Tax information exchange and FATCA

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FORTHCOMING CHANGES: The UK is due to implement the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law with effect from 1 January 2026. The implementing measure is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which was laid before the House of Commons on 25 June 2025. On the same day, HMRC published tax impact and information notes (TIIN) for the measure. HMRC has also published guidance on reporting under the CARF.

The government has also introduced legislation amending the domestic law implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878) and the amending measure is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). The amendments implement the OECD’s 2023 changes to the CRS and introduce other changes ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5). The principal changes are to include e-money

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Latest Tax News

UT rules FTT erred in holding that property was not entirely ‘residential property’ (HMRC v Brzezicki)

Tax analysis: In HMRC v Brzezicki, the Upper Tribunal (UT) allowed HMRC’s appeal against the decision of the First-tier Tax Tribunal (FTT) and held that the residential rates of Stamp Duty Land Tax (SDLT) applied to the purchase of a house and land.

Tax weekly highlights—19 March 2026

This week's edition of Tax weekly highlights includes: (1) the enactment of Finance Act 2026 on 18 March 2026, (2) HMRC launching a consultation on extending the Uncertain Tax Treatment regime, (3) News Analysis on the Court of Appeal’s decision in Muller UK and Ireland Group LLP that amortisation debits were correctly disallowed by HMRC, (4) News Analysis on the UT’s decision in Putney Power Limited on the issue of whether the appellants had begun to trade by the relevant date for EIS relief purposes, (5) new HMRC guidance on multinational top-up tax and domestic top-up tax reporting software, and (6) News Analysis on the FTT’s decision in Countrywide Partners Limited to uphold a penalty for failure to comply with a stop notice issued under the promoters of tax avoidance schemes (POTAS) rules.

Upper Tribunal denies EIS relief as trade not commenced (Putney Power and Piston Heating v HMRC)

Tax analysis: The Upper Tribunal (UT) has held that the First-tier Tax Tribunal (the FTT) made a material error of law in its approach to determining when a trade has ‘begun to be carried on’ by a company for the purposes of qualifying for Enterprise Investment Scheme (EIS) relief under section 179(2)(b) of the Income Tax Act 2007 (ITA 2007). The FTT had identified a set of principles by reference to factors which were of relevance in previous cases and applied those ‘legal’ principles to determine that neither Putney Power Limited (‘Putney’) nor Piston Hearing Services Ltd (‘Piston’) had begun to carry on a trade by the relevant date of 4 April 2018. The UT set aside the FTT’s decision on the basis that the FTT had sought to apply a principles-based test which did not exist as a matter of law. The proper approach requires a multi-factorial evaluation of all of the circumstances in the case at hand. The UT re-made the decision but ultimately reached the same conclusion as the FTT, dismissing the appeals of both Putney and Piston and holding that neither company had commenced trading by the relevant date. The decision is significant because it clarifies that there is no strict legal test for when a trade commences: the question remains highly fact sensitive and will be determined by reference to the particular facts and circumstances of each case. Written by Kate Ison (partner at Macfarlanes LLP) and Victoria Braid (associate at macfarlanes LLP).

FTT upholds £1m penalty for stop notice breach (Countrywide Partners Ltd v HMRC)

Tax analysis: In Countrywide Partners Ltd v HMRC, the First-tier Tax Tribunal (FTT) upheld HMRC’s £1m penalty on the taxpayer for breach of a stop notice under section 236A of the Finance Act 2014 (FA 2014), holding that the appellant continued to promote the arrangements by organising and managing them (including issuing payslips and making payments) for existing users.

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