Author: Glenn

Fit and proper test fee to jump from £150 to £700 under HMRC’s proposed AML supervision changes

Many businesses are monitored by the Financial Conduct Authority (FCA) or certain professional bodies for Anti-Money Laundering (AML) purposes. However, HMRC is responsible for supervising more than 36,000 businesses in 9 business sectors. There are registration and annual fees that are charged for anti-money laundering supervision by HMRC. These fees have remained the same since May 2019, and HMRC is currently looking to increase the fees that they charge within the current fee structure to meet the costs of providing effective AML supervision.

HMRC plans to increase the premises fee from £300 to £400, representing a 33% increase since 2019. The reduced rate for small businesses will also increase from £180 to £200. Most affected businesses operate from a single premises.

The approvals fee, which ensures responsible individuals (BOOMs) are suitable for their roles, will remain unchanged at £40. However, the fit and proper (F&P) test fee, which applies to MSBs and TCSPs due to their higher risk profiles, will significantly rise from £150 to £700.

HMRC also plans to reintroduce an application fee of £400 for businesses newly registering or reapplying due to lapsed registration. Finally, the sanctions administration charge will be revised. While previously tied to the type of penalty, HMRC proposes a flat £2,000 charge for all types of sanctions, capped at the value of the penalty. A separate lower charge of £350 will still apply for specific regulatory failures.

These changes are open for comment until 29 August 2025, and it is expected that further information on when these new charges will be introduced will follow shortly afterwards.

HMRC’s new Q&A tool guides you through each step of a compliance check.

The free interactive online tool is designed to help individuals and businesses better understand what happens during a tax compliance check. Available on GOV.UK, the Interactive Compliance Guidance tool brings together key guidance and video content in one place, making it easier to navigate the process.

The tool explains:

• What an HMRC compliance check is.
• Why certain information or documents are requested.
• How to get extra support due to personal or health issues.
• How to appoint someone to act on your behalf.
• What to do if you disagree with HMRC’s decision.
• How to pay a tax assessment or penalty.

It uses a simple question and answer format with clear guidance videos, step-by-step explanations and links to other relevant guidance. The tool was developed with input from stakeholders like the Low Incomes Tax Reform Group to ensure it meets the needs of unrepresented and vulnerable taxpayers.

This guidance supports the government’s Plan for Change, aiming to improve taxpayer confidence, simplify access to information, and promote economic growth. The guidance and interactive tools are intended solely for informational purposes. Using them does not result in tax registration and HMRC does not collect or store any user information.

If your property has changed or seems mis-banded, you may have the right to request a Council Tax review.

Properties in England and Wales are assigned Council Tax bands based on their value as of 1 April 1991 (England) or 1 April 2003 (Wales). If you believe your property is incorrectly banded, you may challenge this through the Valuation Office Agency (VOA).

You have a legal right (known as ‘making a proposal’) to challenge if:

• You have paid Council Tax for less than 6 months.
• The VOA changed your band in the last 6 months.
• Your property or local area has undergone significant change (e.g. structural alterations, change of use, or redevelopment).

If you don’t have a legal right, you may still request a band review by submitting evidence such as:

• Sale prices of similar properties around the valuation date.
• Up to five comparable properties in lower bands, matching on type, size, age, and location.

Challenges can be made online, by form, phone, or email. Council Tax payments must continue during the review. VOA decisions may take up to 6 months (legal right) or 12 months (band review). Appeals are permitted only where a legal challenge was made.

If you live in Scotland, then you need to use the Scottish Assessors portal website to check your Council Tax band and if necessary, lodge a claim with them (known as a proposal).

Properties needing repairs still count as homes and false claims to recover Stamp Duty Land Tax could mean big tax bills and penalties.

HMRC has issued a warning to homebuyers about rogue tax agents promoting false Stamp Duty Land Tax (SDLT) repayment claims, especially those based on the condition of properties. Following a recent Court of Appeal decision, it has been confirmed that properties requiring repairs remain liable for residential rates of SDLT if they retain the fundamental characteristics of a dwelling. This applies even if the properties are temporarily uninhabitable.

Some agents exploit this by misleading buyers into believing they can reclaim SDLT by arguing the property is “non-residential.” These agents often charge hefty fees and leave homeowners liable for repayment of the tax, penalties, and interest.

HMRC’s press release on the matter provides an illustrative example of a person who bought a house in London for £1,100,000 with his solicitor filing the SDLT return and SDLT being calculated at the residential rates (£53,750). The home required some modernisation and repair.

The homebuyer was then targeted by a repayment agent who claimed he could recover £9,250 in SDLT due to property repairs. The agent took a 30% fee, and the homebuyer received £6,475. Later, HMRC carried out a compliance check and found the property was residential all along. This meant that the homebuyer was left owing the full £9,250, plus interest and penalties, with the agent refusing to assist.

The case reinforces that a property’s poor condition does not alter its classification as a dwelling if it is structurally sound and previously used as a home. SDLT claims that are invalid can result in serious financial consequences for the buyer, who is ultimately responsible for the accuracy of any SDLT repayment submission.

We would be happy to help you consider where you are eligible to make a claim without incurring unnecessary fees or risks.

Businesses can reclaim duties on qualifying goods moved to or through Northern Ireland since 2021

The Northern Ireland Duty Reimbursement Scheme allows businesses to reclaim import duties paid on goods moved into Northern Ireland, provided specific conditions are met. It applies retrospectively, covering eligible goods moved from 1 January 2021 onward.

A claim can be made by importers of ‘at risk’ goods into Northern Ireland. Additionally, agents or representatives authorised to act on behalf of an importer can also make a claim. If you are not UK-based, you must appoint a UK-established agent to submit the claim.

You can claim for duty paid or deferred if:

• The goods were sold, consumed or permanently installed in Northern Ireland.
• They were moved from Northern Ireland to Great Britain.
• They were exported outside the UK or EU.
• You have sufficient evidence that the goods meet the qualifying conditions.

Claims may be made for full or partial consignments. For example, if 50 out of 100 ‘at risk’ goods meet the criteria you can reclaim duty on those 50.

There are deadlines for making a claim which are as follows:

• By 30 June 2026 for goods moved between 1 January 2021 and 30 June 2023.
• Within 3 years of duty notification for goods moved after 30 June 2023.

The full amount of duty can be claimed for goods moved from Great Britain (England, Scotland and Wales) to Northern Ireland. The difference between EU and UK duty rates (where the EU duty was higher than the UK duty) can be claimed for imports into Northern Ireland from outside the UK or EU countries.

This scheme guidance has been updated as the new arrangements set out in the Windsor Framework have now been implemented.