The Budget · September 2026
Autumn Budget on 28 October: what is already settled
The Chancellor has fixed the Autumn Budget for Wednesday 28 October 2026, and the speculation is already building. Much that matters to private clients does not depend on it, because it is already law: unused pension funds enter the inheritance tax estate for deaths from 6 April 2027, the tax rates on savings and property income rise by two points from the same date, the cash ISA subscription cap of £12,000 for those under 65 arrives in April 2027, and the high value council tax surcharge on English homes worth more than £2 million follows from April 2028. Planning against the known changes now leaves the Budget itself with less power to surprise.
Estates and succession · September 2026
Pensions and inheritance tax from April 2027: the machinery is now in law
Finance Act 2026, which received Royal Assent on 18 March, brings most unused pension funds and death benefits within the inheritance tax estate for deaths on or after 6 April 2027. HMRC has since published a technical note and draft regulations on the exchange of information between personal representatives and pension scheme administrators, which will now be required before a grant is issued. Personal representatives will be able to direct a scheme to pay inheritance tax to HMRC directly before funds are released, an important safeguard against being liable for tax on money they cannot reach. For anyone whose pension was intended to pass to the next generation, the year ahead is the time to revisit that intention.
Personal taxation · September 2026
Making Tax Digital for Income Tax: the first year, and who is next
Since 6 April 2026, sole traders and landlords with combined gross income above £50,000 have been required to keep digital records and file quarterly updates. The threshold falls to £30,000 from April 2027 and to £20,000 from April 2028, and HMRC has said that from this month it will begin signing up taxpayers automatically where it believes they should already be within the regime. HMRC is also writing to landlords whose declared rental income does not match the information it holds from deposit schemes and other sources. If you receive such a letter, it should not be ignored; if you are approaching the thresholds, the transition is far easier planned than improvised.
Family enterprises · September 2026
Payrolling of benefits becomes mandatory from April 2027
From 6 April 2027, company cars, car and van fuel, vans and private medical benefits must be reported through payroll in real time rather than on a form P11D after the year end, with most other benefits and expenses following from April 2028. Employers will be able to register voluntarily from November 2026 to payroll benefits outside the first phase, including beneficial loans and living accommodation. For owner managed companies the change is administrative rather than fiscal, but it needs the payroll, the software and the timing of benefit decisions to be ready before the first pay run of the new year.
Structuring · September 2026
UK land held offshore: the Upper Tribunal in Knights Developments
In Knights Developments Ltd v HMRC [2026] UKUT 329, the Upper Tribunal confirmed that profits made by a non resident company from acquiring, developing and selling United Kingdom land are taxable here under the immovable property article of the relevant treaty, even where the company has no permanent establishment in the United Kingdom. The case concerned the Isle of Man treaty, but the reasoning reaches further. Anyone holding or developing United Kingdom property through an overseas company should have the structure reviewed against it.
International · September 2026
The first tax returns under the foreign income and gains regime
The returns now being prepared for 2025 to 2026 are the first under the regime that replaced the remittance basis, and they work differently: foreign income and gains must be reported in full before relief is claimed, the claim is made each year on the residence pages and is not automatic, and those claiming it forgo the personal allowance and the capital gains exemption. The temporary repatriation facility, which allows pre April 2025 foreign income and gains to be brought to the United Kingdom at a reduced rate, runs until 5 April 2028, and the designation for 2025 to 2026 must be made by 31 January 2028 and cannot afterwards be amended. For anyone who arrived recently, or who holds untaxed funds abroad, this is the year in which the new rules bite for the first time.