Guidance

Issue 138 of Agent Update

Published 18 December 2025

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This publication is available at https://www.gov.uk/government/publications/agent-update-issue-138/issue-138-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 engagement

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

Tax

Guidelines for Compliance — help with Investment Zones — GfC15 

HMRC has recently published new Guidelines for Compliance — Help with Investment Zones — GfC15.

Investment Zones are areas across the UK where central and local government will work with business and local partners to create the conditions for investment and innovation.

Businesses operating in Investment Zones can access a variety of incentives, including tax advantages. These include reduced National Insurance contributions, relief from Stamp Duty Land Tax, and enhanced capital allowances for eligible investments.

These guidelines are primarily for customers who have business premises in an Investment Zone or are considering doing business within one. However, they will also be useful to Investment Zone governing bodies and professional bodies that advise clients on Investment Zones.

The guidelines provide practical support by:

  • explaining the tax reliefs available within Investment Zones
  • highlighting areas where HMRC is identifying errors
  • encouraging compliance by clarifying areas of uncertainty
  • helping customers reduce the risk of incorrectly claiming tax reliefs
  • advising on what records and evidence should be retained
  • explaining what to do if a mistake is made

Guidelines for Compliance (GfC) are part of HMRC’s ongoing commitment to publishing practical support for customers. Guidelines are designed to complement existing HMRC guidance by clarifying our position in complex, widely misunderstood, or novel areas of the tax rules.

Read more information on GfC guidelines including our other publications.

Student and postgraduate loans thresholds and rates for 2026 to 2027 

The new student loan plan type and postgraduate loan thresholds and rates have been announced by the Department for Education. The thresholds from 6 April 2026 are: 

  • Plan 1 — £26,900
  • Plan 2 — £29,385
  • Plan 4 — £33,795
  • Plan 5 — £25,000
  • postgraduate loan — £21,000

Deductions rates from 6 April 2026 for: 

  • Plan type 1, 2, 4 and 5 remain at 9% for any earnings above the respective thresholds
  • postgraduate loans remain at 6% for any earnings above the threshold

Changes to the student loan starter checklist and Expat version

We are now updating the student loan starter checklist ahead of the new tax year for 6 April 2026. This is mainly to add new student plan type 5 and to clarify options for customers with multiple loan types.

Key changes to the checklist are:

  • a new Plan type 5 checkbox added to the PDF and online version
  • employees will now only be able to select one plan type plan 1 or 2 or 4 or 5 on the online version, however they can still select postgraduate loan at the same time as plan type loans

Additional guidance has been added in the forms to support customers with multiple loans and to help employees identify their repayment loan type.

You can read how we informed agents with more details about the new student loan plan 5 in the October Agent Update.

Student loan and postgraduate loan repayment guidance for employers will be updated on 6 April 2026. 

Operational activity following the new independent review of the Loan Charge

The final report of the Independent Loan Charge Review 2025 was published at Budget 2025.

Alongside this report, the government published its response.

The government has accepted all but one of their recommendations, and in some areas has gone further. The government believes that what has been announced needs to be a decisive break with what has gone before. Legislation will be brought forward in the Finance Bill to provide for a generous new settlement offer which it hopes, maximises the opportunity for individuals to come forward and settle.

For people who have yet to settle with HMRC, a new settlement opportunity will be introduced that will substantially reduce the amount that they must pay, particularly those with the lowest liabilities (typically those on the lowest incomes). If they decide to settle, most individuals could see reductions of at least 50% in what they have to pay, to settle their loan charge liabilities. About 30% of individuals affected may, dependant on their individual circumstances, be able to settle without having to pay anything.

The new settlement opportunity is open to anyone with outstanding loan charge liabilities, including employers.

HMRC is working to deliver the new settlement opportunity quickly, so that people with loan charge liabilities can finalise them and move on. Legislation will be brought forward immediately in the Finance Bill, to be followed shortly with Treasury regulations setting out the detail. HMRC will begin contacting customers to notify them of eligibility from January 2026.

HMRC has published an update to the Loan Charge operational activity which gives further detail on the settlement opportunity and what you can do while you wait for us to review your clients’ arrangements.

Spotlight update — Disguised remuneration: tax avoidance using unfunded pension arrangements (Spotlight 58)

Spotlight 58 — guidance on disguised remuneration: tax avoidance using unfunded pension arrangements warns about tax avoidance using unfunded pensions arrangements.

This spotlight has been updated following 2 General Anti Abuse Rule (GAAR) Advisory Panel opinions on:

The GAAR Advisory Panel determined that the arrangements did not constitute a reasonable course of action to undertake or implement.

Spotlight 58 will help you understand the GAAR Advisory Panel opinions and what they mean for any clients using tax avoidance schemes involving unfunded pension arrangements.

If any of your clients are using these or similar schemes or arrangements, HMRC strongly advises them to withdraw from them and settle their tax affairs.

If any of your clients are using the tax avoidance schemes outlined in these Spotlights, you should contact HMRC before you take action to withdraw your clients from the specific scheme arrangements contained in this Spotlight.

If you are already in contact with someone in HMRC about your client’s use of an avoidance scheme, you should contact them to discuss this further.

If you do not have an HMRC contact and want to help your clients leave this or similar arrangements, you can contact HMRC to discuss getting out of an avoidance scheme.

Payrolling of Benefits in Kind — update

On 26 November 2025, HMRC published draft guidance and legislation to help customers prepare for reporting Benefits in Kind (BiKs) in real-time building on the previous April 2025 release.

This interim Benefit in Kind guidance and legislation:

  • explains what agents need to consider when advising clients on preparing their employees and payroll functions for real-time reporting from April 2027
  • includes worked examples of how the taxable values of specific BiKs can be calculated
  • provides draft legislation to aid understanding of the changes to reporting BiKs to HMRC from April 2027
  • confirms a registration service for the voluntary payrolling of employer-provided loans and accommodation, the most complex BiKs to report, will go live from November 2026

HMRC encourages agents to review the latest interim guidance and discuss with clients what they need to understand and do, to prepare for the upcoming changes, such as making a list of all BiKs they provide and usually report to HMRC using the online P11D form.

To assist software providers, HMRC sent technical documentation to software developers in November 2025, detailing planned changes to Real Time Information (RTI) required for the upcoming payrolling of Benefits in Kind. Agents should be aware of these changes when advising clients on payroll processes and compliance with HMRC’s requirements.

Final guidance will be published ahead of mandatory payrolling of BiKs coming into effect in April 2027.

HMRC encourages agents to read all updates to stay informed and help clients move smoothly to the new process.

Research and Development tax reliefs

Pre-1 April 2024 Relevant Research and Development (R&D) expenditure

HMRC has updated the Research and Development manual to remove a paragraph in relation to Pre-1 April 2024 Relevant R&D expenditure. The update to the manual reflects a legislative amendment made in Finance Act 2025.

Advance Assurance Pilot 

From Spring 2026, HMRC will pilot a targeted R&D advance assurance service for all small and medium-sized enterprises (SME) planning to claim R&D relief. The service will enable SMEs to gain clarity on key aspects of their R&D tax relief claims before submitting to HMRC.

Applicants will be able to seek assurance on one of 4 issues during the pilot.

These issues have been chosen from stakeholder feedback as the most complex or high-risk aspects of an R&D claim: 

  • whether the project meets the definition of R&D for tax purposes

  • whether overseas expenditure qualifies for relief

  • which party can claim relief for contracted-out expenditure

  • whether the company qualifies for exemption from the PAYE or National Insurance contribution cap

HMRC will set out further detail in due course.

A summary of responses to the advance clearances consultation has also been published.

Important changes to Automatic Exchange of Information (AEOI) — action required

Significant updates to the OECD Common Reporting Standard (CRS) will expand coverage to include more financial institutions and products. In addition, amendments have been made to strengthen the due diligence and reporting requirements.

HMRC has also introduced a new mandatory requirement for Reporting Financial Institutions and Trustee Documented Trusts to register for the AEOI service.

These changes may affect any financial institutions you represent.

New mandatory registration requirement

Mandatory registration has been introduced to gain a full understanding of the whole reporting population. This is a one-off rather than an annual requirement.

All Reporting Financial Institutions and Trustee Documented Trusts should register for the AEOI service by 31 December 2025, or 31 January following the calendar year in which they become a Reporting Financial Institution or Trustee Documented Trust. This includes those who have no reportable accounts.

If you represent Financial Institutions or Trustee Documented Trusts, make sure they are registered by this deadline, or as soon as possible afterwards. Late registration penalties will not apply if you have a reasonable excuse for any delay in registering. 

If you need any support with registering, or think you will be unable to meet the deadline, email us at enquiries.aeoi@hmrc.gov.uk.

Changes to the CRS from January 2026

From 1 January 2026, the following changes will be introduced as part of CRS 2.0 Compliance:

  • the CRS will include specified electronic money products, central bank digital currencies, and indirect investments in cryptoassets through derivatives and investment vehicles
  • enhanced due diligence requirements will apply
  • additional data fields must be reported
  • charities that are financial institutions may be classified as Non-Reporting Financial Institutions, provided set conditions are met

These changes first apply to the reporting period ending 31 December 2026, which will need to be reported to HMRC by 31 May 2027.

what financial institutions must do

To make sure they are ready to meet these new reporting requirements it is important that financial institutions act now to:

  • review products and accounts to see if they are in scope
  • update onboarding and due diligence processes
  • review reporting systems to ensure they can produce the new CRS 2.0 data fields

If you represent clients who will be impacted by these changes, make sure they are ready to fulfil the new requirements.

Next Steps

Read more about these changes including mandatory registration, technical guidance on CRS 2.0 and an overview of the new penalty regime in the International Exchange of Information Manual.

Transferring a business out of a company — guidance publication

HMRC has published new guidance on transferring a business out of a company. It also provides more information about disincorporation.

The guidance sets out the tax implications people should consider when a company’s business and assets are moved to its shareholders, who then operate as sole traders or a partnership.

The guidance on transferring a business out of a company covers:

  • tax considerations for the company, including Corporation Tax, PAYE and VAT
  • tax considerations for shareholders, including Income Tax, Capital Gains Tax and Stamp Duty

Borders and Trade

Import Control System 2 — act now to be ready by 31 December 2025

Import Control System 2 (ICS2) is the new IT system for submitting entry summary declarations, arrival notifications and presentation of goods notifications replacing Import Control System Northern Ireland (ICSNI) for goods entering Northern Ireland, and Import Control System 1 (ICS1) for goods entering the EU

Moving goods into Northern Ireland

After 31 December 2025, you will no longer be able to use ICSNI to submit Entry Summary Declarations for movements into Northern Ireland

So, if you have already migrated to ICS2, make sure your customers know what additional information you need from them.

If you are a Trader Support Service (TSS) user, TSS will register you for ICS2 automatically. However, if you do not use TSS, you must make sure you register now for ICS2 if you have not already migrated.

How to register

As with ICSNI, ICS2 requires an XI or EU Economic Operators Registration and Identification (EORI). You cannot use your Great Britian (GB) EORI with ICS2. Find out how to apply for an XI EORI

Register for ICS2 through:

When registering for onboarding you must provide:

  • your company name, contact email address, business address and EORI number
  • role in the ICS2 process
  • date that you expect to onboard

compliance for movements into Northern Ireland

It is a legal requirement to submit Safety and Security declarations, including Arrival and Presentation notifications for goods arriving in Northern Ireland.

Failure to submit declarations within the legal time limit (2 hours before arrival at a port in Northern Ireland) will be considered non-compliant.

Read more information on Safety and security declarations — Safety and security import requirements: entry summary declarations

moving goods into the EU

Be aware that different EU countries will start using ICS2 at different times — and in some cases, will already be using ICS2 for road and rail movements, so you may need to meet the new ICS2 requirements for some movements sooner than others.

Things to do if you are moving goods into the EU by road or rail:

A reminder of your role and responsibilities

As an intermediary, you must only submit the ENS declaration once you have been instructed by the carrier and have their agreement to do so. When you submit an ENS declaration, the legal responsibility for ensuring it has been submitted remains with the carrier. However, it is your responsibility for ensuring that the declaration is accurate and complete.

Make sure you have access to the extra ICS2 specific data to enable you to submit ENS declarations.

As a reminder, the type of information required for ICS2 includes:

You must provide the information known to you at the time of submitting the ENS, and you are entitled to base your declaration filing on data provided by the carrier, trading, or contracting parties.

In those cases where you find out that information has changed or was incorrect, you will be able to amend the declaration up to the point of arrival at the GB border, or up to 4 hours pre-arrival if the submission was made through the Trader Support Service (TSS). 

Further support

Contact HMRC directly by email nistakeholderengagementteam@hmrc.gov.uk for further queries.

Making Tax Digital

Improving the MTD experience — key changes agents should know

As we move closer to April 2026, we have taken further steps to strengthen confidence in Making Tax Digital for Income Tax by making key improvements. This comes from the announcements made at the Autumn Budget, including:

Additionally, we are removing most restrictions that previously prevented certain customers from signing up for the year 2026 to 2027. Signing up now for MTD for Income Tax is the best way for agents and customers to get ahead.

Staying ahead — MTD support and resources for agents

For guidance on how to prepare for and use MTD for Income Tax, make sure to read the MTD agent step by step guide.

Adding your existing Self Assessment authorisations to your Agent Services Account

If you currently represent Self Assessment clients, you may add these authorisations to your Agent Services Account. This will enable you to act on behalf of your client for Making Tax Digital for Income Tax purposes without requiring additional authorisation.

We have updated the screens, so you now see the Self Assessment codes connected to your Agent Services Account instead of your Government Gateway ID.

These changes have been made in response to agent feedback.

If you previously linked your Government Gateway ID, you do not need to repeat this process; we will add the Self Assessment agent code for you.

Read more about the process of adding client authorisations for MTD.

HMRC Agent Services

Help your clients steer clear of tax avoidance

If you have clients working as contractors through umbrella companies, you can share HMRC’s don’t get caught out campaign with them. This will help your clients be more informed on tax avoidance.

Our campaign provides online guides that explain how to spot tax avoidance, with interactive tools to check payslips and contracts to confirm the right amount of tax is being paid. Doing this avoids getting any unexpected tax bills later.

Personal stories of people who have been caught up in tax avoidance are available to view in a You Tube video which explains how umbrella companies work.

Support is also available to contractors who need to leave and report a tax avoidance scheme, helping them to get back on track and settle their tax affairs quickly to prevent bigger tax bills.

HMRC never approves tax avoidance schemes, no matter what some promoters claim. We publish a list of named tax avoidance schemes and their promoters. But it is important to note that this is not an exhaustive list.

Encourage your clients to use our ready to go campaign resources on tax avoidance. You can help to equip them with the knowledge they need to make informed and compliant decisions, by using our ready to go campaign resources in your newsletters, on your websites and across your social media channels, including sharing and liking our posts on Facebook, LinkedIn, and X (formerly known as twitter). 

Every share helps protect more people from bad tax advice.

Changes to HMRC sign-in screen

From 10 November 2025, customers signing into HMRC may have noticed a new sign-in screen. This new screen introduces an additional option — GOV.UK One Login, alongside the existing Government Gateway option.

Users should continue using their Government Gateway sign-in details as usual. This change is part of HMRC’s preparation for moving to GOV.UK One Login, a secure, modern sign-in system that will eventually replace Government Gateway.

Users on the HMRC sign-in screen will not be able to create a GOV.UK One Login or sign into HMRC with a GOV.UK One Login at this point, instead, they will be redirected to Government Gateway. 

Some users may already have a GOV.UK One Login credential from another government department, however, they cannot use their GOV.UK One Login to sign into HMRC services yet. They must continue to use their Government Gateway details to sign-in.

What this change mean for agents

Agents trying to access HMRC online services from 19 November 2025 will also see the new sign-in screen, this will include the GOV.UK One Login option. Agents cannot access HMRC with GOV.UK One Login at this time and should continue to sign-in through the Government Gateway and enter their details as normal (10-12-character user ID and password).

Once signed in, agents will not see any changes and can continue to act on behalf of their authorised clients. The login flow, client list and available services will look the same.

Important points to note:

  • you do not need to do anything — you can continue using your normal agent sign-in details as usual
  • users cannot create a GOV.UK One Login to access HMRC Online services yet
  • if users select GOV.UK One Login, it will redirect them back to Government Gateway for now
  • read more information on GOV.UK One Login and the sign-in options

Self Assessment — trading losses and carry back claims

If your client is self-employed or in a partnership and makes a trading loss, you may be able to make a claim to carry that loss back to the previous year, or in certain circumstances earlier years.

To make a claim for losses you need to:

  • complete all relevant boxes on the tax return
  • include details in the ‘any other information’ section
  • if you are not filing online and are using the self-employment (short) (SA103S) supplementary page, use the ‘any other information’ section of the main tax return (SA100)

Important points about carry back of losses to be aware of:

  • carrying back a loss does not change the Self Assessment or tax liability for the earlier year
  • relief is calculated as if the loss were carried back, but it is given as a credit on the client’s Self Assessment account

To make sure credit is given on a successful claim:

  • enter the relief amount (as a decrease in tax due) in Box 15 on the Tax calculation summary (SA110) page, or
  • use the ‘decrease in tax due because of an adjustment to an earlier year’ box when filing online

Read more information in:

Get ready to file Self Assessment tax returns

As we approach the end of the year, it is time to make sure you and your clients are ready to file their Self Assessment tax returns and pay their tax by 31 January 2026.

Getting ahead now gives you time to resolve any issues and helps you and your clients avoid any last-minute stress.

HMRC digital services can make your tax administration simpler and faster.

Our digital services include:

And in case you missed it, see our Self Assessment top tips for agents which also includes information on using our new Self Assessment reactivation service.

Self Assessment income thresholds

If your client’s income is over £150,000 but taxed entirely through PAYE, you do not need to file a Self Assessment (SA) tax return for the 2024 to 2025 tax year.

The income threshold for PAYE-only taxpayers has been removed. Previously, it was £100,000, then it was raised to £150,000 for the 2023 to 2024 tax year. Now it has been removed entirely for PAYE-only income.

Your client will still have to file a tax return if they:

  • have other untaxed income, such as dividends or rental income
  • need to pay the High Income Child Benefit Charge and are not using the new PAYE service
  • have capital gains, foreign income, or are a business partner
  • want to claim tax reliefs on personal pension contributions or Gift Aid donations that cannot be handled through the PAYE coding

You can check if your client needs to send a tax return by using the checker on GOV.UK.

Remember to reactivate your client’s account before submitting their tax return if they have registered before but did not submit a tax return last year. Information on how to reactivate your client’s account can be found in our top tips.

Providing feedback on HMRC Manuals

HMRC manuals contain technical guidance for HMRC staff and tax professionals. Their primary purpose is to explain HMRC’s interpretation of relevant legislation, which is the basis on which the department makes decisions.

All pages on GOV.UK contain feedback routes in the footer of each page as well as the contact GOV.UK form that allows you to tell us whether a page is useful, suggest improvements or report a problem with a page.

The HMRC Manuals Team review all items of feedback on our manuals from internal and external users.

We received 1,755 feedback comments within the last 12 months and 65% led to guidance improvements. However, the volume is still low compared to the overall usage, so help us improve the content by providing feedback, even if it is to indicate a page is useful.

Live Webinar — Foreign income and gains (FIG) regime

From 6 April 2025, the rules for non-domiciled individuals ended and were replaced by a system based on tax residence.

Qualifying new residents will get 100% tax relief on eligible foreign income and gains (FIG) during their first 4 years of being resident. This is known as the ‘FIG regime’.

Tax agents can now register for our live webinar on 13 January 2026 or 10 February 2026. A webinar recording will be posted on GOV.UK for anyone who cannot attend.

The webinar will help agents understand the main changes, including:

  • qualifying new residents
  • claims for relief and making a claim
  • time limits
  • qualifying foreign income and disqualified income
  • Foreign capital gains

Mandatory tax adviser registration: policy paper published, guidance coming soon

From May‌‌‌ 2026, all tax advisers who interact with HMRC on behalf of clients must register and meet minimum standards — an important step towards creating a fairer market for taxpayers and advisers.

Most tax advisers will already meet the minimum standards, which includes basic legal requirements such as having Anti-Money Laundering Supervision. This change will ensure that tax advisers who are not fit to act are not able to access taxpayer data and use HMRC systems.

HMRC is committed to supporting good tax advisers through strong safeguards — no tax adviser will be suspended automatically, and HMRC will always work with tax advisers who are trying to comply in a timely way even if their case is complex. For example, suspending registration will only happen after clear warnings and a fair chance to comply, including providing a reasonable excuse.

The new system will replace existing HMRC registration routes with one streamlined digital process, making registration simpler and more consistent. HMRC will continue to work with Professional Bodies and tax advisers to get the new system right.

We have published a policy paper setting out the details of this change to registration and meeting minimum standards.

In early 2026, we will publish further guidance on GOV.UK explaining who needs to register, what they will need to do, and how to get in touch if something goes wrong. This will include step-by-step instructions and support to help tax advisers prepare ahead of May 2026. All tax advisers will have at least 3 months to register from May, and most tax advisers will have longer.

new tool for finding HMRC manuals guidance

We have published a find HMRC manuals page which allows you to search across all HMRC manuals, filter by manuals or manual pages and sort the results, enabling you to see the latest page updates more easily.

We have also updated the HMRC manuals information about the tool in the GOV.UK resources for agents section of the Tax Agent’s Handbook.

Agent Engagement

September Wealthy External Forum minutes

On 11 September 2025, the Wealthy External Forum was held online, hosted by Danielle Simmons, Deputy Director (Wealthy Team). The session brought together representatives from professional bodies, key agent firms, and members of the Wealthy team to collaborate on current priorities.

Key topics discussed at the forum included:

  • updates on Capital Gains Tax Rate Changes (effective October 2024)

  • developments in Crypto

  • legal Interpretation

  • agent standards

  • an overview of HMRC’s Accelerated Response Team

The wealthy external forum minutes from the forum are now published and available.

As part of these discussions, the forum highlighted ongoing work on changes to the taxation of non-UK domiciled individuals. This initiative is overseen by a joint sub-group comprising representative bodies from HMRC’s Wealthy External Forum and the Capital Taxes Liaison Group, ensuring alignment between policy development and stakeholder engagement.

Read more information on changes to the taxation of non-uk-domiciled-individuals.

Digital Signatures

HMRC currently accepts digital signatures in limited circumstances.

The use of advanced electronic signatures has been developed. Tax advisers submitting repayment claims on behalf of taxpayers — using nominations for P87, R40 or the Marriage Allowance Tax Form, must use an advanced electronic signature when filing these forms.

HMRC recognises the benefits of digital solutions and continues to consider opportunities to improve efficiency while maintaining robust safeguards. Wet signatures will remain available for those who are digitally excluded.

If additional clarification on the use of digital signatures is needed, this can be requested using the form on the contact tab at the bottom of the GOV.UK page for the specific service. 

Income Record Viewer

Agents are strongly recommended to report technical issues using the ‘Is this page not working properly?’ link at the bottom of key HMRC online service pages.

By completing the form available at this link, your inquiry will be promptly directed to a member of our digital support team for assistance.

Using this channel is beneficial because it captures valuable technical information that helps our technical team investigate, prioritise, and resolve issues efficiently. We will keep users updated by email throughout the process and may ask for more information if necessary.

After implementing a solution, we will request the user to verify whether the issue has been resolved or to supply additional information if further analysis is necessary. This process is not unique to Income Record Viewer (IRV) and should be used for technical issues arising from other services, such as the Agent Services Account.

We were recently able to promptly identify the issue that prevented the tax code breakdown being displayed in Income Record Viewer after agents alerted us to it using the ‘is this page not working properly?’ link. This enabled us to identify the source of the problem, and a resolution implemented quickly for the majority of those impacted.

Service updates

To make sure agents receive regular service updates, they should select the option ‘add email alerts’ in their Agent Services Account (ASA). An option to select the type of updates you wish to receive is also available.

Contact Information for professional and representative bodies

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