HMRC Publishes IHT-on-Pensions Technical Note Ahead of April 2027
HMRC released its long-awaited Inheritance Tax on Pensions Technical Note on 11 May. From 6 April 2027, most unused pension funds and pension death benefits sit inside the deceased's estate for IHT. Death-in-service lump sums and charity lump sum benefits are the two clean carve-outs. Discretionary scheme rules no longer take a pot outside the estate.
The deceased's personal representatives bear primary responsibility for reporting and paying IHT on pension death benefits. The note introduces a withholding notice: a PR can direct a scheme administrator to hold back up to 50% of any death benefit for up to 15 months while the IHT position is finalised — the mechanism stops a family inheriting a tax bill they cannot fund.
Source: GOV.UK — Inheritance Tax on Pensions: Technical Note | Related: The IHT Pension Raid: What Changes in April 2027
Scottish Election: SNP Returns for a Fifth Term, No New Income Tax Bands Promised
The Scottish Parliament election on 7 May returned the SNP as the largest party with 57 seats — short of a majority but the fifth consecutive win. Labour and Reform UK tied on 17 seats each. The SNP manifesto promised no new income tax bands or rate increases for the lifetime of this parliament, which sets the base case for Scottish income tax through to 2031.
Scottish divergence with rUK is now structural: 6 bands against 3, and a Scottish taxpayer pays more than an rUK equivalent above £30,318. 26.3% of Scottish taxpayers sit at higher rate or above. The election holds that picture in place for at least the next year.
Source: SPICe — General Election 2026: The Results Are In | Related: Scottish Budget 2026/27: The "Fiscal Drag" Reality
PGMOL Wins £584,000 Tribunal — Referees Self-Employed, IR35 Implications
The First-tier Tribunal ruled on 1 May that football referees engaged by Professional Game Match Officials Limited were self-employed, denying HMRC the £584,000 in PAYE and NIC it had been chasing since 2018. The case went through every appeal stage to the Supreme Court and back. Judge Williams accepted that there was an "irreducible minimum" of mutuality but characterised the obligations as "narrow, short-lived and suffused with choice".
FTT decisions are not binding precedent, but this is the first ruling to apply the Supreme Court's clarified employment-status test to a real factual matrix. For contractors operating outside IR35, the framing — that regulatory or developmental control carries little weight on its own — is persuasive in any engager's favour.
Source: Lewis Silkin — Football referees are not employees: HMRC loses latest bout against PGMOL | Related: Sole Trader vs Limited Company
HMRC Opens One-to-Many BADR Campaign as the Rate Rises to 18%
ICAEW's 12 May tax news flagged a fresh HMRC one-to-many campaign on Business Asset Disposal Relief claims. The campaign targets disposals where HMRC's data suggests the trading or ownership conditions may not be satisfied — typically holdings under 5%, sub-2-year ownership, or post-cessation gaps that exceed the three-year window. Recipients are asked to review and either amend or confirm their position.
The timing is sharp. The BADR rate stepped up to 18% on disposals on or after 6 April 2026, from 14% in 2025/26 and 10% before that. The £1,000,000 lifetime limit is unchanged. If you sold a business or shares in 2024/25 or 2025/26 and the conditions are tight, expect a letter — and take advice before responding.
Source: ICAEW — Tax news in brief, 12 May 2026 | Related: Capital Gains Tax on Shares
Key Dates
18 May 2026 — Mandatory tax adviser registration opens. Existing SA/CT-only agents have until 18 August; payroll-only providers until 18 November.
20 May 2026 — ONS publishes April CPI inflation. The Bank had pencilled in 3% to 3.5% through Q2; an upside surprise would harden the hawkish dissent at the last MPC.
21 May 2026 — UK CBAM consultation closes. Draft secondary legislation for the Carbon Border Adjustment Mechanism, due to start 1 January 2027.
31 May 2026 — P60 deadline for 2025/26. Also the final day to use HMRC's online service to retrieve your overlap relief figure.
18 June 2026 (Thursday) — Next Bank of England MPC decision. Bank Rate currently 3.75%.
6 July 2026 — P11D deadline for 2025/26 benefits-in-kind, for employers not signed up to payroll BIKs.