HMRC Covid scheme amnesty: action by 31 December 2025

This quarterly civil fraud update provides a summary of reported decisions handed down in the courts of England and Wales in the period of January - March 2026.

Many people mistakenly believe that once they've established residency outside the UK, HMRC's authority over their tax affairs ceases to exist. However, HMRC retains the power to examine historical matters stretching back up to two decades in the most serious cases, and UK-situated assets remain within their jurisdiction regardless of where the owner physically resides. 

The 2026 Spring Statement, delivered on 3 March 2026, was intentionally modest in ambition and delivery. Reflecting the government’s stated preference for a single major fiscal event each year, the Spring Statement was used primarily to set out the economic context and respond to the Office for Budget Responsibility’s latest forecasts, rather than to announce wide ranging tax reform. Stability and predictability were clearly prioritised over new policy intervention.

A significant number of employment law reforms are coming into effect in 2026 and 2027 following the introduction of the Employment Rights Act 2025 at the end of last year. 

Costs in tax litigation often catch even experienced advisors off guard. Unlike other areas of civil litigation, where costs consequences are ever-present and a continuous strategic consideration, proceedings before the First-tier Tax Tribunal (Tax Chamber) (“FTT”) are often approached with less emphasis on potential costs exposure.

Privacy and confidentiality in tax cases have always been important, particularly where the taxpayer is someone in the public eye. Whilst a tax enquiry, or indeed litigation, does not mean that the taxpayer has ‘done something wrong’, there are certain negative inferences made by the public and media which could impact future opportunities for the individual or corporate involved.

One of the benefits of an appeal before the First-tier Tax Tribunal (“the Tribunal”) is that it is seen as less formal than an appeal in the Higher Courts.  However, the Court of Appeal's recent ruling in HMRC v Medpro Healthcare [2026] is a reminder in case it was needed that deadlines matter in tax disputes and securing permission for a late appeal is not guaranteed.

Section 994 of the Companies Act 2006 provides one of the most important protections available for shareholders - allowing a shareholder to apply to the court by petition for relief where “the company’s affairs are being or have been conducted in a manner that is unfairly prejudicial to the interests of members generally or of some part of its members (including at least himself),…”. These claims are often termed as “corporate divorce”.

At our recent Tech Briefing, 'What tech businesses need to know in 2026', we explored how the EU’s Digital Omnibus package and the UK’s Employment Rights Act will reshape compliance for UK tech SMEs. 

The 2026 Winter Olympic Games in Italy are in full swing, showcasing athletic excellence on the world stage. At the time of writing, British hopes remain high despite some agonisingly close finishes, with Kirsty Muir, Mia Brookes, Jen Dodds and Bruce Mouat all delivering thrilling performances that placed them just outside the medals.

2025 was a notable year for arbitration in England & Wales, marked by legislative change, technological advances, and significant judicial developments that continue to shape the arbitration landscape.

As 2026 begins, the UK is entering a period of the most substantial reform of employment rights in a generation. The Employment Rights Act 2025 (“ERA 2025”) became law in December 2025 following extensive Parliamentary debate and marks a decisive shift in the balance between employers and workers. Overall, ERA 2025 represents a material strengthening of workers’ rights in the UK, bringing employment protections closer to European standards in several key respects. 

2025 produced many interesting decisions in trust and estate disputes in the courts of England & Wales. We consider just a few of those key decisions below, which illustrate that the outcome in cases of this nature remains highly dependent on the particular facts of the case and available evidence.  

There has been a trend in recent years of seeking to use data protection claims as a means of obtaining redress for reputational harm, which would traditionally have been sought through defamation proceedings.

This quarterly civil fraud update provides a summary of reported decisions handed down in the courts of England and Wales in the period of October - December 2025.

In Rachel Reeve’s Budget on 26 November 2025, the Chancellor set out plans, among other things a to tackle fraud within the Construction Industry Scheme (“CIS”) and announced a technical consultation “aimed at simplifying and improving the administration of the scheme”.

The Chancellor has announced the terms of the financial incentive for those who report serious tax avoidance or evasion, the Strengthened Reward Scheme. Between 2023 and 2024, there is estimated to be a tax gap of £46.8 billion between the amount of tax recovered by HMRC and the amount of tax due to HMRC. With a minimum threshold of £1.5 million in unpaid tax, the scheme aims to address the tax gap by specifically targeting large-scale tax evasion by companies, wealthy individuals, and offshore or avoidance schemes.

In Rachel Reeve’s Budget on 26 November 2025, the Chancellor set out plans, among other things a to tackle fraud within the Construction Industry Scheme (“CIS”) and announced a technical consultation “aimed at simplifying and improving the administration of the scheme”.

The Court of Appeal’s judgment in the important whistleblowing cases Wicked Vision and Barton Turns highlights the need for legislative reform of the UK’s outdated and ineffective rules on workplace whistleblowing.  To quote from its final sentence: