Consultation on pre-development costs paused
At the Autumn Budget 2024, the government announced that it would consult on changes to tax relief for pre-development costs incurred in renewable energy and major infrastructure projects. The government has now said that it has paused the publication of the consultation following the decision of the Court of Appeal in Orsted West of Duddon Sands (UK) Limited & Ors v HMRC [2025] EWCA Civ 279.
In the interim, the government welcomes views on the implications of the decision (mailto:predevcosts@hmtreasury.gov.uk).
New HMRC guidance on off-payroll working rules
HMRC has published guidance on how the changes to company size thresholds from 6 April 2025 affect the application of the off-payroll working rules. For further information, see ICAEW’s article Changes to size thresholds for off payroll working.
HMRC explains new foreign income and gains regime
HMRC has published the Residence and FIG regime manual. The manual covers:
- the statutory residence test, which applies for 2013/14 onwards;
- how to determine an individual’s residence prior to 2013/14;
- the foreign income and gain (FIG) regime which applies from 6 April 2025; and
- other matters that may have to be considered when looking at an individual’s residence position.
Guidance for umbrella companies
HMRC has published guidance setting out the actions an umbrella company can take to “support compliance and best practice in the temporary labour market”. HMRC says that the guidance may also be useful to workers, recruitment agencies and others in the supply chain in choosing which umbrella companies to engage with.
HMRC has also updated its Work out pay from an umbrella company tool for the tax rates and thresholds for 2025/26.
Read more about umbrella companies
Automatic exchange of information obligations
HMRC has published a factsheet explaining the penalties HMRC may charge a financial institution for failure to comply with its automatic exchange of information obligations under the International Tax Compliance Regulations 2015, SI 2015/878).
Latest news for insolvency practitioners
HMRC has published the following insolvency practitioner bulletins:
- bulletin 4 (2025), which explains what to include in the email subject heading when contacting the individual voluntary arrangements team; and
- bulletin 5 (2025), which provides guidance on areas where the rights of insolvency practitioners to recover assets subject to excise duty, and to sell those assets, can potentially conflict with excise duty requirements.
International tax round-up
CFE Tax Advisers Europe has published its latest collection of tax top 5 developments. It includes a summary of the 2025 CFE Forum which was convened on 27 March 2025 under the theme ‘Navigating tax transformation: from compliance to competitiveness’. Topics discussed included:
- global tax reform: OECD implementation, UK initiatives and EU competitiveness;
- ECJ case law, DAC6 and EU tax law enforcement;
- transfer pricing and VAT: bridging two systems; and
- digitalisation, sustainability and professional ethics in tax.
Tax Faculty
This guidance is created by the Tax Faculty, recognised internationally as a leading authority and source of expertise on taxation. The Faculty is the voice of tax for ICAEW, responsible for all submissions to the tax authorities. Join the Faculty for expert guidance and support enabling you to provide the best advice on tax to your clients or business.