Time to act

• Mandatory disclosure rules reporting | Ongoing, within 31 days of a relevant event
• Register of overseas entities – registration and annual update | Ongoing, and annually within 14 days of the anniversary of registration
• Platform operator reporting requirement – registration, notification, reporting and due diligence election | Annually, by 31 January
• Corporation tax instalment payments due for very large companies | Generally quarterly, from two months and 13 days after the first day of the corporation tax accounting period 
• Corporation tax return filing | By the first anniversary of the end of each period of account for which financial statements are drawn up
• Corporation tax claims and elections | Generally by the first anniversary of the corporation tax return filing date or the second or fourth anniversary of the end of the relevant corporation tax accounting period
• Publication of tax strategy | By the end of each relevant period of account for which financial statements are drawn up (or within 15 months of previous publication if earlier)
• Senior accounting officer notification and annual compliance certificate | Within six or nine months of the end of each relevant period of account for which financial statements are drawn up
• Notification of uncertain tax treatments | Generally by the first anniversary of the end of each relevant period of account for which financial statements are drawn up
• Country-by-country reporting – filing requirements | By the first anniversary of the end of each relevant period of account for which financial statements are drawn up
• Corporate interest restriction – group reporting company notification and return submission | By the first anniversary of the end of each relevant period of account for which financial statements are drawn up
• Corporate interest restriction – elections not in corporate interest restriction return | Various
• Corporation tax group deductions allowance | By the first anniversary of the end of each relevant period of account for which financial statements are drawn up
• Research and development tax relief – advance notification form | Within six months of the end of the relevant period of account for which financial statements are drawn up
• Foreign branch profits exemption election | Before the start of the first corporation tax accounting period for which it is to apply
• Payment of gift aid by charity subsidiaries | Within nine months of the end of the corporation tax accounting period
• Diverted profits tax | Within three months of the end of the accounting period
• Annual tax on enveloped dwellings (ATED) – amended returns | By 31 March following the end of the relevant ATED tax year
• Corporation tax payment due | Within nine months and one day of the end of the corporation tax accounting period
• Corporation tax instalment payments due for large companies | Generally quarterly, from six months and 13 days after the first day of the corporation tax accounting period
• Income tax withheld on interest, royalties and certain other payments to be paid over to HMRC | Generally 14 days after the end of each calendar quarter, or 14 days after the end of a period of account for which financial statements are drawn up
• ATED – returns | Generally by 30 April during, or immediately following, the relevant ATED tax year
• ATED – payment | Generally by 30 April during, or immediately following, the relevant ATED tax year
  
   

Mandatory disclosure rules reporting

Deadline for action: Ongoing, within 31 days of a relevant event

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 – registration and annual update

Deadline for action: Ongoing, and annually within 14 days of the anniversary of registration

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.

Platform operator reporting requirement – registration, notification, reporting and due diligence election

Deadline for action: Annually, by 31 January

Issue: UK resident, incorporated or managed platform operators (operators of digital platforms that connect sellers to customers to supply goods or services) are required to:

• Undertake certain due diligence procedures on sellers using their platform.
• Register, notify their reporting status, and, where required, report information on reportable sellers to HMRC and provide a copy of the reported information to sellers by 31 January following the end of the first calendar year in which they meet the relevant conditions or their status changes.

Platform operators may elect to only undertake due diligence on active sellers, provided HMRC is notified of the election by 31 January following the end of the first calendar year to which it is to apply.

Certain digital platforms are excluded from the reporting requirement.

Action: Platform operators falling within the regime in a calendar year must take the following action by 31 January following the end of that calendar year:

• Register with HMRC (if not previously registered).
• Notify HMRC that they are either excluded or reporting platform operators (if no notification has been made previously or if their status has changed).
• Provide information on reportable sellers for the calendar year to HMRC and those sellers.
• Where appropriate, make a due diligence election (if no election has been made previously or if they wish to withdraw the election).

Corporation tax instalment payments due for very large companies

Deadline for action: Generally quarterly, from two months and 13 days after the first day of the corporation tax accounting period

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 tax accounting period and every three months thereafter. For example, a very large company with a 12-month period of account ending on 31 December should make payments on 14 March, 14 June, 14 September and 14 December during that period of account.

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: By the first anniversary of the end of each period of account for which financial statements are drawn up 

Issue: Companies and other entities subject to corporation tax are required to file their corporation tax return by the first anniversary of the end of the period of account 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 should ensure their corporation tax return is filed by the first anniversary of the end of the period of account to avoid late filing penalties, starting from £100.

Corporation tax claims and elections

Deadline for action: Generally by the first anniversary of the corporation tax return filing date or the second or fourth anniversary of the end of the relevant corporation tax accounting period

Issue: Companies and other entities subject to corporation tax must generally make certain claims and elections by the first anniversary of the corporation tax return filing date, or the second or fourth anniversary of the end of the relevant corporation tax accounting period. Relevant outstanding claims and elections must be submitted as follows:

• By the first anniversary of the corporation tax return filing date – 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), group relief and capital allowances; and elections for patent box treatment; 
• By the second anniversary of the end of the corporation tax accounting period – eg claims for certain loss reliefs, including loss carry-backs; and
• By the fourth anniversary of the end of the corporation tax accounting period – eg claims for double taxation relief and overpayment relief.

Action: Entities subject to corporation tax should ensure that relevant claims and elections for earlier accounting periods are made by the relevant deadline.

Publication of tax strategy

Deadline for action: By the end of each relevant period of account for which financial statements are drawn up (or within 15 months of previous publication, if earlier)

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 period of account. Large businesses are multinational groups with global annual turnover exceeding €750m, or single UK entities (UK companies, partnerships and permanent establishments) and UK groups with annual turnover exceeding £200m or gross assets exceeding £2bn. 

Action: Each head UK entity of a relevant large business should ensure that it has published a UK tax strategy by the end of the period of account 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: Within six or nine months of the end of each relevant period of account for which financial statements are drawn up

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 must notify HMRC of the identity of their SAO and the SAO must provide their certificate to HMRC within six months of the end of the period of account. Other relevant companies must notify HMRC of the identity of their SAO and the SAO must provide their certificate to HMRC within nine months of that date. 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: Generally by the first anniversary of the end of each relevant period of account for which financial statements are drawn up

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 as members) should ensure that, where appropriate, UTTs in respect of corporation tax are notified to HMRC by the first anniversary of the end of the period of account. 

Country-by-country reporting – filing requirements

Deadline for action: By the first anniversary of the end of each relevant period of account for which financial statements are drawn up

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 first anniversary of the end of the period of accounts. Certain other UK entities that are members of relevant multinational groups but are not UPEs must, by the first anniversary of the end of the period of account, 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 should ensure that, by the first anniversary of the end of the relevant period of accounts, 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: By the first anniversary of the end of each relevant period of account for which financial statements are drawn up

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 period of account (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 first anniversary of the end of each period of account for which the group prepares financial statements; 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 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 the first anniversary of the end of the group period of account to which the nomination is to apply (or earlier if a CIR group ceases to exist earlier). Group reporting companies must generally file their CIR return by the first anniversary of the end of each group period of account. The return should include relevant elections for that period and, where relevant, subsequent periods, including: 

• group ratio election;
• group ratio (blended) election;
• group earnings before interest, taxes, depreciation and amortisation (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: Various

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 by the first anniversary of the end of the first relevant corporation tax 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 first corporation tax accounting period they wish the alternative treatment to apply from.
• The CIR legislation applies standard rules to determine the relevant group period of account end date when no group accounts are prepared. The ultimate parent company may elect for a different period of account 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 wishing to make an amortised cost basis election should do so by the first anniversary of the end of the first relevant corporation tax accounting period in which fair value accounting is applied.
• Companies that meet the requirements and wish to make a public infrastructure election should do so by the end of the first relevant corporation tax accounting period.
• Where no group accounts are prepared and a group wishes to prepare its CIR return to a particular date, the ultimate parent entity should elect to do so by that date.

Corporation tax group deductions allowance

Deadline for action: By the first anniversary of the end of each relevant period of account for which financial statements are drawn up

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 corporation tax returns are filed; ie by the first anniversary of the end of the period of account. The final deadline for submitting a deductions allowance allocation statement is the second anniversary of the end of that period of account. Affected groups should therefore ensure a nomination is made and an allocation statement is submitted by the relevant 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: Within six months of the end of the relevant period of account for which financial statements are drawn up

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 that 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 must submit a claim notification within six months of the end of the relevant period of account unless an exception applies.

Foreign branch profits exemption election

Deadline for action: Before the start of the first corporation tax accounting period for which it is to apply

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 corporation tax accounting period for which the exemption will apply. 

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: Within nine months of the end of the corporation tax accounting period 

Issue: Companies wholly owned by charities can set gift aid donations paid within the nine months following the end of a corporation tax accounting period against taxable profits for that 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 a corporation tax accounting period must be physically paid within nine months of the end of that period. 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: Within three months of the end of the relevant corporation tax accounting period

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 a corporation tax accounting period must notify HMRC within three months of the period end.

Action: Those with profits arising that potentially come within the scope of DPT must notify HMRC within three months of the end of the relevant corporation tax accounting period. Companies do not have to notify in certain circumstances, but advice should be taken to confirm the position.

Annual tax on enveloped dwellings (ATED) – amended returns

Deadline for action: By 31 March following the end of the relevant ATED tax year 

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. Amended ATED returns for prior ATED tax years (where the original return was incorrect, property was disposed of, or a relief can be claimed) are due by the first anniversary of the end of the relevant ATED tax year.

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 the prior ATED tax year to reflect the correct position should submit them by 31 March.

Corporation tax payment due

Deadline for action: Annually, within nine months and one day of the end of the corporation tax accounting period

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. 

Action: Companies should calculate their liability to corporation tax and tax on loans or benefits provided to participators and make full and final payment within nine months and one day of the end of the corporation tax accounting period to avoid or mitigate interest on late tax.

Corporation tax instalment payments due for large companies

Deadline for action: Generally quarterly, from six months and 13 days after the first day of the corporation tax accounting period

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. For example, a large company with a 12-month period of account ending on 31 December should make payments on 14 July and 14 October during the period, and 14 January and 14 April following the period.

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: Generally 14 days after the end of each calendar quarter, or 14 days after the end of a period of account for which financial statements are drawn up 

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 period of account, 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 to HMRC using form CT61 within 14 days of the end of a calendar quarter or period of account.

ATED – returns 

Deadline for action: Generally by 30 April during, or immediately following, the relevant ATED tax year

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. ATED returns and relief declaration returns for the current ATED tax year are generally due by 30 April in that tax year, and further ATED returns for the immediately preceding ATED tax year (where a change in circumstances during the year increases the tax liability) are generally due by 30 April following that tax year.

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. 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.

ATED – payment

Deadline for action: Generally by 30 April during, or immediately following, the relevant ATED tax year

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. Any ATED due for the current ATED tax year, and any further ATED due for the prior tax year, must be paid by 30 April, or by the return filing date where a later filing date applies.

Action: Owners of affected properties should pay any ATED due by 30 April. The ATED liability depends on the valuation band the property falls within. 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.

• 60-day reporting for disposals of UK property | Ongoing, within 60 days of completion
• HMRC trusts register - registration | Ongoing, within 90 days of the creation of a trust
• HMRC trusts register - changes | Ongoing, within 90 days of each reportable change
• Mandatory disclosure rules reporting | Ongoing, within 31 days of a relevant event
• Register of overseas entities - registration and annual update | Ongoing, and annually within 14 days of the anniversary of registration
• HMRC trusts register – annual declaration | Annually, by 31 January 
• Self-assessment tax returns | Annually, by 31 January
• Payment of tax and national insurance contributions for individuals (including partners), trustees and executors | Annually, by 31 January
• Amendments to individual/partnership/trust and estate self-assessment tax returns | By 31 January
• Carry back of gift aid donations | Annually, by 31 January
• Loss relief claims – trading losses | By 31 January 
• Tax claims and elections | Annually, by 31 January
• Election to disapply incorporation relief | By 31 January
• Avoid penalties for late payment of income tax, national insurance contributions and capital gains tax | By 2 March (1 March in leap years)
• Annual tax on enveloped dwellings (ATED) – amended returns | By 31 March following the end of the relevant ATED tax year
• Reclaim overpaid tax | By 5 April
• Pre year-end tax planning | Annually, by 5 April
• Pension contributions | Annually, by 5 April
• Foreign capital loss election for non-domiciliaries | By 5 April
• Taxation of UK resident non-domiciliaries | By 5 April
• ATED – returns | Generally by 30 April during, or immediately following, the relevant ATED tax year
• ATED – payment | Generally by 30 April during, or immediately following, the relevant ATED tax year
• Self-assessment tax returns – avoid penalties for late filing | By 1 May
• Deadline for automatic exchange of information reporting to HMRC | Annually, by 31 May
• Second payment on account of personal taxes due | Annually, by 31 July
• Avoid penalties for late payment of personal taxes | By 31 July
• Notify chargeability to tax to HMRC | By 5 October
• Paper self-assessment tax returns | Annually, by 31 October
• Calculation of self-assessment tax liability | By 31 October
• Collection of tax liability through PAYE tax codes – paper self-assessment returns | By 31 October
• Check forms P800 issued by HMRC | Ongoing, by 30 November
• Collection of tax liability through PAYE tax codes – online self-assessment returns | 30 December

60-day reporting for disposals of UK property

Deadline for action: Ongoing, within 60 days of completion

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 report, and make payments on account of CGT for any chargeable gains on, all disposals of UK land, whether residential or non-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, within 90 days of the creation of a trust

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, within 90 days of each reportable change

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, within 31 days of a relevant event

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 – registration and annual update

Deadline for action: Ongoing, and annually within 14 days of the anniversary of registration

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.

HMRC trusts register – annual declaration

Deadline for action: Annually, by 31 January

Issue: Trustees of trusts that are liable to tax and already registered through HMRC’s trust registration service (TRS) must confirm annually that the details for the trust are up-to-date. If the trust has a liability to UK tax in a tax year, trustees must use the TRS to submit an annual declaration by 31 January following the end of the tax year, confirming all trust details to the end of the tax year are up-to-date.

Action: Trust details as at the end of each tax year must be confirmed by way of annual declaration by the following 31 January.

Self-assessment tax returns

Deadline for action: Annually, by 31 January

Issue: Self-assessment tax returns must be submitted electronically by the 31 January following the end of the tax year to which they relate to avoid an initial late filing penalty of £100.

There are very limited exceptions to the requirement for self-assessment returns to be filed electronically by 31 January, where a paper return was not filed by the previous 31 October.

Action: Taxpayers should submit their self-assessment return electronically by 31 January to avoid penalties. Where an exception to the electronic filing requirement applies, a paper return must be submitted by 31 January and should be accompanied by a reasonable excuse claim outlining why the paper return was filed after the earlier normal paper filing deadline of 31 October.

Payment of tax and national insurance contributions (NICs) for individuals (including partners), trustees and executors

Deadline for action: Annually, by 31 January

Issue: Payment of the tax and NICs due in a self-assessment tax return should be made by 31 January following the end of the tax year to which the tax return relates. The amount due is the balancing payment of income tax and NICs, any CGT liability for the year, and the first payment on account of income tax and NICs for the following tax year.

Action: Payment should be made by the due date to avoid interest and late payment penalties. In cases of financial difficulty, it is possible to contact HMRC to request a Time to Pay arrangement that allows tax payments to be made in instalments. Interest is charged on any instalments that fall after the usual payment deadline, but late payment penalties are not charged as long as the terms of the arrangement are met.

Amendments to individual/partnership/trust and estate self-assessment tax returns

Deadline for action: By 31 January

Issue: Self-assessment taxpayers generally have 12 months following the original normal final submission deadline to make any amendments to their tax return. If the return in question was issued after 31 October following the end of the tax year, the amendment window generally runs for 15 months from the date of issue.

Action: Amendments to self-assessment tax returns should generally be made, where appropriate, by the next 31 January following the normal final tax return submission deadline.

Carry back of gift aid donations

Deadline for action: Annually, by 31 January

Issue: Provided that a claim is made before submission of the previous year’s tax return, gift aid donations made in the current tax year can be treated as made in the previous tax year and thereby potentially reduce the donor’s tax liability. The aggregate donations treated as made in the previous tax year must not exceed the taxable income and gains for that year.

Action: Individuals should make a claim to backdate gift aid donations before the submission of their previous year’s tax return, which should typically be no later than 31 January following the end of that tax year. This may allow them to benefit from improved cash flow and, where their highest tax rate in the previous tax year is greater than that expected for the current tax year, provide a higher rate of tax relief.

Loss relief claims – trading losses

Deadline for action: By 31 January

Issue: The deadline for partners and traders to claim relief for trading losses against general income and gains of that same year and/or the previous year is aligned with the deadline to amend their tax return. For tax years prior to 6 April 2024, such claims are not possible where a cash basis election has been made.

Action: Taxpayers who have realised trading losses should ensure that loss relief claims are made by the deadline, where it is in their best interests to do so. If no claim for offset is made, the losses will generally be carried forward to be set against subsequent trading profits and the opportunity to receive a repayment of tax will be lost.

Tax claims and elections

Deadline for action: Annually, by 31 January

Issue: Avoid paying unnecessary tax by ensuring you have made all relevant claims and elections. Most claims and elections must be made before the deadline to amend a self-assessment tax return expires, which is generally the next 31 January following the normal final tax return submission deadline. If in doubt, a professional review should be undertaken.

Action: Taxpayers who are able to benefit from tax claims and elections should ensure that all appropriate claims and elections are made by 31 January following the normal final tax return submission deadline, or they will generally no longer be possible and unnecessary tax may be paid.

Election to disapply incorporation relief

Deadline for action: By 31 January

Issue: If you have incorporated a business and the relevant conditions are fulfilled, any capital gain arising will be automatically deferred until you dispose of the shares in the company to which the business was transferred. If this is not advantageous, you may prefer to elect that this deferral will not apply.

Such elections must generally be made before the second anniversary of 31 January following the tax year of incorporation, or, if you sold all the shares in the company before the end of the tax year following the tax year of incorporation, before the first anniversary of 31 January following the tax year of incorporation.

Action: Those wishing to elect to disapply incorporation relief should submit their claim to HMRC in writing by the relevant 31 January deadline.

Avoid penalties for late payment of income tax, national insurance contributions and capital gains tax

Deadline for action: By 2 March (1 March in leap years)

Issue: Individuals and trustees should have paid their full tax liability for each tax year by 31 January following that tax year. Any tax remaining unpaid 30 days later is 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 subsequent tax year, which falls due on the same date. HMRC will charge late payment interest from 1 February on all self-assessment tax liabilities remaining outstanding after the 31 January payment deadline.

Action: Ensure full payment of any outstanding tax liability for each tax year is made by 2 March (1 March in leap years) following the final payment deadline, or that a suitable Time to Pay arrangement has been agreed with HMRC, to avoid tax-geared penalties.

Annual tax on enveloped dwellings (ATED) – amended returns

Deadline for action: By 31 March following the end of the relevant ATED tax year

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. Amended ATED returns for prior ATED tax years (where the original return was incorrect, property was disposed of, or a relief can be claimed) are due by the first anniversary of the end of the relevant ATED tax year.

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 the prior ATED tax year to reflect the correct position should submit them by 31 March.

Reclaim overpaid tax

Deadline for action: By 5 April

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 should be submitted by 5 April four years after the end of the relevant tax year.

Pre-year-end tax planning

Deadline for action: Annually, by 5 April

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

Changes to UK tax regimes, rates and allowances usually apply from the start of a new tax year and these may significantly alter the landscape for impacted taxpayers. Notwithstanding any specific changes, individuals may also wish to ensure that they utilise relevant tax allowances for the ending tax year.

Action: Individuals should consider fully utilising their:

• CGT annual exemption of £3,000;
• 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. 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: Annually, by 5 April

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 each 6 April.

Action: Reasons to make pension contributions by 5 April, where possible, include that any annual allowance that remains unused for the tax year ended three years prior to the current tax year will otherwise be lost. However, it is worth noting that the annual allowance is reduced by £1 for every £2 of adjusted income over £260,000 (£240,000 prior to 6 April 2023), down to a minimum of £10,000 (£4,000 prior to 6 April 2023).

Foreign capital loss election for non-domiciliaries

Deadline for action: By 5 April

Issue: Individuals who were subject to the non-domiciled individuals remittance basis tax regime prior to 6 April 2025 should consider whether it is beneficial to make an election to permit their foreign capital losses to be utilised against gains taxable in the UK. Such elections must be made by the fourth anniversary of the end of the first tax year in which they used the remittance basis, even if no capital gains were made in that tax year, and would apply for that first remittance basis tax year and all subsequent tax years in which the remittance basis is used.

Action: Remittance basis users should review their particular circumstances to determine if a foreign capital loss election is appropriate and, if so, should make it by 5 April four years after the end of the first remittance basis tax year to ensure the benefit of foreign capital losses is not lost forever.

Taxation of UK resident non-domiciliaries

Deadline for action: By 5 April

Issue: Individuals who were eligible for the non-domiciled individuals (non-doms) remittance basis tax regime prior to 6 April 2025 and were not within the deemed domicile rules could 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 in relevant tax years. If so, a remittance basis charge of £30,000 applies to non-doms who were 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 must therefore be made by 5 April four years after the end of the relevant tax year.

ATED – returns

Deadline for action: Generally by 30 April during, or immediately following, the relevant ATED tax year

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. ATED returns and relief declaration returns for the current ATED tax year are generally due by 30 April in that tax year, and further ATED returns for the immediately preceding ATED tax year (where a change in circumstances during the year increases the tax liability) are generally due by 30 April following that tax year.

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. 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.

ATED – payment

Deadline for action: Generally by 30 April during, or immediately following, the relevant ATED tax year

Issue: ATED is payable in respect of high-value residential properties 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) owned by certain non-natural persons (UK or non-UK resident, including companies, collective investment schemes and certain partnerships) for tax years from 1 April to the following 31 March. Any ATED due for the current ATED tax year, and further ATED due for the prior tax year, must be paid by 30 April, or by the return filing date where a later filing date applies.

Action: Owners of affected properties should pay any ATED due by 30 April. The ATED liability depends on the valuation band the property falls within. 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.

Self-assessment tax returns – avoid penalties for late filing

Deadline for action: By 1 May

Issue: Penalties of £10 per day usually arise for any personal tax returns not submitted within three months of the relevant 31 January filing deadline. Fixed/tax-geared penalties also usually arise for certain paper returns submitted over six months after the 31 October filing deadline for such returns. The fixed/tax-geared penalty is the greater of £300 or 5% of the tax shown in the return/determination.

Action: Overdue individual, partnership, trust and estate tax returns that have not yet been lodged with HMRC should be submitted at the earliest opportunity to ensure that no further daily penalties accrue. Fixed/tax-geared penalties can be avoided if returns are filed online by 31 July following the normal filing date for the relevant tax year, instead of being submitted as paper returns. If a notice to file a return for a tax year was issued after 6 April in the following tax year, the penalty dates may vary, but it is nevertheless recommended to submit the return as soon as possible.

Automatic exchange of information reporting to HMRC

Deadline for action: Annually, by 31 May

Issue: Certain UK entities (eg trusts and personal investment companies) may be required to submit a report to HMRC under the automatic exchange of information (AEOI) legislation. Such entities may need to have registered with HMRC and, for US Foreign Account Tax Compliance Act (FATCA) reporting, with the US Internal Revenue Service (IRS).

Action: Entities should review their position annually to establish whether they have any AEOI registration and reporting obligations for the calendar year. Those that do should register with and report to HMRC (and, where relevant, register with the IRS) as applicable by 31 May following the end of the calendar year. Nil reports are not usually required.

Second payment on account of personal taxes due

Deadline for action: Annually, by 31 July

Issue: Individuals, trustees and personal representatives subject to income tax and/or Class 4 national insurance contributions (NICs) via self-assessment may be required to make a second interim payment of tax on account of their total liability for a tax year by 31 July following the end of that tax year. Payment may be needed where the amount payable by assessment in the preceding tax year exceeds £1,000 and 20% of the total tax liability for the year. This payment usually equates to half of the net tax payable for the preceding tax year.

Action: Individuals, trustees and personal representatives should identify the amount payable and arrange to pay it by 31 July following the end of the relevant tax year. Interest is normally due on late payment of tax. Individuals whose financial circumstances have been adversely impacted by economic factors in their assessable accounting period might, in certain circumstances, be expecting a reduced tax liability. Those affected should consider whether it is appropriate to apply to HMRC to reduce their payments on account before the 31 July payment becomes due.

Avoid penalties for late payment of personal taxes

Deadline for action: By 31 July

Issue: A second late payment penalty is due in respect of balancing payments that were due on 31 January following the end of a tax year but remain unpaid as at the next 1 August. The penalty is 5% of the balancing payment due as at 31 January remaining unpaid as at 31 July, but does not apply to unpaid amounts of interest on late tax, late filing penalties, or payments on account due in respect of the subsequent tax year which fell due on the same date.

Action: Any unpaid tax for a tax year should be paid by 31 July following the normal final payment date, where possible, to avoid further penalties. If there are any reasons why payment cannot be made, it will often be appropriate to discuss the situation with HMRC as, for example, the penalty is not charged where a Time to Pay arrangement is agreed before the date the penalty becomes due.

Notify chargeability to tax to HMRC

Deadline for action: By 5 October

Issue: Individuals, trustees and personal representatives that have not received a tax return (or notice to file a return) for the most recently ended tax year must notify HMRC of their chargeability to tax where appropriate. Failure to notify new sources of income (other than those dealt with under PAYE) and capital gains will result in penalties up to the amount of the tax that remains unpaid by the following 31 January. The penalty may be higher for tax reporting obligations arising from offshore matters.

Action: Individuals, trustees and personal representatives with new income sources and capital gains in a tax year that have not received a tax return (or notice to file a return) for that tax year should notify HMRC of chargeability by 5 October after the end of the relevant tax year. This will register them for self-assessment and trigger the issue of a tax return.

Paper self-assessment tax returns

Deadline for action: Annually, by 31 October

Issue: Paper self-assessment tax returns must generally be submitted by 31 October following the end of a tax year to avoid late filing penalties. In general, the only exceptions to this rule are for individuals or entities, such as partnerships that include an overseas corporate member, for whom there is no facility to file their return in electronic format. However, this deadline for paper returns may be extended where HMRC issues a tax return less than three months prior to 31 October, ie after 31 July.

Action: Individuals and partnerships choosing to submit paper self-assessment tax returns should ensure these are with HMRC by 31 October following the end of the tax year to avoid late filing penalties. If this deadline is missed, an electronic return can generally be submitted instead by the following 31 January to avoid late submission penalties.

Calculation of self-assessment tax liability

Deadline for action: By 31 October

Issue: HMRC will calculate a taxpayer’s liability to tax if their paper return is submitted by 31 October following the tax year. If paper self-assessment tax returns are not submitted by 31 October, HMRC will generally not calculate the tax due.

Action: Individuals, trustees and personal representatives wishing for HMRC to calculate the relevant tax liability/liabilities should ensure their paper self-assessment return is with HMRC by 31 October following the end of the relevant tax year.

Collection of tax liability through PAYE tax codes – paper self-assessment returns

Deadline for action: By 31 October

Issue: If an individual is employed or receives an occupational pension, HMRC can collect up to £3,000 of their unpaid tax through the PAYE system. Self-assessment balancing payments and PAYE underpayments for a tax year can be collected through adjustment to the individual’s tax code for the second subsequent tax year following the year of underpayment, provided certain conditions are met, thereby spreading collection of the amount rather than requiring payment in one sum.

Action: To enable the collection of underpaid tax through PAYE, the individual’s paper self-assessment tax return must be submitted by 31 October following the end of the relevant tax year. If an online return is submitted instead, the deadline is 30 December following the end of the tax year.

Check forms P800 issued by HMRC

Deadline for action: Ongoing, by 30 November

Issue: Where an individual is employed or receives a pension, HMRC checks whether they have paid the right amount of tax and, where it is believed the right amount has not been paid, issues form P800. The P800 contains HMRC’s calculation of the individual’s tax liability and is issued before the end of September following the tax year to which it relates.

Action: As a matter of good practice, P800 calculations should be checked when they are received as they are frequently wrong. This may be because HMRC double counts or does not include all income sources; eg self-employment income is often excluded, resulting in a repayment of tax via the P800 that then has to be paid back. If the calculations are wrong, HMRC should be contacted within 60 days, and, at the latest, by 30 November following the tax year, so that they can be revised.

Collection of tax liability through PAYE tax codes – online self-assessment returns

Deadline for action: By 30 December

Issue: If an individual is employed or receives an occupational pension, HMRC can collect up to £3,000 of their unpaid tax through the PAYE system. Self-assessment balancing payments and PAYE underpayments for a tax year can be collected through adjustment to the individual’s tax code for the second subsequent tax year following the year of underpayment, provided certain conditions are met, thereby spreading collection of the amount rather than requiring payment in one sum.

Action: To enable the collection of underpaid tax through PAYE, the individual’s online self-assessment tax return must be submitted by 30 December following the end of the relevant tax year. Where an individual has submitted a paper tax return, the deadline is 31 October following the end of the tax year.

For more information, please get in touch with Helen Relf.

• Mandatory disclosure rules reporting | Ongoing, within 31 days of a relevant event
• Notification of uncertain tax treatments | Generally by the last full payment submission date for the financial year, or the first anniversary of that date
• Submit paper or electronic forms P46(Car) | Generally quarterly, by 2 February, 3 May (or 5 April), 2 August and 2 November
• Onshore and offshore employment intermediaries – quarterly reports | Quarterly, by 5 February, 5 May, 5 August and 5 November
• PAYE and national insurance contributions reporting and payments | Monthly, by 19 (or 22) of the month following the end of each tax month
• Construction industry scheme reporting and payment dates | Monthly, by 19 (or 22) of the month following the end of each tax month
• Check for new advisory fuel rates | Quarterly, on 1 March, 1 June, 1 September and 1 December
• Provide P60 returns to employees | Annually, by 31 May 
• Short-term business visitor arrangement report (Appendix 4) | Annually, by 31 May 
• Short-term business visitor arrangement payroll (Appendix 8) | Annually, by 31 May
• Make PAYE settlement agreement to reduce administration | Annually, by 5 July 
• Online employment related securities annual returns | Annually, by 6 July 
• File P11D and P11D(b) returns and provide them to employees | Annually, by 6 July 
• Termination payments and benefits report | Annually, by 6 July 
• Class 1A national insurance contributions - payment | Annually, by 19 (or 22) July 
• PAYE settlement agreement liabilities - payment | Annually, by 19 or 22 October 

Mandatory disclosure rules reporting

Deadline for action: Ongoing, within 31 days of a relevant event

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: Generally by the last full payment submission date for the financial year, or the first anniversary of that date

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 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 their financial year.

Submit paper or electronic forms P46(Car)

Deadline for action: Generally quarterly, by 2 February, 3 May (or 5 April), 2 August and 2 November

Issue: Details of company cars provided to employees or withdrawn without a replacement for each quarter of the tax year 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 first three quarters of each tax year are required to be received by HMRC by the 2nd of the month following the quarter end (eg the quarter ended 5 January is due by 2 February). P46(Car) forms covering the quarter to 5 April are required to be received by HMRC by 5 April (if reported electronically) or 3 May (if reported by paper). 

Onshore and offshore employment intermediaries – quarterly reports

Deadline for action: Quarterly, by 5 February, 5 May, 5 August and 5 November

Issue: Employment intermediaries are required to make quarterly reports to HMRC where they have not operated PAYE. The quarterly reports for each quarter of the tax year are due by the 5th of the following month (eg the quarter ended 5 January is due by 5 February). 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, by 19 (or 22) of the month following the end of each tax month

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. Employers’ NICs, together with income tax and NICs deducted under PAYE, should be paid by the 19th of the month following the tax month in which employees are paid 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, by 19 (or 22) of the month following the end of each tax month

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 month following the tax month in which subcontractors are paid to avoid late filing penalties. In addition, to avoid interest and late payment penalties, CIS tax deducted should be paid by the 19th of the following tax 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: Quarterly, on 1 March, 1 June, 1 September and 1 December

Issue: HMRC revises its 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.

Provide P60 returns to employees

Deadline for action: Annually, by 31 May

Issue: All employers are required to provide forms P60 to all individuals who were employees as of 5 April at the end of each tax year. Failure to provide P60s by 31 May following the end of the tax year constitutes an offence, potentially resulting in penalties, determined by the Tribunal, of up to £300 per return plus up to £60 for each additional day the return remains outstanding.

Action: All employers must provide forms P60 to relevant employees by 31 May following the end of each tax year.

Short-term business visitor arrangement report (Appendix 4)

Deadline for action: Annually, by 31 May

Issue: End-of-year reports must be made when an employer or receiving entity has entered into an Appendix 4 arrangement with HMRC on the tracking and reporting of short-term business visitors to the UK. If such an arrangement has been entered into but there were no short-term business visitors in the tax year, a nil return should be made.

Action: Employers and receiving entities should prepare and submit their annual short-term business visitor arrangement report by 31 May following the end of each tax year.

Short-term business visitor arrangement payroll (Appendix 8)

Deadline for action: Annually, by 31 May

Issue: End-of-year annual payroll reports must be submitted when an employer or receiving entity has entered into an Appendix 8 arrangement with HMRC to account for the tax on qualifying short-term business visitors who cannot benefit from exemption under a double tax treaty.

Action: Employers and receiving entities should prepare and submit their annual short-term business visitor payroll reports and make any payment of tax due by 31 May following the end of each tax year.

Make PAYE settlement agreement to reduce administration

Deadline for action: Annually, by 5 July

Issue: PAYE settlement agreements (PSAs) are a convenient way to meet the tax and national insurance contributions (NICs) payable on certain expenses and benefits provided to employees. Under a PSA, employers do not need to enter the relevant items on forms P11D, operate PAYE on them, or assess them for Class 1 and/or Class 1A NICs. Payment is due by 19 October following the end of the relevant tax year if paid by cheque, or 22 October for electronic payments.

Action: Employers wishing to take advantage of a PSA for the current tax year need to agree this with HMRC by close of business on 5 July following the end of each relevant tax year. They are otherwise required to include additional entries in employee P11D returns and account for income tax and NICs under PAYE as appropriate.

Online employment related securities annual returns

Deadline for action: Annually, by 6 July

Issue: Online reporting is obligatory for employment related securities (share option schemes, one-off share awards, etc) operated by UK and overseas companies, with automatic penalties for late filing. Each plan or unapproved award needs to first be registered, then the annual return submitted online. Details of participants and awards must be provided in a specific format. Automatic penalties for late filing start at £100 per return, rising to £400 if returns are three months late and £700 if they are six months late. Daily penalties may be charged if returns are over nine months late.

Action: Employers should finalise their employment related securities annual returns in good time to meet the 6 July online filing deadline following the end of the relevant tax year.

File P11D and P11D(b) returns and provide them to employees

Deadline for action: Annually, by 6 July

Issue: The deadline for filing P11D and P11D(b) returns and providing them to employees is strictly enforced with penalties automatically generated by HMRC’s computers. Penalties for P11D(b) forms are based on employee numbers and are repeated for every month the return remains late. Late filing penalties also apply for failure to submit forms P11D.

Action: Employers should finalise their P11Ds and P11D(b)s in good time to meet the 6 July filing deadline following the end of each tax year. HMRC should also be notified of taxable termination packages exceeding £30,000, consisting of cash and non-cash benefits.

Termination payments and benefits report

Deadline for action: Annually, by 6 July

Issue: Employers are required to submit a termination payments and benefits report where they include non-cash benefits in an employee termination package. No report is required where the total value of the settlement is estimated by the employer/ex-employer not to exceed £30,000.

Action: Employers/ex-employers should prepare and submit their annual terminations and benefits report, if required, by 6 July following the end of each relevant tax year.

Class 1A national insurance contributions - payment

Deadline for action: Annually, by 19 (or 22) July

Issue: The deadline for receipt by HMRC of payment of Class 1A national insurance contributions (NICs) included on form P11D(b) is 19 July following the end of each relevant tax year for postal payments and 22 July for electronic payments. Failure to meet these deadlines will result in automatic interest on the late payment of tax, and penalties starting at 5% of the NICs due when payment is 30 days late, increasing to 10% after six months and 15% after 12 months.

Action: Employers should identify the amount payable and arrange to make payment, to be with HMRC by the due date to avoid interest on late tax and penalties.

PAYE settlement agreement liabilities - payment

Deadline for action: Annually, by 19 or 22 October

Issue: Income tax and Class 1B national insurance contributions (NICs) are due on benefits in kind included in a PAYE settlement agreement (PSA). Cheques sent by post must arrive at HMRC’s Accounts Office by 19 October following the end of each relevant tax year to avoid penalties. The deadline is extended to 22 October for electronic payments.

Action: Employers that entered into a PSA should make payment by 19 October (22 October for electronic payments) following the end of the tax year based on the figures shown on the PSA1 calculation form.

For more information, please get in touch with Martin Cooper.

• VAT return filing and payment | Quarterly or monthly, within one month and seven days of the end of each VAT return period
• Notification of uncertain tax treatments | Annually, generally within one month and seven days of the end of the final VAT return period in the financial year, or the anniversary of that date
• Plastic packaging tax return filing and payment | Quarterly, by the last working day of the month following the end of each relevant calendar quarter
• Platform operator reporting requirement - registration, notification, reporting and due diligence election | Annually, by 31 January
• VAT road fuel scale charge changes | Annually, on 1 May
• Recovery of UK VAT by overseas businesses | Annually, by 31 December following the end of the claim year from 1 July to 30 June
• Recovery of EU VAT by UK businesses | Annually, by 31 December following the end of the claim year from 1 July to 30 June

VAT return filing and payment

Deadline for action: Quarterly or monthly, within one month and seven days of the end of each VAT return period

Issue: VAT-registered businesses and other VAT-registered organisations are generally required to file their VAT returns 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: Annually, generally within one month and seven days of the end of the final VAT return period in the financial year, or the anniversary of that date

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 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: Quarterly, by the last working day of the month following the end of each relevant calendar quarter

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 each relevant calendar quarter. 

Action: To avoid scope for late filing and/or late payment penalties, businesses subject to PPT should ensure their PPT return for each relevant calendar quarter is filed and payment is made to HMRC no later than the last working day of the month following the end of that quarter.

Platform operator reporting requirement - registration, notification, reporting and due diligence election

Deadline for action: Annually, by 31 January

Issue: UK resident, incorporated or managed platform operators (operators of digital platforms that connect sellers to customers to supply goods or services) are required to:

• Undertake certain due diligence procedures on sellers using their platform.
• Register, notify their reporting status, and, where required, report information on reportable sellers to HMRC and provide a copy of the reported information to sellers by 31 January following the end of the first calendar year in which they meet the relevant conditions or their status changes.

Platform operators may elect to only undertake due diligence on active sellers, provided HMRC is notified of the election by 31 January following the end of the first calendar year to which it is to apply.

Certain digital platforms are excluded from the reporting requirement.

Action: Platform operators falling within the regime in a calendar year must take the following action by 31 January:

• Register with HMRC (if not previously registered).
• Notify HMRC that they are either excluded or reporting platform operators (if no notification has been made previously or if their status has changed).
• Provide information on reportable sellers for the calendar year to HMRC and those sellers.
• Where appropriate, make a due diligence election (if no election has been made previously or if they wish to withdraw the election).

VAT road fuel scale charge changes

Deadline for action: Annually, on 1 May

Issue: New VAT fuel scale charges are updated annually on 1 May and apply to private use fuel provided by businesses from the start of the next prescribed VAT accounting period beginning on or after 1 May. By using the VAT fuel scale charge, a business can recover all the VAT charged on road fuel without having to split mileage between employees’ business and private use.

Action: Businesses must use the new scale charges from the start of the next prescribed VAT accounting period beginning on or after 1 May each year. The updated valuation tables and accompanying notes, which set out the new scale charges and the VAT applicable thereon on an annual, quarterly, and monthly basis, are typically published by HMRC in late April.

Recovery of UK VAT by overseas businesses

Deadline for action: Annually, by 31 December following the end of the claim year from 1 July to 30 June

Issue: Entities registered for business purposes in a country outside the UK that are not registered for VAT in the UK (nor liable or eligible to be registered for VAT in the UK) may seek to recover UK VAT incurred on goods and services bought in the UK. Claims for recovery of such UK VAT must be made by 31 December following the claim year ended 30 June.

Action: UK VAT recovery claims for the period between 1 July and 30 June (the claim year) must be made electronically or by post by 31 December following the end of the claim year, using form VAT 65A, providing original invoices and a certificate of status from the official authority in the claimant’s own country to show that it is registered for business purposes there.

Recovery of EU VAT by UK businesses

Deadline for action: Annually, by 31 December following the end of the claim year from 1 July to 30 June

Issue: UK (and other non-EU) entities registered for business purposes in a country outside the EU that are not registered for VAT (nor liable or eligible to be registered for VAT) in an EU member state may seek to recover VAT incurred on goods and services bought in the EU. Claims for recovery of such VAT should be made to the EU member state in question no later than 31 December following the claim year ended 30 June.

Action: EU VAT recovery claims for the period between 1 July and 30 June (the claim year) must be made according to rules set out by the EU member state in which the VAT was incurred by 31 December following the end of the claim year. Most, if not all, such EU member states require claims to be accompanied by original invoices and a certificate of status from HMRC (or equivalent tax authority) to show that the claimant is registered for business purposes in the UK (or other non-EU country) - see this EU VAT refunds portal, which links to information provided by each member state on how to make a claim in their territory.

For more information, please get in touch with Rowena Clifton.