Modernising the correction of errors

Draft FB 2026/27 legislation introduces a new obligation for taxpayers to take corrective action when they become aware of an inaccuracy in a return or document.

In ICAEW Representation 62/26, ICAEW encourages HMRC to consider:

• the case for introducing a de minimis threshold for the proposed taxpayer requirement to correct, so that the cost of administering the requirement does not exceed the amount of tax collected through it in each case; and
• whether further clarity is required, in the legislation itself or through detailed guidance, to address uncertainties around how the changes will work in some circumstances. 

Changes to the taxation of crypto assets

Draft FB 2026/27 legislation:

• treats eligible stablecoins more like money for tax purposes;
• changes the taxation of certain disposals involving crypto asset loans and liquidity pools so that they are treated as being ‘no gain, no loss’ for capital gains tax (CGT) purposes; and
• modernises HMRC’s civil information and inspection powers and definitions of computer records.

In ICAEW Representations 64/26 and 65/26, ICAEW recommends that: 

• key terms and definitions in the legislation applying to stablecoins and to crypto asset loans and liquidity pools are made clearer, either in the legislation or through more detailed explanatory notes; 
• HMRC publishes and maintains an “allow list” of instruments it believes would constitute a qualifying stablecoin; 
• for individuals, stablecoins are treated as always having been tax-exempt assets, so that no taxable gain or loss arises as a result of these rules coming into force;
• for companies, qualifying stablecoins are deemed to become loan relationships from the start of the first accounting period commencing on or after 1 April 2027. On transition to the new rules any capital losses should be treated as loan relationship debits to prevent ‘trapped’ losses; and any capital gains should be spread over a six-year period, subject to the company electing for this to be the case;
• the meaning of “crypto asset service provider” in connection with new information powers for HMRC is defined more precisely so that it is clear it only applies to parties that facilitate or carry out financial or transactional activities in relation to crypto assets. 

Simplifying the process to grant EMI options

Draft FB 2026-27 legislation removes the requirement to submit a notification of a grant of enterprise management incentives (EMI) options. 

In ICAEW Representation 70/26, ICAEW has raised some operational concerns, and called for guidance on aspects of the new process. For example, for an option to be treated as a qualifying option, the grant must be included in the annual return. ICAEW believes that a “proportionate remedy for errors” is needed and has asked HMRC to clarify what happens if an otherwise qualifying option is omitted from an annual return because of an administrative error. 

Implementing electric vehicle excise duty

Draft FB 2026/27 legislation implements the new electric vehicle excise duty (eVED), from April 2028. We previously explained how eVED is expected to work based on a consultation document published by the government in January 2026. The government confirmed the final design of eVED in a consultation outcome, published in July 2026. 

In ICAEW Representation 71/26, ICAEW has identified:

• several aspects in which the draft legislation does not yet deliver on commitments made in the government's consultation outcome. For example, it was originally stated that eVED rates will be uprated annually in line with CPI. However, the draft legislation sets fixed rates with no indexation mechanism or order-making power; 
• some operational gaps that would benefit from confirmation of the intended approach. For example, the draft legislation does not address how mileage is to be determined where an odometer has been replaced or reset, or how the mileage declared on first registering an imported vehicle is to be verified; and
• a small number of drafting errors that should be corrected before introduction. 

Implementing the securities transfer tax

Draft FB 2026-27 legislation implements a single, self-assessed tax on the transfer of securities: the securities transfer tax (STT). STT will replace stamp duty and stamp duty reserve tax. A commencement date has not been set yet.

In ICAEW Representation 69/26, ICAEW expresses broad support for the draft legislation. However, ICAEW is concerned that the draft legislation imposes joint and several liability on authorised agents, significantly altering the risk profile of acting as an agent in relation to STT. ICAEW believes this may discourage agents from filing returns on behalf of clients, potentially undermining compliance. 

ICAEW has strongly urged the government to amend the draft provisions, removing the reference to joint and several liability for an accountable person who is a tax agent.

Other measures

ICAEW has:

• expressed support for the government’s proposals to simplify treaty relief from withholding tax on interest paid overseas, (ICAEW Representation 63/26);   
• raised several technical points on the draft legislation implementing changes to the soft drinks levy (ICAEW Representation 67/26);
• identified a possible unintended outcome in the draft legislation providing for the removal of the landfill tax exemption for stabilisers added to dredgings when sent to landfill (ICAEW Representation 72/26); and
• asked that the government identifies the statutory basis for introducing an additional fee on low-value imports, charged to the seller or online marketplace alongside customs duty (ICAEW Representation 73/26).