Know

The “ties” that catch expats out

If none of the automatic tests settle your status, HMRC applies the sufficient ties test. This is where many expats run into trouble. The number of ties needed depends on how many days you spend in the UK and whether you were a resident in any of the previous 3 tax years. For someone recently resident in the UK, even 46 to 90 UK days can be enough if they have at least 3 ties.

The main ties include the following:

  • Family tie: for example, a UK resident spouse, partner or child under 18 in the UK in the relevant way.
  • Accommodation tie: a place to live in the UK available for at least 91 continuous days, with enough nights spent there.
  • Work tie: UK workdays can matter, especially where more than 3 hours of work are performed on enough days.

This is why casual visits can become risky. Staying with family, keeping a UK flat, doing a few work trips, or spending more time here during school holidays can shift the result.

The second route: staying non-resident but still paying UK tax

Many expats are surprised to learn that leaving the UK does not remove UK tax from UK income. GOV.UK is clear that you usually have to pay tax on your UK income even if you are not a UK resident. That includes things like pension income, rental income, savings interest and wages.

Common areas where tax still applies

Income or assetWhy it matters
UK rental incomeUsually remains taxable in the UK
UK workdaysUK tax for expats can apply to work performed here
UK property salesNon-residents must report all disposals of UK property or land
UK pensions and other UK incomeTreaty relief may help, but the UK position still needs checking

Rental income is one of the most common traps. You need to pay tax on UK rental income if you rent out a property here. If you live abroad for 6 months or more per year. HMRC classifies you as a non-resident landlord for these purposes, even if you are still a UK resident for tax. Tax may be deducted by a letting agent or tenant unless HMRC approves gross payment through the relevant application route.

Double taxation agreements can help if the country where you live also taxes that income. GOV.UK says you may be able to claim full or partial relief, depending on the treaty. But that does not mean you can ignore the UK side. It means you need the position reviewed properly.

The third route: selling UK property while abroad

This is another major area where expats get caught. If you are not resident in the UK, you must report all sales of UK property or land even if you have no tax to pay. That applies to residential and non-residential property.

For UK residential property sold on or after 27 October 2021, the reporting and payment deadline is generally within 60 days of completion. GOV.UK warns that you should not wait until the next tax year to deal with it, because interest and penalties may apply.

This is often missed because people assume no tax means no filing. That assumption is wrong for non-residents selling UK property. Even where a loss arises, or relief means little or no tax is due, the reporting duty can still apply.

The fourth route: returning to the UK too soon

Some expats leave the UK, realise gains or receive income abroad, and then return within a few years expecting those transactions to stay outside the UK tax net. HMRC’s temporary non-residence rules are designed to stop that. HMRC states that when an individual returns to the UK after a period of temporary non-residence, they may be charged to tax on certain income and gains received during that period.

A person can be temporarily non-resident if, among other conditions, they had sole UK residence before departure, were solely UK residents in 4 or more of the 7 tax years before leaving, and their period of non-residence is 5 years or less. HMRC also states that for these special rules not to apply, the period of non-residence must exceed 5 years, in effect at least 5 years and 1 day.

For capital gains in particular, gains arising during a period of temporary non-residence can become chargeable to Capital Gains Tax in the period of return. This is a key trap for expats who sell assets while abroad and then move back sooner than planned.

Split-year treatment can help, but it is not optional

When someone leaves or arrives in the UK during a tax year, split-year treatment may apply. HMRC explains that a split year divides the year into a UK part and an overseas part. The UK part is taxed broadly as resident, while the overseas part is taxed broadly as non-resident for most purposes.

However, this is not something you simply choose because it suits you. If you meet the conditions for one of the split-year cases, it applies. If you do not, it does not. That makes it essential to review the facts carefully rather than relying on assumptions.

New rules on foreign income and gains

Since 6 April 2025, the old remittance basis has been replaced by the 4-year foreign income and gains regime. If you qualify and claim under this regime, you will not pay tax on eligible foreign income and gains covered by the claim. To qualify, you must be a UK tax resident under the Statutory Residence Test and still be within your first 4 years of UK tax residence after at least a 10-year period of non-UK tax residence.

This matters for expats returning to the UK after a long period abroad. The new regime may offer relief, but it has conditions and limits. GOV.UK also says unused years cannot be rolled forward. So a returning expat should review their position as soon as they become a UK resident again, not years later.

Inheritance Tax can still follow some expats after they leave

Income Tax and Capital Gains Tax are not the only issues. From 6 April 2025, GOV.UK says the old domicile and deemed domicile rules for Inheritance Tax were replaced by long-term UK residence rules. If you are a long-term UK resident, your overseas assets may be subject to Inheritance Tax.

A person is a long-term UK resident if they were a UK tax resident for either the previous 10 consecutive years or for 10 years or more in the previous 20 years. GOV.UK also says you can keep long-term UK residence for up to 10 tax years after leaving the UK, although that tail can be shorter depending on how long you lived here before departure.

That means some expats can leave the UK and still remain exposed to UK Inheritance Tax on overseas assets for years afterward. This is a major point that is often missed in international estate planning.

Key deadlines expats should not miss

ObligationMain deadline
Tell HMRC you need a returnBy 5 October after the relevant tax year
Paper Self Assessment returnBy 31 October
Online Self Assessment returnBy 31 January
Self Assessment tax paymentBy 31 January
UK residential property CGT reportUsually within 60 days of completion

GOV.UK says HMRC must receive your tax return and any money owed by the deadline. Missing these dates can trigger penalties and interest.

How We Can Help You

At Apex Accountants, we help expats and internationally mobile individuals understand exactly where they stand before problems build up.

Our support includes:

  • reviewing your UK residence position under the Statutory Residence Test
  • checking whether split-year treatment may apply
  • reviewing UK rental income and non-resident landlord obligations
  • handling UK property disposal reporting
  • advising returning expats on temporary non-residence risks
  • assessing whether the 4-year foreign income and gains regime may apply
  • reviewing longer-term Inheritance Tax exposure for former UK residents

Each case turns on detailed facts. A few extra days in the UK, a family connection, a retained home, or a return to Britain sooner than expected can change the outcome.

Conclusion

Yes, expats can absolutely be dragged into the UK tax system. Sometimes that happens because they become UK residents again. Sometimes it happens because UK income and UK property remain taxable even while they live abroad. In other cases, the issue only becomes clear when they return to the UK, sell property, or begin reviewing their estate planning.

The rules are not impossible, but they are technical. The safest approach is not to assume. It is to review your residence status, income sources, property exposure and future plans early using current HMRC guidance. If you are unsure how these rules apply to you, contact Apex Accountants for professional guidance. Our specialists can review your circumstances and help you manage your UK tax position with confidence.

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