Explanatory notes have been published for government amendments to Finance Bill 2026.

Tax analysis: Legislation proposed by the government in Part 7 of the Finance Bill 2026 will mandate that tax advisers register with HMRC. The registration scheme is designed to address inconsistencies across HMRC’s current services, to ensure minimum standards among advisers and reduce the presence of so-called ‘bad actors’ in the sector. Any individual or organisation offering tax advice, which is defined broadly, must register with HMRC. Failure to register can lead to compliance notices giving an opportunity to register, fines and orders ultimately preventing future registration indefinitely. Exemptions to registration include responding to requests for information from HMRC or interacting with HMRC in relation to an appeal to the tribunal. Written by Gideon Sanitt, a partner in the litigation and dispute resolution team at Macfarlanes LLP, and Joshua Rutt, an associate in the litigation and dispute resolution team at Macfarlanes LLP.

Tax analysis: Finance Bill 2026 (FB 2026) introduces the most extensive reform to the UK’s international tax regime in over a decade. In this piece, Jessica Eden, partner, Salli McElligott, counsel, Naoko Uehara, senior associate, and Carlos Garcia Cuesta, senior economist at Baker McKenzie, look at some of the key changes being made.

Tax analysis: The government is legislating in Finance Bill 2026 for new measures to tackle the promotion of marketed tax avoidance schemes. Abigail McGregor and Ian Robotham, Legal Directors in Pinsent Masons’ Contentious Tax team, analyse the measures and consider their practical consequences.

Tax analysis: The Final Report of the independent review of the Loan Charge, together with the government’s response to the Final Report, were both published at Budget 2025, with Finance Bill 2026 containing provisions in respect of the accepted recommendations. Jackelyn West, a senior associate in Macfarlanes’ tax disputes team, sets out the key outcomes of the Final Report and government response below.

Tax analysis: Following the decisions in Delinian Ltd (formerly Euromoney Institutional Investor plc) v HMRC and Wilkinson v HMRC legislation is being introduced, effective from Budget 2025 on 26 November 2025, to allow HMRC to dissect a transaction into its constituent parts to counteract avoidance. This is facilitated by a number of changes to sections 137 and 138 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992). Philip Ridgway, barrister, Temple Tax Chambers and member of the LexisNexis Tax Consulting Editorial Board, considers the background to the legislation and scope of the new provisions.

Tax analysis: The government is legislating in Finance Bill 2026 to implement new anti-fraud measures in the construction industry scheme (CIS). Ian Robotham and Abigail McGregor, legal directors in Pinsent Masons’ Contentious Tax team, analyses the measures and considers their practical consequences.

Tax analysis: Natasha Kaye, partner at Akin Gump Strauss Hauer & Feld, highlights the key features and practical considerations of the new stamp duty reserve tax (SDRT) UK listing relief announced at Budget 2025 and brought into effect that day.

Tax analysis: Helen Coward is a partner at Simmons & Simmons LLP. Helen provides both direct and indirect tax advice on a wide range of matters and transactions, with particular experience in relation to real estate taxation, investment funds and private equity transactions. In this article, Helen considers the advance tax certainty service, launching in July 2026, which is a new HMRC initiative offering binding, upfront tax certainty for major UK investment projects. Open to both UK and non-UK investors, the service is open to projects with at least £1bn of qualifying UK expenditure. It covers corporation tax, VAT, Stamp duty land tax (SDLT), income tax, Pay As You Earn (PAYE), and the construction industry scheme. Clearances are binding on HMRC for up to five years, with the possibility of renewal, unless there is a change in law or material facts. The process is intended to be collaborative, involving early engagement and scoping meetings, and aims for a 90-day turnaround once an application has been made. The service is expected to enhance the UK’s attractiveness for large-scale investment, with its scope and operation to be reviewed after 12 months to ensure it meets business needs.

The House of Lords Finance Bill Sub-Committee has launched an inquiry into the Draft Finance Bill 2025–26, focusing on two key provisions: (1) reforms to bring unused pension funds and death benefits within the scope of inheritance tax and (2) changes to agricultural property relief and business property relief. The Sub-Committee is seeking evidence from taxpayers, their advisers and relevant organisations. The deadline for submitting written evidence is 7 October 2025. The Sub-Committee will publish its recommendations in a report following the conclusion of the inquiry.

Financial Services analysis: In each of three cases relating to motor finance commission (Johnson, Hopcraft and Wrench), car dealers had introduced customers to lenders to help the customers obtain secondhand vehicles on finance, and been paid commission by the lenders for doing so. The Court of Appeal held that in Hopcraft and Wrench the lenders were liable for paying secret commission, and in Johnson the lenders were liable as accessories for procuring the dealer’s breach of fiduciary duty. The findings that car dealers owe their customers fiduciary duties when helping them to obtain finance, and that statements in a lender’s terms and conditions that commission may or will be paid may not amount to sufficient disclosure to negate secrecy, are likely to lead to significantly increased risks for all lenders who pay or have paid commission to credit brokers, whether in the motor finance industry or more widely. Written by Christopher Adams, barrister at Henderson Chambers.

Law360, London: The High Court has ordered the winding up of Kession Capital Ltd after it went into administration following claims of £1.7 million from investors in failed property redevelopment schemes, ruling that the reason for administration was 'tenuous'.