ETX Tax Intelligence
Bespoke Private Client Briefing Hub
June 2026 represents a critical milestone in UK tax administration with the launch of the Advance Tax Certainty Service (ATCS) and the new SDLT conveyancer registration rules. As HMRC scales up its digital enforcement and compliance audits, business owners and private clients must navigate a rapidly evolving landscape. Proactive planning—particularly ahead of the 2027 pension taxation integration—remains the key to capital preservation and long-term security.
HMRC Launches Advance Tax Certainty Service for Major Capital Projects
What Changed
Effective 1 June 2026, HMRC opened expressions of interest for its new Advance Tax Certainty Service (ATCS), formally launching on 1 July 2026. This service offers binding, multi-tax clearance for corporate tax, VAT, SDLT, and employment taxes (PAYE/CIS) for major investment projects. The service is restricted to projects with £1 billion or more in lifetime UK qualifying capital expenditure.
Why It Matters
For large-scale developers, infrastructure builders, and ultra-high-net-worth investors undertaking massive UK capital works, this service offers unprecedented certainty, bypassing standard post-filing enquiry timelines. However, the high threshold restricts its benefits to institutional-level projects, leaving mid-market developers to rely on standard non-statutory clearance procedures.
What Most People Miss
Crucially, taxpayers miss that the £1 billion threshold is a lifetime qualifying expenditure. Projects cannot pool unrelated developments to meet the limit. Additionally, the application process requires revealing sensitive commercial projections, which HMRC may share with other compliance departments. If an application is rejected, HMRC's specialist units will have a pre-mapped blueprint of the transaction, increasing audit exposure.
ETX View
“While the ATCS offers a golden ticket to absolute tax certainty for landmark projects, the qualifying bar is exceptionally high. For clients with major capital deployments, we recommend a pre-clearance feasibility review. If you do not meet the £1 billion cap, we can still structure robust non-statutory clearance applications under existing frameworks to manage risk before capital is committed.”
HMRC Mandates Tax Adviser Registration for SDLT Conveyancers
HMRC Activity
HMRC has implemented a new compliance regime starting 18 May 2026, requiring all conveyancers and property agents who submit Stamp Duty Land Tax (SDLT) returns to register as tax advisers with HMRC. A three-month registration window is active, after which unregistered agents will be blocked from accessing HMRC portals.
Why It Matters
This is a massive compliance shift designed to clamp down on aggressive SDLT mitigation schemes and unauthorized 'boutique' planning agents. By forcing conveyancers to register, HMRC can now track and flag advisors associated with high-risk SDLT relief claims (such as mixed-use properties or multiple dwellings relief) and apply direct professional sanctions.
ETX View
“This registration drive is HMRC’s first step toward direct professional oversight of SDLT filers. We advise property purchasers to ensure their conveyancers are fully registered and qualified. For complex transactions, do not rely solely on conveyancing software defaults; involve an independent, specialized property tax advisor to review SDLT filings before submission.”
CIOT President Calls for Collaborative Policy Design Amid MTD Rollout
What Happened
At the Chartered Institute of Taxation (CIOT) AGM on 4 June 2026, newly appointed President Paul Aplin urged HMRC to adopt a policy of 'co-creation' with the tax profession for future digital changes. Reflecting on the ongoing implementation of Making Tax Digital (MTD) for Income Tax (ITSA), which targets self-employed individuals and landlords with gross income over £50,000, Aplin highlighted that early unilateral implementation by HMRC created unnecessary friction and compliance burdens.
What Most People Miss
What many miss is that the professional bodies (CIOT, ATT, ICAEW) are actively pushing back against the operational difficulties of MTD. While the software requirements are legally active, HMRC's portal remains procedurally complex. Taxpayers who struggle with digital logging must maintain paper-trail backups, as system errors during the initial rollout phase do not exempt them from failure-to-file penalties.
ETX View
“Aplin’s address highlights the widening gap between legislative intent and operational reality. We advise clients to ensure their digital record-keeping systems are robust but, crucially, to document any software discrepancies or HMRC portal issues. A well-maintained administrative audit trail remains the strongest defense if HMRC challenges filing timelines during this transition.”
Pre-Empting the April 2027 Inheritance Tax on Pension Funds
Opportunity
While the integration of unused pensions into the taxable estate for IHT does not start until 6 April 2027, the public consultation on draft regulations closed on 11 June 2026. This indicates the final rules are being locked in. High-net-worth individuals have a critical planning window before April 2027 to restructure their retirement holdings. By shifting surplus wealth out of pensions and into alternative structures, such as Family Investment Companies (FICs) or specialized trust arrangements, families can bypass the future 40% IHT hit.
Who Should Review This
- Individuals with total pension assets exceeding £500,000.
- High earners who have maxed out SIPP contributions.
- Families who planned to pass down unused SIPP balances tax-free.
- Trustees of family wealth trusts under review.
ETX View
“Do not wait until April 2027 to address your pension exposure. Restructuring takes time. If you have substantial unused pension reserves, we advise analyzing a phased drawdown strategy combined with gifting under the 'normal expenditure out of income' exemption, or establishing an FIC. This keeps your wealth growing in a low-tax corporate environment rather than exposing it to a future 40% estate levy.”
How ETX Advisory Can Help
ETX Advisory provides partner-led, technical tax advisory services designed to protect private client wealth, secure commercial continuity, and resolve complex HMRC enquiries. We work alongside our clients as trusted specialists, translating legislative shifts into practical wealth protection structures.
Inheritance Tax Planning
We structure worldwide estates, assets, and trust arrangements to safeguard wealth under the new £1 million BPR/APR caps and the 2027 pension rules.
Capital Gains Tax Planning
Advising on business exits, spousal equity transfers, and EOT structures to optimize disposal proceeds under the 18% BADR rate.
Business Succession Planning
Establishing inter-generational charters, shareholder agreements, and Family Investment Companies (FICs) to transition trading businesses securely.
Estate Planning
Drafting structured wills, utilizing agricultural reliefs, and setting up family trusts to protect generational legacies.
Corporation Tax Advice
Implementing robust compliance procedures for R&D tax credit claims and managing close company tax obligations.
HMRC Enquiries
Providing technical representation during HMRC audits, defending against Section 29 discovery assessments, and preparing tribunal appeals.
Family Wealth Planning
Aligning long-term corporate success with structured family estate protection.
Our team focuses on delivering clear, technically robust guidance, ensuring that your wealth and business assets transition securely to the next generation.
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