HMRC accepts registration exemptions for specified non-group tax services

HMRC accepts that businesses in specified non-group structures need not register as tax advisers for services resembling in-house adviceGOV. Its transitional guidance covers joint ventures, post-sale arrangements, partnerships, professional networks and investment structuresGOV, and protects organisations that rely on it in good faith against sanctions for failing to registerGOV.

The distinction is between genuine third-party advisory business and relationships akin to those within a group. The statutory prohibition concerns an unregistered tax adviser interacting with HMRC over a client’s tax affairs, subject to exceptions. A group undertaking includes a parent, subsidiary or subsidiary of a parent undertakingLegislation. HMRC’s additional examples describe its treatment pending specific exemptions being added to Schedule 20; they do not announce those amendments as enactedGOV.

For joint ventures, an in-house team serving a venture more than 50% owned by its organisation falls within HMRC’s group example. HMRC also accepts a holding of 50% or less where the remaining interest belongs to one investor and an agreement assigns tax management to the first investorGOV. A partner dealing with another partner’s partnership tax affairs need not register where the JV partners share profits, losses and management responsibilities.

The guidance also covers a privately held UK group with several shareholders, none controlling it, whose in-house team handles those shareholders’ other UK investments. HMRC treats the ownership-derived relationship as similar to group adviceGOV.

After a disposal, a seller’s team may handle the sold companies’ pre-sale accounting periods without registration for those services. Where the buyer acquires the tax team, a time-limited arrangement serving the former group while it recruits or finds another provider is also acceptedGOV. The examples additionally describe an exiting 50% JV investor continuing fund-management and tax-filing services pending a replacement supplierGOV, and accept a seller’s temporary contracted tax support while the sold business moves onto the buyer’s systems.

A partner’s services concerning only partnership tax affairs are treated as in-house, including in a partnership JV. HMRC’s architecture LLP example also treats its team’s personal tax returns for members as part of wider in-house services. Employer tax support for employees on international assignments receives the same treatmentGOV.

Independent professional-network entities separated by legal or regulatory requirements can provide agreed tax services to one another without registration for that activityGOV. Fund managers’ or investment advisers’ in-house teams can serve fund entities, investee entities and investors where tax services form part of the wider management mandate, including through another entity in the management business. An originator’s or sponsor’s in-house tax work for an orphan SPV is similarly accepted.

The protection requires an organisation to act in good faith and rely on this guidance in deciding not to registerGOV. HMRC says it will treat it as compliant and impose no sanctions or penalties for that failure, even if registration is later found necessaryGOV; it would then support registration within a reasonable timeframeGOV. The manual also notes that some firms carrying on regulated activities fall within the tranche not required to register until 1 April 2027GOV.

The legal framework is Finance Act 2026, sections 223, 224 and 247 and Schedule 20Legislation, with “group undertaking” defined by Companies Act 2006, section 1161(5), as applied in HMRC’s MTAR10200 guidance.