HMRC One to Many letters – Risk management expenses - T&L

HMRC have advised us that they have commenced a One-to-Many letter campaign directed at large businesses regarding claiming of management expenses under s1219 CTA 2009 (investment businesses). A copy of the letters that are being sent to agents and to companies are provided below.

The letters to the agents were issued in the week commencing 15 September 2025 and the letters to the customers were sent out starting in the week commencing 29th September 2025. The aim of this One-to-Many campaign is to provide education to customers on the appropriate use of management expenses and risks around not tracking the beneficiary of management expenses. The letters were issued to a population of Large Business customers which HMRC sifting had indicated were more exposed to this risk.

Corporation Tax – Claiming Management Expenses (customer letter)
Corporation Tax – Claiming Management Expenses (agent letter)