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HMRC manual changes: 10 October 2025

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This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.

Direct taxes 

Manual  Page  Comments 
Business Income Manual Updated: BIM70005 The guidance for small businesses on using the cash basis for income tax purposes has been updated to reflect the changes made from 6 April 2024 (abolishing turnover requirements and making the cash basis opt-out). The guidance in BIM70005 to BIM70100 is now stated to cover the pre-6 April 2024 period and signposts further guidance at BIM72005 to BIM72073 for 6 April 2024 onwards.
 
Capital Gains Manual Archived: CG30200+, CG72601+, CG72850P+, CG73000P+ Various paragraphs on death and personal representatives (CG30200+), land development value (CG72601+), deferred consideration on disposals of land (CG72850P+), and exchange of joint interests in land (CG73000P+) have been archived.
 
  Archived: CH200000+ Chapter CH200000 (how to do a compliance check) is under review. Various pages have been archived and HMRC directs readers to CH202025 and CH202050.
 
Company Taxation Manual Updated: CTM41305 HMRC has added to its guidance on the meaning of ‘unincorporated association’ for corporation tax purposes, which states that in HMRC’s view there is no reason why an unincorporated association should not have trading or business objects or carry on significant commercial activities.
In Conservative and Unionist Association v Burrell (1981) 55 TC 671, Lawton LJ inferred that by unincorporated association in the corporation tax context, ‘Parliament meant two or more persons bound together for one or more common purposes, not being business purposes, by mutual undertakings, each having mutual duties and obligations, in an organisation which has rules which identify in whom control of it and its funds rests and on what terms and which can be joined or left at will’ (emphasis added).
The guidance now states that HMRC considers this a ‘practical description rather than an authoritative definition’.
 
Corporate Intangibles Research and Development Manual Updated: CIRD61420 The revised guidance on radon contamination for land remediation relief (LRR) reflects revised UKHSA Action Levels. HMRC accepts the test for harm is satisfied where radon levels exceed 300 becquerels (previously 400) for workplaces. The domestic threshold (200 becquerels) remains unchanged.
 
  Updated: CIRD63215, CIRD68065 HMRC has removed text from the guidance on LRR for expenditure on preparatory activities which stated that expenditure that did not qualify for LRR because the company did not proceed to remediate the land may still be deductible in computing the company’s profits under normal rules.
 
  Updated: CIRD68065 HMRC has updated its guidance on the recovery of excessive LRR tax credits and associated penalties to refer to the Finance Act 2007, Sch 24 penalty rules which superseded the Finance Act 1998, Sch 18 rules and which uses different terminology from those rules (‘deliberate’ instead of ‘fraudulent’ and ‘careless’ instead of ‘negligent’ in the context of inaccuracies, and failure ‘to take reasonable steps to inform HMRC [of an] inaccuracy’ instead of failing to ‘remedy [an] error without unreasonable delay’).
 
National Insurance Manual Updated: NIM02025, NIM09320 HMRC has added Statutory Neonatal Care Pay, which was introduced for employees whose babies were born on or after 6 April 2025, to the list of payments treated as ‘remuneration derived from employed earner’s employment’ for the purposes of the Social Security Contributions and Benefits Act 1992, s 4.
 
PAYE Manual Updated: PAYE81015 HMRC has updated its guidance for non-UK resident individuals claiming double taxation relief from UK PAYE income tax. HMRC will not accept a claim unless the tax authority in the individual’s country of residence has certified their tax residence there. For Malaysian residents, HMRC now states that it will accept a Malaysian Certificate of Residence (CoR) with the claim form because the Malaysian Tax Authority no longer certifies the claim form itself (and provides an address for CoR applications).
 
  Updated: PAYE82008 HMRC now provides a template document for an EP Appendix 8 arrangement, which is a special PAYE arrangement for short-term business visitors. The template sets out definitions, eligibility (including non-DTA visitors up to 60 UK workdays), and operational rules on annual reporting, month-12 withholding, BIK inclusion, deadlines and termination. Employers and advisers now have a complete HMRC template to implement or review Appendix 8 terms, requiring payroll configuration for annual collection, NIC checks (disapplying the arrangement where Class 1 arises), evidence/tracking of UK workdays and robust controls to meet the 31 May filing/payment timetable and manage cancellation risk.
 
Property Income Manual Updated: PIM2205 The revised page on deductibility of rent paid on in a property business now clarifies that in the example of a landlord who part lets property but part of it is also used as their office at home then that part identifiable as being part of an office is included within allowable deductions against landlord’s property business where landlord may be carrying out computing their business profits (as opposed to rule in itself).
 
Theatre Tax Relief Manual Updated: TTR50070, TTR55040 Reminder added that, from 1 April 2024, qualifying expenditure for theatre tax relief is UK expenditure (rather than European expenditure).
 

 

Administration 

Manual  Page  Comments 
International Exchange of Information Manual Added: IEIM906000, IEIM906100, IEIM906200, IEIM906201 New chapters on ‘Reportable Jurisdictions for Previous Reportable Periods’, ‘Partner Jurisdictions and Reportable Jurisdictions’, ‘Reportable Jurisdictions for the 2024 Reportable Period’ and ‘Reportable Jurisdictions for the 2025 Reportable Period’ have been added.
 
Self-Assessment Manual Updated: SAM100060 The revised guidance now states that taxpayers must complete a tax return if receiving foreign interest even if amount is small or already taxed abroad. The guidance confirms that this requirement is not required for taxpayer whose...
 

 

Issue: 1726
Categories: News , Trackers
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