Time to act

The UK tax deadlines you need to comply with.

UK tax deadlines

Although many tax deadlines recur every year, they still seem to catch some individuals and businesses by surprise. The ability to meet these deadlines, either to take advantage of valuable tax reliefs that save you money or to avoid penalties, underscores the importance of timely tax planning.

To help you plan and take appropriate action, Time to act sets out forthcoming tax deadlines. Although the deadline dates provided below give an indication of how urgently you need to consider the issues, some will require initial attention well in advance.

Click on the category headings below to see more information about each deadline.

  • Corporate tax
  • Private client
  • Employment tax
  • Indirect taxes

Corporate tax

Mandatory disclosure rules reporting

Deadline for action: Ongoing

Issue: UK intermediaries that promote or assist in the design or implementation of certain cross-border arrangements may be required to report details of the arrangement to HMRC under the mandatory disclosure rules (MDR). In some circumstances, the reporting obligation may fall on the relevant UK taxpayer instead. A cross-border arrangement may be reportable if it circumvents the automatic exchange of information between tax authorities under the common reporting standard (CRS) or involves an opaque offshore structure that obscures the beneficial ownership of assets. 

A report must be made:

  • where the reporting obligation falls on an intermediary, within 31 days of the day they make the arrangement available for implementation or supply relevant services; or
  • where the reporting obligation falls on a taxpayer, within 31 days of the day the first step in the arrangement is implemented.

Action: Intermediaries and taxpayers should ensure they have implemented appropriate procedures and processes and that reporting obligations are met on a timely basis.

Register of overseas entities

Deadline for action: Ongoing

Issue: Relevant entities looking to acquire (or, in some cases, dispose of) UK property held freehold or on leasehold for a term exceeding seven years, or registrable charges over such property, must be entered on the Companies House register of overseas entities in order to register the property transaction with the relevant land registry. Registered relevant entities must file an annual update every year following registration. Relevant entities comprise companies and limited liability partnerships (LLPs) registered outside the UK, foreign foundations and non-UK partnerships with legal personality.

It is generally not possible for relevant overseas entities to directly acquire or dispose of UK property or hold registrable charges over such property without being registered. Failure to meet the obligation to register, where required, carries a criminal sanction for the entity and every officer of the entity who is in default. These range from fines of £2,500 per day for failing to update the register, to unlimited fines for making a materially false statement, and prison sentences.

Action: Affected entities that are not already registered should register and complete any necessary reporting on the Companies House register of overseas entities in advance of intended UK property transactions, as acquisitions and certain disposals by relevant entities cannot be registered at the relevant land registry until this has been done. Registered relevant entities must file an annual update within 14 days of the anniversary of the date they registered.

Corporation tax instalment payments due for very large companies

Deadline for action: 14 March 2025

Issue: The dates on which corporation tax payments are due depend on whether a company is large, very large or not large for these purposes. Very large companies are generally required to make four corporation tax instalment payments, two months and 13 days after the first day of their accounting period and every three months thereafter. Very large companies with a 31 December 2025 accounting reference date are required to make their first corporation tax instalment payment on 14 March 2025. Second, third or fourth instalment payments are due on the same day for very large companies with 30 September 2025, 30 June 2025 and 31 March 2025 period ends, respectively.

Action: Companies should consider whether they are subject to the corporation tax quarterly instalment payment regime for very large companies and, if so, should make arrangements to calculate and pay any instalments due. Very large companies are broadly companies with annual taxable profits exceeding £20m. This threshold is reduced proportionately by reference to the number of active associated companies under common control (generally as of the last day of the previous accounting period).

Corporation tax return filing

Deadline for action: 31 March 2025

Issue: Companies and other entities subject to corporation tax are required to file their corporation tax return by the anniversary of their accounting reference date for all relevant corporation tax accounting periods. Entities subject to UK corporation tax include UK companies, non-UK companies with a UK permanent establishment or a UK property business, non-UK companies and certain collective investment vehicles disposing of UK property, clubs, cooperatives and other unincorporated associations.

Action: Such entities with a 31 March 2024 accounting period end should ensure their 2024 corporation tax return is filed by 31 March 2025 to avoid late filing penalties, starting from £100.

Corporation tax claims and elections

Deadline for action: 31 March 2025

Issue: Companies and other entities subject to corporation tax must make certain claims and elections by the relevant anniversary of their accounting reference date. Relevant outstanding claims and elections must be submitted by 31 March 2025 for:

  • periods ended 31 March 2023 – eg claims for research and development (R&D) and creative sector tax reliefs (which must be accompanied by an additional information form submitted via HMRC’s online portal), loss carry-backs, group relief and capital allowances; and elections for patent box treatment; and
  • periods ended 31 March 2021 – eg claims for double taxation relief and overpayment relief.

Action: Entities subject to corporation tax in the relevant period with 31 March accounting period ends should ensure that relevant claims and elections for earlier accounting periods are made by 31 March 2025.

Publication of tax strategy

Deadline for action: 31 March 2025

Issue: Large businesses are required to publish details of their UK tax strategy (including certain prescribed information) on the internet by the end of their accounting period. Large businesses include:

  • multinational groups (with global annual turnover exceeding €750m); and
  • single UK entities (UK companies, partnerships and permanent establishments) and certain other groups including UK entities with annual turnover exceeding £200m or gross assets exceeding £2bn, after excluding figures for non-UK entities other than their UK permanent establishments.

Action: Each head UK entity of a relevant large business with a 31 March 2025 accounting reference date should ensure that it has published a UK tax strategy by 31 March 2025 or, if sooner, within 15 months of the publication of its previous tax strategy. The tax strategy must include all prescribed information and be published in an internet location that is accessible to the public free of charge. Penalties for failure to comply with the requirements start at £7,500.

Senior accounting officer notification and annual compliance certificate

Deadline for action: 31 March 2025

Issue: Certain large companies or members of large groups are required to identify a senior accounting officer (SAO) and notify HMRC of the SAO’s name. The SAO must provide HMRC with an annual compliance certificate. The notification and certificate must be provided to HMRC no later than the Companies House filing date for the company’s accounts. The SAO certificate must state whether or not the company had appropriate tax accounting arrangements throughout the financial period and, if not, provide appropriate details. For this purpose, large companies and large groups are those with annual turnover exceeding £200m or gross assets exceeding £2bn, after excluding figures for companies that are not incorporated in the UK.

Action: Relevant public companies with a 30 September 2024 period end and other relevant companies with a 30 June 2024 period end must notify HMRC of the identity of their SAO and the SAO must provide their certificate to HMRC by 31 March 2025. Companies are liable to a £5,000 penalty for failure to notify, and SAOs are personally liable for penalties of £5,000 for failure to maintain appropriate tax accounting arrangements and £5,000 for failure to provide an accurate certificate.

Notification of uncertain tax treatments

Deadline for action: 31 March 2025

Issue: Certain large businesses are required to notify HMRC where they have adopted an uncertain tax treatment (UTT) in corporation tax, income tax (including income tax due under PAYE) and/or VAT returns. A tax treatment is “uncertain” if it results in the recognition of an accounting provision or relies on an interpretation of tax legislation that is contrary to HMRC’s known view. It becomes reportable if it gives rise to a potential tax saving (when compared with the tax that would have been paid if a treatment that was not uncertain was adopted) of more than £5m in a return or returns for the same financial year. The requirement to notify UTTs applies to corporate groups, single companies, partnerships and limited liability partnerships (LLPs) with annual turnover exceeding £200m and/or a balance sheet total of more than £2bn, after excluding figures for non-UK entities other than for their UK permanent establishments and other activities subject to UK corporation tax. Notifications in respect of corporation tax are generally due by the relevant tax return filing deadline.

Action: Relevant companies (and partnerships/LLPs that include only companies) that draw up accounts to 31 March 2024 should ensure that, where appropriate, UTTs in respect of corporation tax are notified to HMRC by 31 March 2025. 

Country-by-country reporting – filing requirements

Deadline for action: 31 March 2025

Issue: UK companies (or other entities) that are members of multinational groups with a global turnover exceeding €750m may be required to meet certain compliance requirements under the country-by-country reporting (CbCR) regime, as follows. UK ultimate parent entities (UPEs) of relevant multinational groups must file an annual CbCR report to HMRC by the anniversary of their accounting reference date. Certain other UK entities that are members of relevant multinational groups but are not UPEs must, by the anniversary of their accounting reference date, either:

  • confirm which UK entity has met the filing obligation on their behalf and the date the report was filed;
  • notify HMRC that the CbCR report has been filed in another jurisdiction and provide the name of the reporting entity and jurisdiction in which the report has been filed; or
  • file a CbCR report to HMRC.

Action: Where relevant, UK entities with 31 March 2024 period ends should ensure that, by 31 March 2025, they either file a CbCR report or notify HMRC that another entity has done so, providing all relevant information.

Corporate interest restriction – group reporting company notification and return submission

Deadline for action: 31 March 2025

Issue: Groups of companies (including “single company groups”) with annual net UK corporate interest expenses and other financing costs exceeding £2m may be denied tax relief for such expenses under the corporate interest restriction (CIR) rules. Those impacted or potentially impacted in future periods may be required or otherwise wish to submit certain CIR filings to HMRC to manage their position.

Groups wishing to submit CIR returns must nominate a group reporting company to submit the group’s returns (for an accounting period and subsequent accounting periods) and must notify HMRC of the eligible UK group reporting company within 12 months of the end of the relevant accounting period (or the date a previous CIR group ceases to exist due to a change in ownership or restructuring). Revocations of earlier nominations must be notified to HMRC within the same timeframe. If no group company is nominated, HMRC has the power to appoint one for a single accounting period, though it will only do so in certain limited circumstances.

The appointed group reporting company must submit a full CIR return or, if the relevant conditions are met, an abbreviated CIR return on behalf of the group by the later of:

  • the anniversary of the group’s accounting reference date; or
  • where it was appointed by HMRC, three months after its appointment.

Failure to submit a CIR return may prevent groups from benefitting from various elections or taking certain other steps to mitigate the impact of the CIR on their tax position.

Action: Affected groups with an accounting period ended on 31 March 2024 should nominate an eligible UK group reporting company. That company should ensure it is authorised by at least 50% of eligible UK group companies and notify HMRC that it is the group reporting company by 31 March 2025 (or earlier if a CIR group ceases to exist earlier). Group reporting companies with a 31 March 2024 accounting reference date must generally file their CIR return by 31 March 2025. The return should include relevant elections for that period and, where relevant, subsequent periods, including: 

  • group ratio election; 
  • group ratio (blended) election;
  • group EBITDA (chargeable gains) election;
  • interest allowance (alternative calculation) election;
  • interest allowance (non-consolidated investment) election;
  • interest allowance (consolidated partnerships) election; and
  • abbreviated return election.

Corporate interest restriction – elections not in corporate interest restriction return

Deadline for action: 31 March 2025

Issue: Groups of companies (including "single company groups") subject to the corporate interest restriction (CIR) may wish to make certain elections outside the annual CIR return. The following elections may be relevant for some entities/groups within the scope of the CIR rules.

  • When calculating tax interest amounts for purposes of the CIR, companies that account for creditor relationships (receivables) on a fair value accounting basis may make an irrevocable election for these amounts to be determined on an amortised cost basis instead (an "amortised cost basis election"). The election must be made within 12 months of the end of the first relevant accounting period in which fair value accounting is applied.
  • Companies providing public infrastructure assets (this may include certain property companies) may qualify for alternative CIR rules that may give rise to reduced interest restrictions (a "public infrastructure election"). Qualifying companies wishing to elect for the alternative treatment to apply must do so by the end of the accounting period they wish the alternative treatment to apply from.
  • The CIR legislation applies standard rules to determine the relevant group accounting period end date when no group accounts are prepared. The ultimate parent company may elect for a different accounting period end date than that which would otherwise apply by the chosen date.

Action: Entities/groups wishing to benefit from elections made outside the annual CIR return should take the following actions.

  • Companies with 31 March 2024 period ends wishing to make an amortised cost basis election should do so by 31 March 2025.
  • Companies that meet the requirements and wish to make a public infrastructure election for the period ended 31 March 2025 and subsequent periods should do so by 31 March 2025.
  • Where no group accounts are prepared and a group wishes to prepare its CIR return to 31 March 2025, the ultimate parent entity should elect to do so by that date.

Corporation tax group deductions allowance

Deadline for action: 31 March 2025

Issue: Relief for corporation tax losses carried forward is generally restricted to a group’s “deductions allowance” plus 50% of its taxable profits above this allowance. The amount of the deductions allowance is £5m per corporate group per year. For group members to claim relief for losses, a group company must be nominated to allocate the deductions allowance and submit a group allowance allocation statement to HMRC.

Action: To benefit from the deductions allowance at the time tax returns are first submitted, and thereby optimise tax cash flow, groups should make a group allowance nomination, and the nominated company should submit the group allowance allocation statement on or before the date the affected tax returns are filed; ie no later than 31 March 2025 for groups with a 31 March 2024 period end. The final deadline for submitting a deductions allowance allocation statement for the period ended 31 March 2023 is 31 March 2025. Affected groups should therefore ensure a nomination is made and an allocation statement is submitted by that date, if they have not already done so, to benefit from the deductions allowance.

Research and development tax relief – advance notification form

Deadline for action: 31 March 2025

Issue: For accounting periods beginning on or after 1 April 2023, companies intending to make research and development (R&D) tax relief claims must submit an online claim notification in advance in order for their claim to be valid, unless:

  • the company has previously made a valid R&D tax relief claim during the three-year period ending on the deadline for submitting the claim notification for that period (claims for accounting periods beginning before 1 April 2023 included in amended returns made on or after 1 April 2023 are ignored for these purposes); or
  • the R&D claim relates to a corporation tax accounting period which falls within the same period of account (ie period for which financial statements are drawn up) as another corporation tax accounting period where a claim or claim notification has already been made.

Advance notification forms must be submitted within six months of the end of the period of account to which the first relevant R&D claim relates.

Action: Companies that intend to submit an R&D tax relief claim for a corporation tax accounting period ended on 30 September 2024 must submit a claim notification by 31 March 2025, unless an exception applies.

Foreign branch profits exemption election

Deadline for action: 31 March 2025

Issue: UK companies with foreign branch profits arising in territories with an effective tax rate lower than the UK rate may benefit from claiming exemption from UK corporation tax on those profits. Companies wishing to benefit must elect for exemption, which applies to all profits and losses of all foreign branches of the entity making the irrevocable election, before the start of the first accounting period for which the exemption will apply. Those with a 31 March accounting reference date must elect by 31 March 2025 for the exemption to apply from 1 April 2025.

Action: Companies with foreign branch operations should review all their overseas branch activities before the start of the first period to which exemption would apply to determine the overall impact of making a foreign branch exemption election. Where it is considered appropriate to make the election, companies should ensure the election is filed before the start of the first exempt period.

Payment of gift aid by charity subsidiaries

Deadline for action: 31 March 2025

Issue: Companies wholly owned by charities can set gift aid donations paid in the nine months following their period end against taxable profits for the period. Where a charity uses a subsidiary company to undertake non-charitable activities, such as trading, it is possible for the corporation tax that would otherwise be due on the profits to be reduced by way of a gift aid payment of those profits.

Action: Gift aid donations for the period ended 30 June 2024 must be physically paid by 31 March 2025. Subject to available reserves, the amount of gift aid may be based on what would otherwise be the company’s taxable profits in order to ensure that the payment may be optimised. However, only non-repayable payments of money, such as a cheque or bank transfer (not book entries on inter-company account), qualify. 

Diverted profits tax

Deadline for action: 31 March 2025

Issue: Companies generally have a duty to notify HMRC if they are potentially within the scope of diverted profits tax (DPT). Companies that are potentially within the scope of DPT in an accounting period must notify HMRC within three months of the period end.

Action: Those with a 31 December 2024 period end must generally notify HMRC by 31 March 2025 if they have profits arising which potentially come within the scope of DPT. Companies do not have to notify in certain circumstances, but advice should be taken to confirm the position.

Annual tax on enveloped dwellings – amended returns

Deadline for action: 31 March 2025

Issue: 2023/24 amended annual tax on enveloped dwellings (ATED) returns (where the original return was incorrect, property was disposed of, or a relief can be claimed), in respect of relevant high-value residential properties, are due by 31 March 2025.

Relevant high-value properties are those owned by certain non-natural persons with a market value in excess of £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal). The ATED liability depends on the valuation band the property falls within (again, generally based on market value as at 1 April 2022 or the date of any subsequent substantial acquisition or disposal).

Action: Non-natural persons owning high-value residential property that need to submit amended returns for 2023/24 to reflect the correct position should submit them by 31 March 2025.

Corporation tax payment due

Deadline for action: 1 April 2025

Issue: Companies with a tax liability falling outside the quarterly instalment payment regimes for large and very large companies must settle their liability to corporation tax and tax on loans or benefits to participators within nine months and one day after the period end. The increased “normal” rate of interest will apply to tax payments made after that date by companies that do fall within a quarterly instalment payment regime. Companies with a 30 June 2024 period end should settle their corporation tax liability not paid within a quarterly instalment payment regime by 1 April 2025.

Action: Companies with a 30 June 2024 period end should calculate their liability to corporation tax and tax on loans or benefits provided to participators and make full and final payment by 1 April 2025 to avoid or mitigate interest on late tax.

Corporation tax instalment payments due for large companies

Deadline for action: 14 April 2025

Issue: The dates on which corporation tax payments are due depend on whether a company is large, very large or not large for these purposes. Large companies are generally required to make four corporation tax instalment payments, six months and 13 days after the first day of their accounting period and every three months thereafter. Large companies with a 30 September 2025 accounting reference date are required to make their first corporation tax instalment payment on 14 April 2025. Second, third and fourth instalment payments are due on the same day for large companies with 30 June 2025, 31 March 2025 and 31 December 2024 period ends, respectively.

Action: Companies should consider whether or not they are subject to the corporation tax quarterly instalment payment regime for large companies and, if so, should make arrangements to calculate and pay any instalments due. Large companies are broadly companies with annual taxable profits between £1.5m and £20m. These thresholds are reduced proportionately by reference to the number of active associated companies under common control (generally as of the last day of the previous accounting period). Transitional rules apply when a company’s profits increase such that it becomes large. 

Income tax withheld on interest, royalties and certain other payments to be paid over to HMRC

Deadline for action: 14 April 2025 (or earlier)

Issue: Companies may be required to withhold income tax on interest, royalties and certain other payments, including payments to non-UK recipients. Where a withholding obligation arises, this must be reported and the relevant tax paid over to HMRC within 14 days of the end of a calendar quarter or accounting period, using form CT61.

Action: Companies should withhold income tax on relevant payments where and to the extent appropriate. They should report and pay tax withheld on such payments made between 1 January 2025 and 31 March 2025 to HMRC using form CT61 by 14 April 2025 (or earlier where an accounting period ends between 1 January 2025 and 31 March 2025).

Annual tax on enveloped dwellings – returns 

Deadline for action: 30 April 2025

Issue: 2025/26 annual tax on enveloped dwellings (ATED) returns and relief declaration returns, and 2024/25 further ATED returns (where a change in circumstances during the year increases the tax liability), in respect of relevant high-value residential properties, are generally due by 30 April 2025.

Relevant high-value properties are those owned by certain non-natural persons with a market value in excess of £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal). The ATED liability depends on the valuation band the property falls within (again generally based on market value as at 1 April 2022 or the date of any subsequent substantial acquisition or disposal).

Action: Except where a later filing date applies, non-natural persons owning high-value residential property should submit their ATED returns, further returns and/or relief declaration returns by 30 April 2025. Those with an ATED liability can apply to HMRC for a pre-return banding check (PRBC) to confirm which valuation band a property falls into, where there is “reasonable belief” the property value is within 10% of a banding threshold. Although HMRC will not confirm the specific valuation, PRBCs should be applied for well before submitting the ATED return.

Annual tax on enveloped dwellings – payment

Deadline for action: 30 April 2025

Issue: Any 2025/26 and further 2024/25 annual tax on enveloped dwellings (ATED) due must be paid by 30 April 2025, or the return filing date where a later filing date applies.

ATED arises on UK residential properties valued above £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal) that are owned by certain UK or non-UK non-natural persons, including companies, collective investment schemes and certain partnerships.

Action: Owners of affected properties should pay any ATED due by 30 April 2025. The ATED liability depends on the valuation band the property falls within. The relevant bands and liabilities are as follows:

  Range 2025/26 2024/25
£500,001 – £1m £4,450 £4,400
£1m – £2m £9,150 £9,000
£2m – £5m £31,050 £30,550
£5m – £10m £72,700 £71,500
£10m – £20m £145,950 £143,550
Over £20m £292,350 £287,500

The charge is reduced on a pro-rata basis where, for example, the property is only owned or meets one of the exemptions for part of the period.

For more information, please get in touch with James Morris.

Private client

60-day reporting for disposals of UK property

Deadline for action: Ongoing 

Issue: UK resident individuals, trustees and personal representatives are liable to report and make payments on account of capital gains tax (CGT) for chargeable gains on disposals of UK residential property. This must be done within 60 days of completion where a CGT liability arises on the disposal. Non-UK resident individuals, trustees and personal representatives must also report and make payments on account of CGT for chargeable gains on all disposals of UK land and non-residential, as well as residential, property (including substantial indirect interests in UK land through assets deriving at least 75% of their value from that land) within 60 days of completion, even if no CGT liability arises.

Action: Up-to-date records should be maintained for all in-scope property subject to potential sale. Taxpayers should take advice on their obligations early to ensure they meet the deadlines, as the reporting and payment windows are short and the calculations can be complex.

HMRC trusts register – registration

Deadline for action: Ongoing 

Issue: Trustees of most UK-connected trusts must submit a report of comprehensive trust information to HMRC within 90 days of the trust’s creation. Trustees of new UK-connected trusts must provide HMRC with details of the settlor, trustees, beneficiaries and any other person who has control over the trust, together with certain other information relating to the trust, within 90 days of the trust’s creation. 

Action: The above information must be provided online via HMRC’s trust registration service (TRS). Whilst some exclusions apply, the trust registration obligation applies to most UK express trusts. It also applies to non-UK express trusts that acquire UK land or property, or have a UK resident trustee and enter into a “business relationship” within the UK. 

HMRC trusts register – changes

Deadline for action: Ongoing

Issue: Trustees of trusts already registered through HMRC’s trust registration service (TRS) must report prescribed changes to HMRC on an ongoing basis. They must use the TRS to report changes to the lead trustee, other trustees, beneficiaries, settlor or protector of the trust.

Action: Details of any changes must be notified to HMRC through the TRS within 90 days of the change.

Mandatory disclosure rules reporting

Deadline for action: Ongoing

Issue: UK intermediaries that promote or assist in the design or implementation of certain cross-border arrangements may be required to report details of the arrangement to HMRC under the mandatory disclosure rules (MDR). In some circumstances, the reporting obligation may fall on the relevant UK taxpayer instead. A cross-border arrangement may be reportable if it circumvents the automatic exchange of information between tax authorities under the common reporting standard (CRS) or involves an opaque offshore structure that obscures the beneficial ownership of assets.

A report must be made:

  • where the reporting obligation falls on an intermediary, within 31 days of the day they make the arrangement available for implementation or supply relevant services; or
  • where the reporting obligation falls on a taxpayer, within 31 days of the day the first step in the arrangement is implemented.

Action: Intermediaries and taxpayers should ensure they have implemented appropriate procedures and processes and that reporting obligations are met on a timely basis. 

Register of overseas entities

Deadline for action: Ongoing

Issue: Relevant entities looking to acquire (or, in some cases, dispose of) UK property held freehold or on leasehold for a term exceeding seven years, or registrable charges over such property, must be entered on the Companies House register of overseas entities in order to register the property transaction with the relevant land registry. Registered relevant entities must file an annual update every year following registration. Relevant entities comprise companies and limited liability partnerships (LLPs) registered outside the UK, foreign foundations and non-UK partnerships with legal personality.

It is generally not possible for relevant overseas entities to directly acquire or dispose of UK property or hold registrable charges over such property without being registered. Failure to meet the obligation to register, where required, carries a criminal sanction for the entity and every officer of the entity who is in default. These range from fines of £2,500 per day for failing to update the register, to unlimited fines for making a materially false statement, and prison sentences.

Action: Affected entities that are not already registered should register and complete any necessary reporting on the Companies House register of overseas entities in advance of intended UK property transactions, as acquisitions and certain disposals by relevant entities cannot be registered at the relevant land registry until this has been done. Registered relevant entities must file an annual update within 14 days of the anniversary of the date they registered.

Penalties for late payment of income tax, National Insurance contributions and capital gains tax

Deadline for action: 2 March 2025

Issue: Individuals and trustees should have paid their 2023/24 tax liability by the due date of 31 January 2025. Any 2023/24 tax remaining unpaid at 2 March 2025 will be subject to a 5% penalty unless it is being collected through an individual’s tax code or a “Time to Pay” arrangement has been agreed with HMRC. No such penalty applies to the first payment on account for the 2024/25 tax year, which was due on 31 January 2025. HMRC will charge late payment interest on all liabilities outstanding from 1 February 2025.

Action: Ensure full payment of any outstanding 2023/24 tax liability is made by 2 March 2025, or that a suitable “Time to Pay” arrangement has been agreed with HMRC, to avoid tax-geared penalties.

Annual tax on enveloped dwellings – amended returns

Deadline for action: 31 March 2025

Issue: 2023/24 amended annual tax on enveloped dwellings (ATED) returns (where the original return was incorrect, property was disposed of, or a relief can be claimed), in respect of relevant high-value residential properties, are due by 31 March 2025.

Relevant high-value properties are those owned by certain non-natural persons with a market value in excess of £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal). The ATED liability depends on the valuation band the property falls within (again, generally based on market value as at 1 April 2022 for 2023/24 or the date of any subsequent substantial acquisition or disposal).

Action: Non-natural persons owning high-value residential property that need to submit amended returns to reflect the correct position should submit them by 31 March 2025.

Reclaim overpaid tax

Deadline for action: 5 April 2025

Issue: Where a person has paid an amount of income tax or capital gains tax and believes that tax is not due, they may, in some circumstances, make a claim to HMRC for repayment of that tax. Such claims must be made within four years of the end of the tax year for which the person believes tax has been overpaid.

Action: Claims relating to overpaid tax in respect of the 2020/21 tax year should be submitted by 5 April 2025.

Pre year-end tax planning

Deadline for action: 5 April 2025

Issue: Pre year-end tax planning may reduce tax liabilities for individuals and unincorporated businesses.

There are several significant changes occurring at the end of the 2024/25 tax year that may significantly alter the landscape for impacted taxpayers. These changes include the abolition of the non-domicile and furnished holiday lettings (FHL) tax regimes, as well as an increase in the rate of capital gains tax (CGT) applicable to gains qualifying for business asset disposal relief. Unincorporated businesses could also consider issues such as the timing of capital expenditure to maximise their entitlement to capital allowances and the annual investment allowance, and whether it is beneficial to incorporate before 6 April 2025.

Action: Individuals should consider fully utilising their:

  • CGT annual exemption of £3,000 for 2024/25;
  • inheritance tax annual exemption of £3,000; and
  • ISA allowances and other tax-efficient investment opportunities.

Where individuals own their business, they should consider the most beneficial timing and way of extracting profits before 6 April 2025. There are many other planning opportunities and deadlines that are relevant to the tax year-end, and professional advice should be sought to explore these where appropriate.

Pension contributions

Deadline for action: 5 April 2025

Issue: Maximise your pension contributions before the tax year-end, where appropriate to your financial position. Unused annual allowances should be utilised, where possible, prior to 6 April 2025.

Action: Reasons to make contributions by 5 April 2025, where possible, include that any annual allowance that remains unused for the year to 5 April 2022 will otherwise be lost. However, it is worth noting that the annual allowance is reduced by £1 for every £2 of adjusted income over £240,000, down to a minimum of £10,000.

Foreign capital loss election for non-domiciliaries

Deadline for action: 5 April 2025

Issue: Non-domiciled individuals who first used the remittance basis in the 2020/21 tax year should consider making an election to permit their foreign capital losses to be utilised against gains taxable in the UK. The election would apply for 2020/21 and all subsequent tax years in which the remittance basis is used and, if appropriate, must be made before 6 April 2025, even if no capital gains were made in 2020/21.

Action: Such remittance basis users should review their particular circumstances to determine if an election is appropriate and, if so, they must make it before 6 April 2025. If the time limit is missed, access to 2020/21 foreign capital losses is generally lost forever.

Taxation of UK resident non-domiciliaries

Deadline for action: 5 April 2025

Issue: Non-domiciled individuals (non-doms) not within the “deemed domicile” rules can currently opt in and out of the remittance basis charge annually, with the charge calculated according to the number of tax years of residence in the UK. Such non-doms may wish to benefit from the remittance basis of taxation for their foreign income and gains. If so, a remittance basis charge of £30,000 applies to non-doms resident in the UK for at least seven of the previous nine tax years, and £60,000 for those resident for at least 12 of the previous 14 tax years.

Action: Non-doms who wish to claim the remittance basis must do so by the fourth anniversary of the end of the relevant tax year. Claims for the remittance basis to apply for the 2020/21 tax year must therefore be made by 5 April 2025.

Taxation of new and long-term UK resident individuals

Deadline for action: 5 April 2025

Issue: From 6 April 2025, the tax regime for non-UK domiciled individuals (non-doms) is replaced with a new foreign income and gains (FIG) regime. The FIG regime allows newly UK resident individuals (those in their first four years of tax residence in the UK who were not UK resident in any of the 10 consecutive years prior to their arrival) to claim exemption from UK tax on their FIG.

The change of regime may significantly impact individuals with non-dom UK tax status, who were previously potentially not subject to tax on FIG that were not remitted to the UK, and newly resident individuals who are taxable on their worldwide income and gains unless they meet the requirements of the new FIG regime from 6 April 2025. Transitional rules govern previously untaxed FIG, including an election to apply a special tax rate to previously unremitted FIG and rebasing for capital assets held on 6 April 2017.

From 6 April 2025, domicile is less relevant for UK inheritance tax (IHT) purposes, with individuals becoming subject to UK IHT on their worldwide assets if they have been UK tax resident for at least 10 of the previous 20 tax years (long-term resident).

Action: Newly UK resident individuals and those who have previously benefitted from the UK non-dom tax regime may wish to review their financial position and their options before the 2025/26 tax year starts, including considering whether to become or remain non-UK resident.

Taxation of offshore trusts with UK resident settlors

Deadline for action: 5 April 2025

Issue: Following the abolition of the non-UK domiciled (non-dom) tax regime from 6 April 2025, if the settlor of an offshore trust is a long-term UK resident and retains a benefit in that trust, the trust’s income is taxable on them personally. Additionally, in most cases, capital gains are taxable on the settlor even if they are excluded from benefiting from the trust.

The inheritance tax (IHT) status of offshore trusts created on or after 30 October 2024 follows that of the settlor, with all assets in such trusts being subject to IHT if the settlor becomes a long-term UK resident from 6 April 2025. Foreign property held in trusts created by those with non-dom status before 30 October 2024 is not subject to IHT on the death of the settlor. However, all offshore trusts are subject to periodic IHT charges on their assets once the settlor is a long-term UK resident.

Action: Due to the significant changes from 6 April 2025, settlors and trustees of offshore trusts may wish to review the revised tax position and consider the options available to mitigate any additional potential tax liabilities before the start of the 2025/26 tax year, including considering whether the settlor may wish to become non-UK resident.

Annual tax on enveloped dwellings – returns

Deadline for action: 30 April 2025

Issue: 2025/26 annual tax on enveloped dwellings (ATED) returns and relief declaration returns, and 2024/25 further ATED returns (where a change in circumstances during the year increases the tax liability), in respect of relevant high-value residential properties, are generally due by 30 April 2025.

Relevant high-value properties are those owned by certain non-natural persons with a market value in excess of £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal). The ATED liability depends on the valuation band the property falls within (again generally based on market value as at 1 April 2022 or the date of any subsequent substantial acquisition or disposal).

Action: Except where a later filing date applies, non-natural persons owning high-value residential property should submit their ATED returns, further returns and/or relief declaration returns by 30 April 2025. Those with an ATED liability can apply to HMRC for a pre-return banding check (PRBC) to confirm which valuation band a property falls into, where there is “reasonable belief” the property value is within 10% of a banding threshold. Although HMRC will not confirm the specific valuation, PRBCs should be applied for well before submitting the ATED return.

Annual tax on enveloped dwellings – payment

Deadline for action: 30 April 2025

Issue: Any 2025/26 and further 2024/25 annual tax on enveloped dwellings (ATED) due must be paid by 30 April 2025, or the return filing date where a later filing date applies.

ATED arises on UK residential properties valued above £500,000 (generally as at 1 April 2022 or on the date of any subsequent substantial acquisition or disposal) that are owned by certain UK or non-UK non-natural persons, including companies, collective investment schemes and certain partnerships.

Action: Owners of affected properties should pay any ATED due by 30 April 2025. The ATED liability depends on the valuation band the property falls within. The relevant bands and liabilities are as follows:

  Range 2025/26 2024/25
£500,001 – £1m £4,450 £4,400
£1m – £2m £9,150 £9,000
£2m – £5m £31,050 £30,550
£5m – £10m £72,700 £71,500
£10m – £20m £145,950 £143,550
Over £20m £292,350 £287,500

The charge is reduced on a pro-rata basis where, for example, the property is only owned or meets one of the exemptions for part of the period.

For more information, please get in touch with Gary Heynes.

Employment tax

Mandatory disclosure rules reporting

Deadline for action: Ongoing

Issue: UK intermediaries that promote or assist in the design or implementation of certain cross-border arrangements may be required to report details of the arrangement to HMRC under the mandatory disclosure rules (MDR). In some circumstances, the reporting obligation may fall on the relevant UK taxpayer instead. A cross-border arrangement may be reportable if it circumvents the automatic exchange of information between tax authorities under the common reporting standard (CRS) or involves an opaque offshore structure that obscures the beneficial ownership of assets.  

A report must be made:

  • where the reporting obligation falls on an intermediary, within 31 days of the day they make the arrangement available for implementation or supply relevant services; or
  • where the reporting obligation falls on a taxpayer, within 31 days of the day the first step in the arrangement is implemented.

Action: Intermediaries and taxpayers should ensure they have implemented appropriate procedures and processes and that reporting obligations are met on a timely basis. 

Notification of uncertain tax treatments

Deadline for action: Ongoing - Last full payment submission date falling in the financial year

Issue: Certain large businesses are required to notify HMRC where they have adopted an uncertain tax treatment (UTT) in corporation tax, income tax (including income tax due under PAYE) and/or VAT returns. A tax treatment is “uncertain” if it results in the recognition of an accounting provision or relies on an interpretation of tax legislation that is contrary to HMRC’s known view. It becomes reportable if it gives rise to a potential tax saving (when compared with the tax that would have been paid if a treatment that was not uncertain was adopted) of more than £5m in a return or returns for the same financial year. The requirement to notify UTTs applies to corporate groups, single companies, partnerships and limited liability partnerships (LLPs) with annual turnover exceeding £200m and/or a balance sheet total of more than £2bn after excluding figures for non-UK entities other than for their UK permanent establishments and other activities subject to UK corporation tax. Notifications in respect of income tax due under PAYE are generally due at the same time as the last relevant return for the financial year where a UTT results from an interpretation of tax legislation that is contrary to HMRC’s known view, or at the same time as the last relevant return for the following financial year where a UTT results in the recognition of an accounting provision.

Action: Relevant businesses that draw up accounts to 31 March 2025 should ensure that, where appropriate, UTTs in respect of full payment submissions (FPSs) for income tax due under PAYE are notified to HMRC by the date of the last FPS submission falling in the financial year.

Submit paper or electronic forms P46(Car)

Deadline for action: 2 February 2025, 5 April 2025 and 3 May 2025

Issue: Details of company cars provided to employees or withdrawn without a replacement for the previous quarter should be provided to HMRC using form P46(Car). These details are usually submitted electronically. The completed online form can, however, be printed out and submitted in paper form to HMRC by the relevant date. This method cannot be used for replacement vehicles and the form should not be used if the car benefit is taxed via the payrolling of benefits process.

Action: P46(Car) forms (electronic or paper) covering the quarter to 5 January 2025 are required to be received by HMRC by 2 February 2025. P46(Car) forms covering the quarter to 5 April 2025 are required to be received by HMRC by 5 April 2025 (electronic) or 3 May 2025 (paper). 

Onshore and offshore employment intermediaries – quarterly reports

Deadline for action: 5 February 2025 and 5 May 2025

Issue: Employment intermediaries are required to make quarterly reports to HMRC where they have not operated PAYE. The quarterly reports for the quarters to 5 January 2025 and 5 April 2025 are due by 5 February 2025 and 5 May 2025, respectively. These reports require a considerable amount of information regarding all workers provided to their clients, including those operating via personal service companies (PSCs), and related payments where the intermediary, or their payroll operator, did not operate PAYE.

Action: Quarterly employment intermediary reports must be made using HMRC’s report template and submitted using HMRC’s online service. Automatic penalties arise if the report is late or incorrect. The amount of each penalty depends on the number of offences in a 12-month period, with penalties of £250 (first), £500 (second) and £1,000 (third and subsequent) applying. The penalty clock is reset once there has been a 12-month period without a late or incorrect return.

PAYE and National Insurance contributions reporting and payments

Deadline for action: Monthly – from 19 (or 22) February 2025

Issue: To avoid interest and penalties, employers should make a full payment submission (FPS) to HMRC at the time they pay their employees and pay over deducted income tax and National Insurance contributions (NICs) by the due date. Employer NICs, together with income tax and NICs deducted under PAYE, should be paid by the 19th of the following month if paid by cheque, or the 22nd if paid electronically. The FPS and, if applicable, an employer payment summary (EPS), should also be submitted by the 19th of the following month.

Action: Employers should submit their FPSs and EPSs (including, where applicable, a report of the apprenticeship levy due and allowance claimed) and pay their PAYE tax and NICs on time. Advance payment should be made where the payment date falls on a weekend. Late payments attract interest and potential penalties, and late filing gives rise to penalties of between £100 and £400 per month, depending on the number of employees. Employers that have incurred penalties have 30 days to appeal if appropriate.

Construction industry scheme reporting and payment dates

Deadline for action: Monthly – from 19 (or 22) February 2025

Issue: Written statements to subcontractors, CIS300 returns of payments made by contractors to subcontractors, and payment of the construction industry scheme (CIS) tax deducted, should be made on a monthly basis.

Action: Contractors should provide a written statement to every subcontractor from whom a deduction has been made and submit their CIS300 returns by the 19th of the following month to avoid late filing penalties. To avoid interest and late payment penalties, CIS tax deducted should be paid by the 19th of the following month if paid by cheque, or the 22nd if paid electronically. Advance payment should be made where the payment date falls on a weekend.

Check for new advisory fuel rates

Deadline for action: 1 March 2025

Issue: HMRC revises the advisory fuel rates every quarter. These rates may be used when an employer reimburses employees for fuel used for business travel in their company cars, and when an employer requires employees to repay the cost of fuel used for private travel in such vehicles.

Action: Employers should review HMRC’s advisory fuel rates each quarter to ensure that they are using the current rates. If employers reimburse such costs at different rates, they must keep records supporting the rates used.

For more information, please get in touch with Anne-Marie Welch.

Indirect taxes

VAT return filing and payment

Deadline for action: Monthly – from 7 February 2025

Issue: VAT-registered businesses and other VAT-registered organisations are generally required to file their VAT return and pay over their VAT liability on a quarterly (or else monthly) basis, one month and seven days after the end of the relevant quarter (or month).  

Action: VAT-registered businesses and other VAT-registered organisations should ensure their VAT returns are filed and payment received by HMRC no later than one month and seven days after the end of the VAT return period to avoid scope for late filing and payment penalties.

Notification of uncertain tax treatments

Deadline for action: Monthly – from 7 February 2025

Issue: Certain large businesses are required to notify HMRC where they have adopted an uncertain tax treatment (UTT) in corporation tax, income tax (including income tax due under PAYE) and/or VAT returns. A tax treatment is “uncertain” if it results in the recognition of an accounting provision or relies on an interpretation of tax legislation that is contrary to HMRC’s known view. It becomes reportable if it gives rise to a potential tax saving (when compared with the tax that would have been paid if a treatment that was not uncertain was adopted) of more than £5m in a return or returns for the same financial year. The requirement to notify UTTs applies to corporate groups, single companies, partnerships and limited liability partnerships (LLPs) with annual turnover exceeding £200m and/or a balance sheet total of more than £2bn after excluding figures for non-UK entities other than for their UK permanent establishments and other activities subject to UK corporation tax. Notifications in respect of VAT are generally due at the same time as the last relevant return for VAT periods ending within the financial year where a UTT results from an interpretation of tax legislation that is contrary to HMRC’s known view, or at the same time as the last relevant return for the following financial year where a UTT results in the recognition of an accounting provision.

Action: Relevant businesses that draw up accounts for financial years ending between 31 December 2024 and 31 March 2025 should ensure that, where appropriate, UTTs in respect of VAT are notified to HMRC by the relevant VAT return filing date. 

Plastic packaging tax return filing and payment

Deadline for action: 30 April 2025

Issue: Businesses that are subject to plastic packaging tax (PPT) are required to file their PPT return and pay over their PPT liability on a quarterly basis on the last working day of the month following the end of the relevant calendar quarter. 

Action: Businesses subject to PPT should ensure their PPT return for the calendar quarter to 31 March 2025 is filed and payment is made to HMRC no later than 30 April 2025 to avoid scope for late filing and/or late payment penalties.

For more information, please get in touch with Ian Carpenter.