Budget 2025: HMRC administration
Modernising HMRC’s outbound digital communications
From spring 2026 HMRC will be able to operate a ‘digital by default’ model for outbound communications. This means new and existing customers using our digital services will automatically receive digital letters instead of letters by post.
Gravita’s view
We are all accustomed to receiving correspondence from HMRC via the post, and aware of the problems this causes in terms of delays, especially when clients are travelling. Therefore, this is a very welcomed measure, which will be rolled out to both individuals and business owners.
There is however still a long way to go to try and meet the ultimate ambition, from HMRC which is to ensure that at least 90% of customer interactions are digital by 2030.
Advance Tax Certainty service
The Government will introduce a service whereby businesses can request clearance from HMRC on the application of corporation tax, VAT, stamp taxes, PAYE and the operation of the Construction Industry Scheme (CIS) to major investment projects. Once issued, the clearance will bind HMRC for 5 years (unless there is a change in the applicable law). To qualify, the project must cost at least £1 billion. The service opens in July 2026.
Gravita’s view
This will be a very welcome addition for businesses that carry out such significant projects in the UK. One has to wonder if such a step would be necessary if the system was not so complicated in the first place!
Collective money purchase scheme – registration for unconnected multiple employers
The 2021 Pension Schemes Act introduced a new type of collective pension scheme arrangement. Currently the law only allows single or connected employers to operate the scheme. The Department for Work and Pensions (DWP) are expanding the scheme to allow for unconnected employers to do so. The measures will be effective from Royal Assent to the Finance Bill.
Crown Immunity: repeal of old legislation
This measure repeals what is seen as an obsolete provision relating to ‘Dominion Governments’. Following consultation, which attracted no comments, it was agreed that the definition of ‘Dominion Governments’ is so uncertain that it is arguable that it no longer applies to any states. It is therefore being abolished.
Gravita’s view
You have to ask yourself how many more such provisions exist in the 21,000 or so pages of UK tax legislation.
Making Tax Digital (MTD) for Self-Assessment and VAT
For taxpayers joining Making Tax Digital for Income Tax in 2026-27, the government will waive late submission penalties on quarterly updates for that year. From 6th April 2027, the new late submission and late payment rules will apply to all other ITSA taxpayers. Penalties for late payment under both ITSA and VAT will also rise from 1st April 2027, with the details set through secondary legislation.
Increases to Corporation Tax late filing penalties
Late filing penalties were originally introduced in 1998 to encourage companies to file their CT returns on time. Over time, the relative value of these penalties has been eroded by inflation and they do not have the same behavioural impact as originally intended. With effect from 1 April 2026, the penalties are set to double as follows:
|
Current rate |
New rate |
|
| Return late |
£100 |
£200 |
| Return is more than 3 months late |
£200 |
£400 |
|
Three successive failures, return late |
£500 |
£1,000 |
| Three successive failures, return is more than 3 months late |
£1,000 |
£2,000 |
Gravita’s view
This is expected to raise £45m in the next year alone, rising to £70m in 2030-31. It is unlikely that this increase will change the behaviour of taxpayers that are consistently late with their tax returns and perhaps a tax-geared penalty system should be introduced alongside the flat-rate penalties for those companies which are profitable.
Capital Gains Tax: anti-avoidance for share exchanges and reorganisations
In simple terms, the government has closed a loophole that allowed some taxpayers to reduce or eliminate Capital Gains Tax (CGT) when swapping or reorganising company shares.
What’s changing?
- Normally, when a company carries out a genuine share-for-share exchange or reconstruction no CGT is due at the time, the gain is simply rolled over and taxed later when the new shares are sold
- From 26th November 2025, if HMRC decides that securing a tax advantage is the main purpose or one of the main purposes of the overall arrangement (not just the reorganisation itself), the rollover relief is denied, and CGT becomes payable immediately
- The old rule only examined the reorganisation in isolation; the new rule looks at the bigger picture, including any linked steps
This primarily effects complex, multi-step transactions. Genuine business restructurings and legitimate succession planning, including transitions to EOTs, remain fully supported and tax efficient. The new rules simply prevent artificial arrangements designed primarily to reduce tax.
Good news for anyone who submitted a clearance application to HMRC before 26th November 2025, the current legislation will apply to shares issued until at least 25th January 2026 or if later, 60 days after HMRC provides clearance.
The change is not retrospective, only share issues from 26th November onwards fall under the new test.
Gravita’s view
The amendment to the anti-avoidance provisions (in sections 137 and 139 TCGA 1992) is a measured tightening of the legislation rather than a fundamental shift. Legitimate commercial reorganisations and reconstructions continue to qualify for rollover treatment provided the primary driver is business rather than tax-driven.
Gravita has advised on and obtained HMRC non-statutory clearance for many share reorganisations and employee-ownership transactions. None of these relied on the contrived multi-step arrangements now targeted by the revised rules. For our clients, the practical impact of the change announced in the Budget is therefore minimal, while the additional clarity strengthens the defensibility of properly structured transactions.
We continue to recommend early engagement on any proposed reorganisation, particularly where it forms part of a wider succession or exit strategy. Our tax team can:
- Review existing plans against the new “main purpose” test
- Prepare and submit clearance applications where appropriate
- Model the tax and cash-flow outcomes of alternative structures, if required
Clients with transactions already in progress or under active consideration will be contacted by their usual Gravita Tax advisor to confirm their position and, if required, adjust documentation ahead of implementation.
Capital Gains Tax (CGT) – Incorporation Relief claims
From April 2026, businesses that look to transfer to a limited company tax free via Incorporation Relief will be required to make a claim for the relief via their self-assessment tax return. Previously the relief was automatic, but now claimants will be required provide a brief description of the transaction, the tax computations and type of business being transferred.
Gravita’s view
For most trading business, this appears to be a small amount of extra administration, but we suspect the reason for the change is the increased take up of property incorporations over recent years, as the tax landscape for individual landlords has become more onerous. HMRC will want details of the business to review as part of the transaction instead of having to find out about it. There are a lot of tax avoidance schemes being promoted on property incorporations and although moving property businesses to a company can offer great tax savings, it is incredibly important to obtain good advice to make sure the transfer does not come with a big CGT bill.
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