Guidance

Issue 132 of Agent Update

Published 19 June 2025

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This publication is available at https://www.gov.uk/government/publications/agent-update-issue-132/issue-132-of-agent-update

Technical updates and reminders

Developments and changes to legislation and allowances relating to UK tax including:

Tax

Borders and Trade

Making tax Digital

HMRC Agent Services

Agent online forum and engagement

Latest updates from the partnership between HMRC and the main agent representative bodies. Including:

Tax

New reporting requirements for cryptoasset businesses launching January 2026 

HMRC has published guidance for reporting Cryptoasset service providers under the new Cryptoasset Reporting Framework (CARF).

From January 2026, UK businesses facilitating cryptoasset exchanges must collect user and transaction data, with the first submissions to HMRC due in May 2027. The UK is introducing the Organisation for Economic Development (OECD) Cryptoasset Reporting Framework (CARF), which standardises global reporting for improved tax transparency, and extending it to include domestic reporting 

The framework requires any UK-based business that either transacts cryptoassets on behalf of users or provides a means for users to transact cryptoassets (such as bitcoin, stablecoins and non-fungible tokens (NFTs) to report user information in XML format, with penalties for non-compliance.

On this page you will find guidance on:

  • whether you’ll need to report to HMRC under CARF

  • what information you’ll need to collect about your users and transactions

  • how you’ll need to report information to HMRC

We have also published guidance for users of UK cryptoasset service providers, explaining what information they will need to provide to the service provider.

HMRC recommends providers:

  • subscribe for guidance updates

  • prepare systems before January 2026

  • review OECD CARF rules and XML specifications

Spotlight 69 — Liquidation of a Limited Liability Partnership used to avoid Capital Gains Tax

Spotlight 69 highlights a tax avoidance scheme being marketed to landlords, which enables them to transfer their property business to a company using a Limited Liability Partnership (LLP), to save Capital Gains Tax (CGT).

The schemes are typically claimed to work as follows:

  • an existing business operates for most of its active life as an unincorporated business.
  • The individual landlord incorporates an LLP.
  • the landlord transfers their rental properties, often with substantial accrued capital gains, to the LLP at market value.
  • after a short period, the LLP is put into Members’ Voluntary Liquidation (MVL).
  • the properties are then sold to a limited company owned by the landlord or connected parties (if continuing with the business).
  • for the purposes of the MVL, the LLP is seen to acquire its assets at the time of the contribution for its market value

It is claimed that this structure avoids CGT, Stamp Duty Land Tax, and has potential Inheritance Tax benefits.

You and your customers should be alert to the details contained in Spotlight 69, as it is HMRC’s view that these schemes do not work, and we will challenge anyone promoting such arrangements. People who use these arrangements may have to pay more than the tax they tried to avoid as well as paying interest, penalties and high fees for using such schemes.

If you think you or one of your customers are already involved in this arrangement and want to get out, HMRC can help. HMRC offers a range of support to get you back on track or avoid being caught out in the first place. Contact HMRC if you want to leave a tax avoidance scheme or if you have any concerns.

You can report tax fraud and tax avoidance arrangements, schemes and the person offering you them to HMRC by using our online form to report tax fraud.

Self Assessment — 2024 to 2025 Specials Document for Individuals, Partnerships and Trusts

The Self-Assessment (SA) Specials Document for Individuals, Partnerships and Trusts, which sets out whether SA customers should file a paper tax return rather than an online one, has been updated. This document is produced for software developers working with SA online services, but we know that some tax agents also find them useful when dealing with clients with complicated tax affairs.

You can read more about Self Assessment technical specifications 2025:

Written off or released directors loans

HMRC are writing to customers who, between April 2019 and April 2023:

  • have received a director’s loan that has been written off or released
  • may not have declared the amount as income on their Self Assessment tax return

The loan amount is liable to Income Tax under S415 ITTOIA05 (Income Tax Trading and Other Income).

Actions to take

Make a disclosure for your client using the digital disclosure service (DDS) Tell HMRC about underpaid tax from previous years.

If you have clients with loans that were written off or released before April 2019, you can use the DDS to make a disclosure on their behalf. 

For loans since 6 April 2023, tax returns will be within the amendment deadline window which means you can make changes to clients’ returns by following the instructions online.

PAYE fraud

HMRC is currently writing to approximately 100,000 customers after detecting unauthorised access to online tax accounts. This is equivalent to approximately 0.22% of our customers.

These incidents involved criminals using personal information they had already obtained from external sources to impersonate genuine customers and claim money fraudulently from HMRC, rather than customers themselves.

HMRC took action to protect customer data and secure affected accounts as soon as possible. No customers have experienced, or will experience, financial loss in respect of their tax affairs. We’re working with other law enforcement agencies both in the UK and overseas to bring those responsible to justice. 

The letters advise customers who are represented to show their agent a copy. We believe that this applies in a minority of cases as most customers affected by this incident are unrepresented. 

Should your clients have wider concerns, they can email our fraud team at FraudPreventionCentre@hmrc.gov.uk or call us on our online services helpdesk on 0300 200 3600 (Monday to Friday, 8am to 6pm) and select the option for ‘unauthorised access of HMRC online accounts’.

Customers can check if a letter from HMRC is genuine on GOV.UK.

Borders and Trade

ICS2 road and rail deployment window is now open for road movements

Import Control System 2 (ICS2) — the new safety and security declaration system for road, rail and maritime movements into Northern Ireland is now being introduced for movements by road, which includes RoRo movements, both unaccompanied and accompanied.

It will eventually replace the current system — Import Control System (ICS) Northern Ireland.

Road (and rail) carriers who bring goods into Northern Ireland or the EU will have until 1 September 2025 to move to ICS2, to be able to continue submitting safety and security declarations.

How ICS2 works

The ICS2 system manages:

  • lodging of pre-arrival entry summary declarations
  • notification of arrival of goods
  • presentation of goods
  • assessment of safety and security risk

What this means for your customer

 If you are an agent for traders who import goods from outside the EU into Northern Ireland or move goods into Northern Ireland from Great Britain, you will need to advise them to register to use ICS2. This will enable them to submit safety and security declarations before their goods arrive in Northern Ireland.

Your customer will also need to register if they are making a safety and security declaration for moving goods into Northern Ireland from:

  • Great Britain (England, Scotland and Wales)
  • countries outside the EU

If any of your clients are a Trader Support Service (TSS) user, they can continue to submit safety and security declarations and will not need to register for ICS2 separately.

If any of your clients has an EORI number that does not begin with XI, tell them to use the National Service Desk contact details on the CIRCABC website of the EU country (national customs authority), where their EORI number is registered. In the UK, this system is only for goods entering Northern Ireland. For goods entering Great Britain, they should use the safety and security GB service.

Preparing to register

To register for ICS2, your clients will need their:

  • EORI number
  • business contact details
  • plan for testing
  • plan for moving into ICS2 operations

As part of the setup process, they’ll need to complete the EU’s mandatory self-conformance testing before they can start operating. To do this they must access ICS2 test documents on the Digital Europe Programme’s CIRCABC website.

How to register

To register, your clients will need to follow these steps:

  1. To access the EU Shared Trader Interface (also known as the EU Customs Trader Portal), email admin.uum@hmrc.gov.uk and provide their name, email, address of their business in Northern Ireland, and EORI number starting XI.

  2. They will also need to submit a presentation of goods notification when the goods arrive in Northern Ireland, which will be done through an API, referring to the Import Control System presentation of goods service guide

After you have registered

Your clients will need to follow these steps:

  1. To start a test campaign, they should email ics.helpdesk@hmrc.gov.uk and give their EORI number, plan for testing and plan for moving into ICS2 operations.

  2. To apply for the relevant user roles to submit on the system and for testing, they should email admin.uum@hmrc.gov.uk.

They will need to tell us they want ICS2 Conformance and Prod roles, and give us the names, email, and address of business in Northern Ireland.

To start filing

Your clients will need to make a request for when they will start to use the system based on the deployment timeframes for their mode of transport.

They should email ics.helpdesk@hmrc.gov.uk if their EORI number begins with XI.

Parcels arrangements

Arrangements for parcels under the Windsor Framework took effect from 1 May 2025. Fast Parcel Operators need to submit ICS2 entry summary declarations into the EU’s Shared Trader Interface and submit presentation of goods notifications through an HMRC Application Programming Interface(API).

Read more information about safety and security requirements on GOV.UK.

Proof of Union Status Goods and the new Customs Goods Manifest (CGM) requirements

Proof of Union Status (PoUS) removes the need for further customs processes or duties when moving goods between the EU and Northern Ireland. Traders can use it when the presumption of Union status does not apply or when goods have been taken out of the EU or Northern Ireland.

Goods produced in Northern Ireland can benefit from being automatically classed as having Union status due to the unique market access benefits granted to Northern Ireland businesses under the Windsor Framework.

What are Union status goods

Union Goods are those produced in the customs territory of the EU or Northern Ireland, or imported goods that are in free circulation, such as those that have had all import duties and taxes paid.

This includes scenarios where a ship arrives from the EU, stops in Great Britain (without unloading Union goods), and then continues to Northern Ireland or another EU country where the goods are unloaded.

PoUS is necessary to confirm that the goods that left the EU or Northern Ireland are the same, unchanged goods that have arrived back in the EU or Northern Ireland. If proof cannot be provided, tax, duties, and other fees may apply.

The first stage of PoUS was introduced on 1 March 2024 and highlighted in Agent Update issue 117. This digitalised T2L and T2LFendorsements and presentation when using the EU digital portal, replacing the paper forms.

What is coming next

The second phase will introduce the Customs Goods Manifest (CGM) from 15 August 2025. This is an alternative method to the T2L for maritime only, using a shipping manifest to prove Union Status. These goods are currently indicated by C status (or similar) on the inventory system.

What does this mean for you and your client

If you currently move Union goods through the shipping manifest on behalf of your clients, this will change to the CGM on 15 August 2025.

To continue entering details of Union goods (normally indicated by ‘C’ status) directly through the inventory, without customs approval or endorsement — you or your client will need to hold authorised issuer (ACP on EU systems) status or use the services of an ACP. If neither of you hold ACP status, you will need HMRC to approve the Union status goods on the CGM through the PoUS EU system before entering the data into the inventory.

  • on presentation, Customs will again need to be notified through the PoUS system and endorse the PoUS goods
  • ACP status can be issued by any EU Member State and used across the EU for T2L or T2LF and CGM purposes

How to prepare

  • you or your client should apply for ACP as soon as possible to be ready for the change. You must be established in Northern Ireland for HMRC to process your request and hold a valid XI EORI.
  • register for access with the Uniform User Management (UUM) authentication system, which manages access to the EU system to apply for ACP

How to apply to be an authorised user

You can send an email to admin.uum@hmrc.gov.uk.

You must provide your client’s:

  • request to register for access to the EU CDMS Portal to apply for ACP
  • name and email address
  • business address
  • XI EORI number

To make a CGM endorsement request through the EU PoUS system

If neither you nor your client holds an ACP, nor uses an agent who holds this status, they should email admin.uum@hmrc.gov.uk.

They must include their:

  • request to access the EU PoUS portal to make a CGM endorsement request
  • name and email address
  • business address
  • EORI number

HMRC will then grant them access to the EU system to raise a CGM endorsement request for each movement of goods when the system goes live on 15 August 2025.

They should also be aware that an endorsement is also required for Presentation of the Goods to complete the process if they are not ACP authorised.

Upcoming learning resources

The EU will launch learning resources in July 2025, and links will be published in a future edition of the Agent Update.

For any questions on this topic, email authorisedissuer@hmrc.gov.uk.

Making Tax Digital

VAT Registration Service taxable turnover screen changes

Changes to the VAT Registration Service (VRS) went live on Monday 19 May 2025.

When completing an application on the VRS you will need to enter a breakdown of the taxable turnover by:

  • standard rate (20%)
  • reduced rate (5%)
  • zero rate (0%)

You will be shown a breakdown of the values you entered and the total taxable turnover value. You will then need to confirm if the taxable turnover values are correct or incorrect.

If they are correct, you can continue with the application.

If they are incorrect, you can amend the values. You must confirm the taxable turnover values are correct before continuing the application.

Get your clients ready for Making Tax Digital for Income Tax by signing up to our testing programme

Making Tax Digital (MTD) for Income Tax is a new way for sole traders and landlords to report their income and expenses to HMRC. This means they will be legally required to keep digital records, send quarterly updates to HMRC, and finalise their tax return using compatible software.

The qualifying income is the gross income (before expenses and tax are deducted) that sole traders and landlords receive in a tax year from self-employment and property combined.

If you have clients who are sole traders or landlords with gross income (before expenses and tax are deducted) from self-employment and property, they will be legally required to use MTD software from:

  • April 2026, if their qualifying income is £50,000 or above in the 2024 to 2025 tax year
  • April 2027, if their qualifying income is £30,000 or above in the 2025 to 2026 tax year
  • April 2028, if their qualifying income is £20,000 or above in the 2026 to 2027 tax year

Why should I sign up for the testing programme

Taking part in MTD testing means you and your clients can build your understanding of the new systems and processes early, so you’ll be more confident when you have to use it.

Once you’re registered for testing, you and your clients taking part will have exclusive access to HMRC’s dedicated Customer Support Team. The team will help you and your registered clients with any questions about the service, and other Income Tax queries.

How to sign up your clients

To take part in testing go to Sign up your client for Making Tax Digital for Income Tax.

You’ll need:

  • software that works with MTD for Income Tax
  • an agent services account
  • your client’s details and their income sources
  • your client’s permission to sign them up

How can I find out more

You can find out more information about MTD for Income Tax and what you need to do to get ready for this change in our updated Agent Toolkit and Making Tax Digital for Income Tax for agents step by step guide. 

You can also register for our next live webinar which will feature a question and answer session.

Or you can check out our recorded webinar which will help you understand the requirements of MTD for Income Tax and the practical steps you can take to:

  • plan for MTD — understand the rules and work out who will be affected and when
  • prepare for MTD — work out who will do what and make informed software choices
  • take action for MTD — update the agent services account and sign up your client
  • use MTD — follow the rules and consider how to utilise any benefits and opportunities

You can also watch our video from the MTD event on 7 April, on YouTube.

During the event, HMRC experts were joined by software developers to discuss the steps agents need to take to get ready.

HMRC Agent Services

Tax advice — do not let your clients get caught out by tax avoidance

HMRC’s don’t get caught out campaign helps people working as contractors to steer clear of bad tax advice by spotting the tell-tale signs of tax avoidance.

Any of your clients who work as contractors can find out more about tax avoidance from our:

  • online guidance, including guides and a short video on YouTube to spot the signs of tax avoidance and understand how umbrella companies work

  • interactive tools to see if their contracts involve tax avoidance or check their pay slips to make sure they are paying the right amount of tax

  • personal stories from people caught up in tax avoidance who want to share their experiences as a warning to others

Contractors who have used a tax avoidance scheme can also find the support they need to leave and report it to HMRC by visiting the don’t get caught out’ campaign page.

Details of tax avoidance schemes and their promoters that we have named are also published. This is not a complete list and remember that contrary to what some promoters tell prospective clients, HMRC never approves tax avoidance schemes.

We know that many people who become involved with tax avoidance regret it and want to get back on track. We want to help them by offering the support they need, free of any judgement, to get out and settle their tax affairs in an affordable and timely way.

We would appreciate you sharing our supportive campaign resources across your newsletters and websites. Including sharing and liking our posts on social media channels such as Facebook, LinkedIn and X (formerly Twitter).

Why submitting your client’s tax returns early makes sense

It’s been a record-breaking start to the tax year, with over 300,000 people filing their tax returns in the first week.

We are seeing a growing trend in early filing as people realise the many benefits of getting ahead.

Filing early is a smart move that benefits you and your clients — here are some good reasons: 

Reduced stress — for everyone

You and your clients will feel relieved when their tax return is completed well ahead of time, and it means you can get on with other important things.

More time to correct errors

Mistakes happen, but filing early gives you more time to correct any errors and ensure there are no consequences from getting it wrong.

Happier clients, stronger relationships

Clients will realise the benefits of filing early and your support in organising them shows you’re looking out for their best interests which will increase customer satisfaction.

Stay ahead of fraudsters

We know fraudsters target taxpayers before the January deadline, so submitting client tax returns early helps protect them from opportunistic identity thieves.

Better financial planning

Filing early does not mean paying early. It does mean your clients will know what they owe in advance which will give them more time to budget before the payment deadline on 31 January 2026.

Avoid penalties and interest

Late filing can lead to automatic penalties — filing early removes that risk.

Prepare for Making Tax Digital (MTD) for Income Tax 

MTD starts rolling out from 6 April 2026, so getting tax returns out of the way gives you more time to prepare your clients and your business for the changes to come.

Find out if you are ready to start filing. Use our Self Assessment online service for agents to submit your client’s tax returns, check their statements, view their tax liabilities and much more.

Enhancing the online complaints service for agents

In April 2024, HMRC introduced a new online complaints service for agents. The new service has made it easier for us to receive and address complaints.

Feedback highlighted two areas where the online service could be strengthened:

  • extending the 28-day time limit for accessing unsubmitted complaints
  • allowing attachments to be uploaded with complaints

In response, we have now updated the service to help you access unsubmitted complaints for up to 90 days and added the ability to upload up to 10 attachments per complaint as supporting material.

We are planning for further improvements, including a new start page that sets out the information you need to provide when making a complaint. The page will also highlight other appropriate services such as the Personal Tax Resolution Service and Agent Account Managers Service.

We value your feedback. If you have any suggestions on how we can further improve our online complaints service, complete the feedback survey that appears after you submit your complaint. 

Register and reactivate Self Assessment accounts early

To avoid delays in processing tax returns, it’s essential for your clients to be properly registered for Self Assessment (SA) or to reactivate their account if they are returning to SA.

Why it matters

Tax returns from customers who have not registered or reactivated their SA account take longer to process. This can lead to unnecessary delays and stress for both you and your clients. For example, sending a tax return without registering your client may result in an incorrect tax calculation or a repayment being issued incorrectly that we will then need to recover later.

Taking early action helps ensure tax returns are processed smoothly.

New to Self Assessment

If your client is new to SA, they must register with HMRC to receive their notice to file and Unique Taxpayer Reference (UTR).

You can register clients using our online registration forms

  • CWF1 — for clients who are self-employed
  • SA1 — for clients who are not self-employed

Returning to Self Assessment

If your client has previously been in SA and did not file a tax return last year, make sure their account is reactivated before submitting their tax return. They do not need to register again, as they already have a UTR.

To reactivate their account, use the CWF1 or SA1 online forms.

Further guidance on reactivation is available

If you cannot use the online service, the following options are available:

If you need a UTR for your client, a letter confirming it will be sent to the customer and can take up to 2 weeks to arrive.

Agent authorisation

Make sure your client has completed the 64-8 online form and your agent code is included so we can link the customer to the correct agent. Using our online service is quicker, but if you cannot use it, you can complete a paper form and post it to us.

Taking early action avoids delays and ensures you’re ready to support your clients.

If your client wants you to act on their behalf for CIS they need to make a note on the 64-8 to say this, or attach a separate letter.

Make it easy for clients — they can find more information on authorising an agent to deal with their tax affairs on GOV.UK.

Pensions for seasonal temporary staff

Employers who take on extra staff over the summer must:

  • check if these workers are eligible for automatic enrolment into a workplace pension

  • must individually assess any seasonal or temporary staff every time they pay them. This includes staff with variable hours and pay, whether they are employed for a few days or longer

Employers who fail to comply with their workplace pensions’ duties may receive a warning notice with a deadline to comply. Those who continue to fail, risk a fine.

If an employer has staff who they know will be working for them for less than three months, they can use postponement to delay assessing those employees. This pauses the duty to assess those staff until the end of the three-month postponement period.

Employers can find out more about postponement and how to enrol staff on irregular hours or incomes on the Pensions Regulator website.

Income Record Viewer

 We would like to remind all agents that HMRC’s Income Record Viewer (IRV) is the quickest and easiest way to check a client’s pay, tax, employment history, pension (private and state) and tax codes.

Using the IRV:

  • saves time and is much quicker than waiting for information to arrive in the post or calling us
  • provides the information you need all in one place
  • helps reduce errors, providing the opportunity to check any information your client gives you

Using the Income record Viewer agents can now access their client’s:

  • PAYE information for the current year plus the 4 previous tax years
  • employment records, including time in employment, their PAYE reference, the pay and tax details for each of their employment
  • student loan repayments, if any, collected through payroll
  • latest tax code for the current tax year including all allowances and deductions
  • taxable benefits provided by an employer such as company car and medical insurance and whether these are forecasted (P11D not received yet) or actual (P11D received)
  • state and private pension information
  • details of any underpaid tax and other debts such as tax credits or Class 2 National insurance contributions collected through their tax code

A client’s authorisation for an agent to access the IRV and act on their behalf is gathered quickly and securely through the digital handshake. Clients only need to authorise the agent once using the digital handshake to access the IRV.

To make it easier for clients to access the IRV we have produced a short YouTube video which explains the online authorisation process that can be shared with them. Any digitally excluded clients who cannot authorise their agent online, can contact the relevant helpline and be referred to our Extra Support Team who’ll help and guide them through the process.

Expansion of voice recognition

We’re expanding voice recognition to offer it to all individuals that use our contact centres from July 2025.

Voice recognition is currently used by 1.5 million HMRC customers who have their identity verified by technology that analyses the unique biological characteristics of their voice.

We now have the technology to offer this easy, quick and secure way for people to use their voice to confirm their identity, helping to reduce call times and increase capacity. The expansion will be introduced in phases across all personal and business tax lines between July and October 2025.

These improvements are part of HMRC’s commitment to modernise services, deliver a digital-first customer experience, transform HMRC and make services more secure, accessible, and resilient.

Agent Forum and Engagement

Taxpayers taken out of Self Assessment

Subject Matter Experts are continuing to consider the proposals provided by the Association of Taxation Technicians (ATT), to have the option to keep some taxpayers in Self Assessment when they no longer meet the criteria.

Contact Information for professional and representative bodies

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