Daily Australia Tax Update: 15 September 2026 : Foreign Resident CGT Reform Passes Parliament, Software Royalty Pushback Grows & PAYGW Annual Report Guidance Updated

Australia’s tax compliance landscape is changing quickly. Today’s key developments affect foreign investors in Australia, Australian businesses making cross-border payments, software and SaaS users, and employers preparing their September lodgments.

The biggest development is the passage of foreign resident Capital Gains Tax reforms. The Bill is awaiting Royal Assent, so you should monitor the commencement date before completing transactions involving Australian land, infrastructure or renewable energy assets.

1. Prepare for foreign resident CGT reforms after Parliament passes the Bill

The Treasury Laws Amendment (Strengthening Accountability for Tax Adviser Misconduct and Other Measures) Bill 2026 passed both Houses of Parliament on 10 September 2026. It is now awaiting Royal Assent.

According to the Treasury Ministers’ media release, the reforms will bring the Australian CGT treatment of foreign residents closer to the OECD Model Rules.

The changes are expected to commence on the first 1 January, 1 April, 1 July or 1 October after Royal Assent. If Royal Assent occurs before 1 October 2026, the expected commencement date will be 1 October 2026.

For foreign investors in Australia, the reforms will significantly expand the assets that may fall within taxable Australian real property, or TARP.

The expanded definition will cover:

  • Interests and rights over Australian land.
  • Contractual and personal rights connected with Australian land.
  • Fixed or installed infrastructure, regardless of how a State or Territory classifies the asset.
  • Solar panels, wind turbines, batteries and transmission lines.
  • Data centres, mining plant and equipment, and gas pipelines.
  • Leases, licences and contractual rights over covered assets.
  • Water entitlements.
  • Options and rights to acquire covered real property.

Mining, quarrying and prospecting information will also be included when testing the value of the principal asset.

Review the 365-day principal asset test

The principal asset test will apply where an entity met the test at any time during the 365 days before the CGT event.

This means you should not assess an asset only on the date of sale. A company may still fall within the regime if it previously met the principal asset test during the relevant look-back period.

Review transactions involving Australian land-rich companies, infrastructure groups and entities with significant natural resource interests. This applies whether the business operates from Sydney, Melbourne, Brisbane, Perth, Adelaide, Canberra or another Australian location.

Prepare for new vendor notification rules

For non-indirect Australian real property interest transactions of $50 million or more, foreign resident vendors will need to notify the ATO:

  • At least 28 days before completion where more than 31 days exist between signing and completion.
  • As soon as reasonably practicable in other cases.

If the vendor does not provide a valid notification, the vendor declaration will be invalid. The purchaser must then withhold 15%.

The purchaser knowledge test will also move from a subjective standard to an objective standard. Non-compliance penalties will start at $7.5 million.

These changes make transaction records, valuation evidence, contracts and completion timetables critical. Keep a clear audit trail so your business can demonstrate how it assessed the asset and withholding requirements.

Check the renewable energy concession

The final Bill includes a 50% transitional CGT discount for eligible Australian renewable energy assets. The concession applies to CGT events from commencement until 30 June 2040, extending the earlier proposed end date of 2030.

The concession can also apply to indirect interests where renewable energy assets represent at least three times the value of other TARP assets.

The final reforms apply prospectively to CGT events occurring on or after commencement. Earlier concerns about broader retrospectivity were removed from the final version.

2. Review offshore software and SaaS payments before the next remittance

The ATO has finalised TR 2026/2, which addresses when software-related payments are royalties for Australian tax purposes.

The ATO also released draft PCG 2026/D4. Consultation closes on 2 October 2026.

The ruling is particularly important for Australian businesses paying overseas software, cloud, platform, licensing or distribution providers. A payment may attract royalty withholding tax where it relates to the use of copyright or other intellectual property rights.

The practical question is not simply whether you call an arrangement “SaaS” or “software access”. You should examine:

  • What rights the contract grants.
  • Whether the Australian payer can use, reproduce, modify or distribute software.
  • Whether copyright or other intellectual property rights are involved.
  • Whether support, hosting and licensing are bundled.
  • Where the software owner and payment recipient are resident.
  • Whether a tax treaty changes the withholding outcome.

International pushback is growing. The US Treasury objected during the consultation process. The Washington-based National Foreign Trade Council has said the ATO position runs against international tax norms. The White House has also warned trading partners against introducing new taxes on US technology companies.

Reporting by The Conversation noted that Apple, Microsoft and Amazon reported combined Australian income of almost A$30 billion in 2023–24, with combined tax payable of approximately A$478 million. The ATO’s position could increase royalty withholding tax exposure for some cross-border software payments, and further litigation is possible.

The ATO has also published a decision impact statement on Oracle Corporation Australia Pty Ltd v Commissioner of Taxation [2025] FCAFC 145. The statement highlights the importance of preserving Mutual Agreement Procedure rights where a payment may be taxed in more than one country.

Action point: Build a payment register for all overseas software, cloud and platform suppliers. Flag higher-risk agreements before the next payment. This will help you identify withholding obligations and reduce the risk of historic reporting gaps.

3. Lodge the PAYGW annual report by 31 October

The ATO updated its PAYG withholding annual report guidance on 11 September 2026. A new completion guide was published on 4 September.

The PAYG withholding from interest, dividend and royalty payments paid to non-residents annual report, known as NAT 7187, covers the period from 1 July 2025 to 30 June 2026.

The lodgment deadline is 31 October 2026.

Use NAT 7187 to report relevant:

  • Interest payments to non-residents.
  • Unfranked dividends paid to non-residents.
  • Royalty payments to non-residents.
  • Amounts withheld from those payments.

If interest or dividend amo

USA Update: FinCEN Ends BOI Reporting for US Companies : What International Sellers Must Know

TITLE: FinCEN BOI Reporting Ends for US Companies: What International Sellers Must Still File

Stop BOI filings for domestic US companies

Domestic US companies are now exempt from CTA BOI reporting.

This includes entities formed under US state or tribal law, such as:

  • US single-member LLCs
  • US corporations
  • US partnerships
  • Other domestic entities created by filing formation documents with a US authority

Under the final rule, these entities no longer need to:

  • File an initial BOI report
  • Submit BOI updates
  • Correct previously filed BOI information
  • Report their beneficial owners or company applicants to FinCEN

US persons also receive broad relief. They no longer need to provide BOI to reporting companies when they are beneficial owners or company applicants. US persons with FinCEN IDs do not need to update or correct the information previously submitted for those IDs.

The rule is effective from 14 August 2026. Read the official FinCEN BOI guidance for the current position.

Understand why the relief is not universal

The exemption applies to domestic US companies. It does not cover every foreign business operating in the United States.

A foreign company can still be a reporting company if it:

  1. Was formed under the law of a foreign country; and
  2. Registers to do business in a US state or tribal jurisdiction by filing with a secretary of state or similar authority.

For example, a UK company, Canadian corporation, or Australian company registering to trade directly in a US state may remain within the BOI reporting rules.

A foreign reporting company must generally file its initial BOI report within 30 calendar days of the earlier of:

  • Receiving actual notice that its registration is effective; or
  • The state or tribal authority first providing public notice of the registration.

The report must identify the foreign company and its relevant foreign beneficial owners. It no longer needs to report US-person beneficial owners or US-person company applicants.

Non-US company applicants may still need to be reported where the rules require that information.

Review the FinCEN final rule Q&A before assuming your business is exempt.

Let FinCEN handle the data purge

FinCEN plans to remove previously submitted information relating to domestic US companies and US persons from its BOI system.

The agency expects to complete this through a one-time database sweep. You do not need to submit a deletion request or contact FinCEN to remove the information.

FinCEN also does not plan to provide individual deletion confirmations. It will publish a public notice when the deletion process is complete.

This administrative purge does not affect other federal or state records. Your IRS filings, state registrations, sales tax accounts, banking records, and accounting documents remain separate.

Keep Form 5472 on your compliance calendar

The most important warning for international sellers is simple:

FinCEN BOI relief does not remove IRS Form 5472 obligations.

A foreign-owned US single-member LLC that is treated as a disregarded entity may still need to file Form 5472 when it has reportable transactions.

The LLC generally files:

  • Form 5472; and
  • A pro forma Form 1120 attached to the filing.

The form is normally due by the deadline, including extensions, for the pro forma Form 1120. A foreign-owned US disregarded entity does not usually file a standard income tax return simply because it has a Form 5472 obligation. However, it must still follow the IRS filing process for Form 5472.

Reportable activity may include transactions with the foreign owner or related parties, such as:

  • Capital contributions
  • Distributions
  • Loans
  • Payments for services
  • Reimbursements
  • Certain formation or acquisition transactions
  • Other monetary, non-monetary, or less-than-full-consideration transactions

Check the IRS Form 5472 instructions and the IRS Form 5472 information page to confirm the filing requirement.

Avoid the $25,000 Form 5472 penalty

The IRS can assess a $25,000 penalty for each failure to file a complete and correct Form 5472 on time.

The same penalty can apply where required records are not maintained.

If the failure continues for more than 90 days after the IRS sends a notice, an additional $25,000 penalty may apply for each 30-day period, or part of a 30-day period, after that 90-day period ends.

There is no maximum penalty amount for Form 5472 failures.

That means a missed filing can become increasingly expensive. The penalty is separate from any FinCEN BOI consequences and is administered by the IRS.

The IRS international information reporting penalties guidance confirms the current penalty structure.

Check state-level reporting separately

Federal BOI relief does not override state reporting rules.

New York’s LLC Transparency Act took effect on 1 January 2026. It applies to certain non-US LLCs formed under foreign-country law and authorised to do business in New York.

A qualifying foreign LLC may need to submit beneficial ownership information to the New York Department of State. Some exempt entities may still need to file an exemption attestation.

The New York requirements are separate from FinCEN reporting. Therefore, a foreign business can be:

  • Exempt from federal FinCEN BOI reporting; but
  • Still required to file a New York disclosure or exemption attestation.

Review the New York Department of State beneficial owner disclosure guidance if your foreign company is registered in New York.

Other states may introduce similar requirements. Always check the state where your entity is formed or registered.

Apply the rules to a UK seller with a US LLC

Consider a UK ecommerce seller that owns a US single-member LLC.

If the LLC was formed under US state law:

  • It is exempt from FinCEN BOI reporting.
  • It does not need to file BOI updates or corrections.
  • The UK owner does not need to report BOI to FinCEN through that domestic LLC.
  • The LLC may still need to file Form 5472 with a pro forma Form 1120 if reportable transactions occurred.

Now consider a different structure. The UK company itself registers to do business in New York as a foreign entity.

In that case:

  • The UK company may remain a FinCEN reporting company.
  • It may need to file its initial BOI report within 30 calendar days of registration becoming effective or public notice, whichever is earlier.
  • It may also need to comply with New York’s beneficial ownership disclosure rules.

Separate FinCEN relief from IRS and state duties

The FinCEN final rule effective 14 August 2026 removes a significant layer of federal reporting for domestic US companies and US persons. For international sellers, the practical effect is narrower than it first appears.

Three duties remain distinct and must be handled separately:

  • FinCEN BOI reporting — gone for domestic US entities, still live for many foreign companies registered in the US.
  • IRS Form 5472 — unaffected by the FinCEN rule, with a starting penalty of $25,000 per failure and no cap.
  • State-level disclosure — such as New York’s LLC Transparency Act, which operates independently of federal rules.

Confirm your entity’s status, check your filing calendar, and verify each obligation against the official guidance before the next deadline.

USA Update: IRS Removes FBAR Penalty Relief Language : What International Sellers Must Know

USA Update: IRS Removes FBAR Penalty Relief Language : What International Sellers Must Know

TITLE: The IRS Has Quietly Removed Its FBAR Penalty Reassurance — What UK-Based Founders Need to Know

What the IRS changed in September 2026

The IRS FBAR page now states that:

Filing an FBAR late or not at all is a violation and may subject you to penalties.

It also advises taxpayers who have not been contacted by the IRS and are not under investigation to file late FBARs as soon as possible to minimise potential penalties.

This replaces the clearer public-facing assurance previously associated with the Delinquent FBAR Submission Procedures. That earlier language stated that certain taxpayers would not face a penalty where they:

  • Properly reported the income from the foreign account.
  • Paid the associated US tax.
  • Had not been contacted by the IRS about the relevant years.

The removal does not change the FBAR filing obligation or the statutory penalty framework. It does mean you should no longer treat the previous public assurance as an automatic, programme-based protection.

The current IRS FBAR guidance now places greater emphasis on prompt filing, accurate records, and the facts surrounding each case.

The FBAR requirement remains unchanged

You generally need to file FinCEN Form 114, commonly called an FBAR, when all of the following apply:

  1. You are a US person.
  2. You have a financial interest in, or signature authority over, at least one foreign financial account.
  3. The combined maximum value of those accounts exceeded $10,000 at any time during the calendar year.

A US person can include:

  • A US citizen.
  • A US resident for FBAR purposes.
  • A corporation formed in the United States.
  • A partnership or LLC created under US law.
  • Certain trusts and estates.

The account does not need to generate taxable income to be reportable. This is important. Reporting the income on your US tax return does not remove the separate FBAR obligation.

You must file the FBAR electronically through the FinCEN BSA E-Filing System. It is not filed with your federal income tax return.

Key FBAR deadlines for international sellers

The standard FBAR deadline is April 15 following the calendar year being reported.

An automatic extension runs until October 15. You do not need to request this extension.

For example:

  • The 2025 FBAR was due on April 15, 2026.
  • The automatic extended deadline is October 15, 2026.
  • A complete filing after October 15 may be considered late.

Special disaster relief notices or limited extensions for specific categories of filers can apply. Always check the latest IRS and FinCEN notices before relying on a different deadline.

If you have not filed a required 2025 FBAR and are not under IRS contact, civil examination, or criminal investigation, act before the October deadline where possible.

Why this matters to UK-based US LLC owners

A US LLC is generally a US entity for FBAR purposes. Its federal income tax classification does not automatically remove its reporting obligations.

Consider this example.

Example 1: US LLC with a UK bank account

A UK-based founder owns a Delaware LLC. The LLC receives ecommerce revenue into a UK business bank account before transferring funds to its US payment processor.

If the LLC had a financial interest in the UK account and the combined maximum value of its foreign accounts exceeded $10,000 during the year, the LLC may have an FBAR filing obligation.

The founder is not automatically required to file a personal FBAR simply because they own the LLC. Their personal obligation depends on their own status as a US person and their personal interest or authority over reportable accounts.

This distinction matters. Review the entity and the individual separately.

Example 2: US citizen living in the UK

A US citizen lives in Manchester and sells products through Amazon and Shopify. They use UK bank accounts to receive or hold business funds.

If the person is a US person and the maximum combined value of reportable foreign accounts exceeded $10,000 during the year, an FBAR may be required. This can apply even if the person has already included the business income on their US tax return and paid the relevant tax.

Example 3: Multiple accounts below $10,000

A US-based ecommerce company has:

  • A Canadian account with a maximum balance of $6,500.
  • A UK account with a maximum balance of $4,000.
  • An Australian account with a maximum balance of $2,000.

No single account exceeds $10,000. However, the combined maximum values exceed the threshold. The aggregate test may therefore create an FBAR filing obligation.

Penalties are possible, but not automatic

The IRS states that civil penalties depend on the facts and circumstances. The main categories are:

  • Non-willful violations: The statutory maximum is $10,000 per violation, adjusted for inflation.
  • Willful violations: The statutory framework allows a penalty up to the greater of an inflation-adjusted $100,000 or 50% of the account balance at the time of the violation.
  • Criminal violations: Serious cases may involve criminal penalties.

The IRS Internal Revenue Manual confirms that examiners have discretion. They may consider whether a warning letter and corrected filings are sufficient to improve future compliance.

The Internal Revenue Manual also states that a penalty should not be asserted where:

  • The failure was not willful.
  • The failure was due to reasonable cause.
  • Accurate delinquent or amended FBARs are filed.

This is helpful, but it is not the same as a guaranteed penalty exemption. You should document your circumstances rather than rely on a general assumption that tax payment alone resolves the issue.

Follow this action checklist

Use the following checklist if you believe an FBAR may be missing.

1. Identify every relevant US person

Review each individual and entity separately. Include US LLCs, corporations, partnerships, US citizens, and US residents where applicable.

Do not assume that living outside the United States removes the obligation.

2. List every foreign financial account

Include foreign bank, securities, brokerage, and other reportable financial accounts. Consider accounts held in the UK, EU, Canada, Australia, and other countries.

Review accounts connected with:

  • Ecommerce operations.
  • Marketplace settlements.
  • International payment flows.
  • Foreign subsidiaries.
  • Business reserves.
  • Founder or director signature authority.

3. Calculate the maximum annual values

Use the highest value of each account during the calendar year. Then convert the figures into US dollars using the

SME Banking & Fintech Review: Multi-Currency Accounts, Open Finance and Smarter Lending (September 2026)

SME Banking & Fintech Review: Multi-Currency Accounts, Open Finance and Smarter Lending (September 2026)

Hold more currencies and reduce avoidable FX costs

Stripe expands multi-currency settlement to 37 markets

Stripe is expanding multicurrency settlement so businesses in 37 markets will be able to settle payment earnings in up to 18 currencies by the end of 2026, depending on their location and eligibility.

Stripe has also introduced instant currency conversion. Businesses can convert funds between 15 currencies through the Dashboard, API or mobile interface. The feature operates 24/7, with real-time rates and no weekend surcharge, according to Stripe’s announcement.

This matters because international businesses often face the “double FX trap”:

  • Customer payments are converted into the business’s home currency.
  • The business later converts funds back to pay an overseas supplier or contractor.
  • The company pays conversion costs twice.

Action for your business:

  1. List the currencies your customers pay in.
  2. Identify the currencies used for suppliers, payroll and advertising.
  3. Keep funds in the original currency where practical.
  4. Convert only when you have a genuine operating need.
  5. Reconcile each settlement against your payment platform and bank records.

This can reduce unnecessary FX leakage. However, you must still record the correct sterling value of transactions and track realised or unrealised exchange differences for your accounts.

Razorpay introduces foreign-currency settlement for exporters

Razorpay’s Multi-Currency EEFC Account enables exporters to receive settlements directly in USD, EUR, GBP, AED and SGD, without immediate conversion into Indian rupees.

The Razorpay newsroom release explains that the account is designed to reduce repeated conversion cycles and give businesses more control over when they convert foreign earnings. The official release was published in August and updated on 7 September 2026.

The wider lesson is relevant to any international seller: your payment account should match your cash-flow needs. A multi-currency business account can be valuable when you regularly receive and spend in the same foreign currency.

Keep a currency-by-currency schedule showing:

  • Opening balance.
  • Payments received.
  • Refunds and chargebacks.
  • Supplier payments.
  • Bank or platform fees.
  • FX conversions.
  • Closing balance.

This structure makes ecommerce bookkeeping UK businesses easier to review and helps your accountant identify missing transactions.

Nu Global combines US banking with stablecoin-based transfers

Nu has launched in the United States through a partnership with FDIC-insured Lead Bank. At the same time, it introduced Nu Global, a multi-currency account using USDC and EURC to support transfers across more than 35 countries.

According to Nu’s Business Wire announcement, the product is aimed at customers with international financial needs. It is initially focused on Europe and Latin America and includes a virtual Mastercard.

For SMEs, stablecoin-linked accounts may offer faster settlement and lower transfer costs. They also require careful records. Treating every movement as a simple bank transfer could create errors in your bookkeeping, especially where balances are converted, spent or exchanged.

Record the asset, currency, value and transaction date for every movement. Keep platform statements and conversion records so your accounts can be supported later.

Aspire links a multi-currency account with Mastercard spending

Aspire has commercially launched an enhanced multi-currency business account integrated with a Mastercard World Business Debit Card.

The announcement reported through Investegate describes a combined platform for:

  • Multi-currency account management.
  • Domestic and international payments.
  • Foreign exchange.
  • Payroll and direct debits.
  • Supplier payments.
  • Business debit-card spending.
  • Trade finance of up to £5 million for eligible customers.

The benefit is operational consolidation. You may not need separate providers for an account, card, FX and selected working-capital services.

The control requirement is equally important. Set clear spending rules and reconcile card transactions weekly. This prevents duplicated expenses, uncategorised payments and VAT errors.

Access working capital using live sales data

Ping An Digital Bank offers purchase-order financing for ecommerce SMEs

Ping An Digital Bank has launched collateral-free Purchase Order Financing for cross-border ecommerce businesses. Eligible merchants may receive up to 95% of accounts receivable, with facilities of up to US$5 million and approval and drawdown as fast as T+1 business day.

The product uses real-time sales data from cross-border buyers and platforms rather than relying only on traditional financial statements. Details are reported by The Asian Banker.

The 95% advance rate and T+1 timing are maximum parameters, not guaranteed terms for every applicant.

Prepare your business before applying:

  • Keep platform sales data complete and consistent.
  • Reconcile orders, refunds and chargebacks.
  • Maintain accurate aged receivables.
  • Separate revenue by market and currency.
  • Track inventory commitments against available cash.
  • Store customer and buyer documentation securely.

Good ecommerce bookkeeping is now part of your funding infrastructure. Accurate data can support lending decisions, while incomplete records may delay or weaken an application.

iwoca brings loans of up to £1 million to Starling users

Starling Bank customers can now apply for iwoca business loans from within the Starling app or online banking. The facility ranges from £1,000 to £1 million, with terms from one day to five years and no early repayment fees.

As iwoca explains, iwoca provides and manages the loan. Starling provides the cus

Weekly Ecommerce Accounting Insights

## The week commencing 14 September 2026 brings important accounting, fulfilment and cross-border compliance actions for Amazon and Shopify sellers.

If you are looking for an **ecommerce accountant in the UK**, an **Amazon seller accountant UK** service, or structured **Shopify accounting UK** support, your priority should be accurate daily records. This means reconciling marketplace settlements, tracking VAT correctly, recording fulfilment costs and preparing for filing deadlines before they become urgent.

Prepare your Amazon FBA accounts for peak-season costs

Amazon’s UK festive season peak fulfilment fee applies from **15 October 2026 to 14 January 2027** for selected FBA orders.

For UK sellers, the fee applies to:

  • Small and standard parcels fulfilled through local UK FBA.
  • Large and extra-large envelopes.
  • Remote Fulfilment orders from the EU to the UK.

The average additional charge is:

  • £0.12 per parcel item.
  • £0.07 per large or extra-large envelope item.

The fee does not apply to oversize items, Low-Price FBA items, apparel, or items delivered to buyers in other EU countries. The fee is determined when units leave the fulfilment centre, based on the ship date.

You should also include Amazon’s separate **1.5% fuel and logistics-related surcharge** in your calculations. This surcharge has applied year-round since **17 April 2026** and continues on top of the festive peak fee.

Do not rely on headline fee estimates. Review the exact impact on each SKU using Amazon’s Revenue Calculator and the FBA Fee Preview report. Then update your product margin reports and cash-flow forecasts.

This is essential for accurate **Amazon FBA accounting UK**. A product can appear profitable before fulfilment, storage, referral, advertising and peak-season charges are reconciled.

Track Amazon’s Q4 deadlines before inventory becomes expensive

Amazon’s key UK deadlines are now close.

For Prime Big Deal Days:

  • Deal submissions remain open until **23 September 2026**.
  • UK inventory should arrive by **16 September 2026** to support Prime badge eligibility.

For Black Friday Week:

  • Deal submissions remain open until **18 November 2026**.
  • UK inventory should arrive by **28 October 2026** to support Prime badge eligibility.

UK promotion fees include:

  • £12 upfront per promotion.
  • 0.75% of promotional sales, capped at £600.

Prime Exclusive Discounts also require a minimum product rating of **3.5**.

Record each promotion fee separately in your bookkeeping system. Do not combine Amazon promotion costs with general advertising. Separating these costs helps you measure the true return from each campaign and supports cleaner year-end accounts.

Amazon’s fulfilment centres typically focus on receiving inventory during September and October before shifting towards order processing in November and December. Inbound delivery slots can become limited, so use Capacity Manager and monitor your available receiving dates.

Keep FBM delivery data and customs records accurate

From **30 September 2026**, Amazon.co.uk sellers using Fulfilment by Merchant must maintain a business-hour delivery rate of at least **90%** for Amazon Business customers.

From **30 October 2026**, Amazon may deactivate listings for business customers where the requirement is not met.

Review your:

  • Dispatch timestamps.
  • Carrier collection records.
  • Delivery confirmations.
  • Business-hour delivery performance.
  • Handling-time settings.

From **1 September 2026**, Amazon may enable Automated Handling Time for SKUs where the set handling time has exceeded actual performance for more than 30 days. Account-level default handling time settings now show only zero-day and one-day options, following the change introduced on **15 July 2026**.

For shipments under €150 imported under IOSS, new EU Customs Reform requirements also mean you must use approved couriers and provide Amazon’s IOSS number and the relevant ASIN details for each product.

Keep customs evidence with your sales records. This will help you reconcile import charges, identify the correct importer and respond quickly if Amazon or a customs authority requests documentation.

Monitor the proposed UK marketplace VAT liability rules

HMRC’s consultation on extending online marketplace VAT liability closed on **18 August 2026**. HMRC is now evaluating feedback, and legislation may follow in Finance Bill 2026–27.

The proposal would potentially make marketplaces jointly or fully liable for VAT on certain sales by UK-established sellers. This would extend the existing approach used for some overseas sellers since 2021.

The consultation targets VAT under-declaration and missing-trader behaviour, including:

  • B2C sales incorrectly classified as B2B.
  • Sellers fragmenting activity across multiple marketplace accounts.
  • VAT not being declared on digital marketplace sales.

Nothing has changed in law yet. Continue applying the current VAT rules and maintain your own transaction records.

Read the full HMRC online marketplace VAT liability consultation. The practical lesson is simple: do not depend solely on marketplace reports. Keep a complete record of sales, refunds, VAT treatment, customer type and stock location.

Review MTD requirements for qualifying ecommerce income

HMRC began auto-enrolling eligible sole traders with qualifying income above £50,000 from September 2026 for the 2026/27 phase of Making Tax Digital for Income Tax.

The second quarterly update for 2026/27 is due by **7 November 2026**. You must keep digital records and use compatible software.

If you operate an ecommerce business as a sole trader, review your 2024/25 qualifying income and confirm whether MTD applies to you. Include marketplace and direct-store income in your records, then reconcile the figures to bank deposits and payment processor reports.

Use HMRC’s MTD eligibility guidance to check your position.

Completing reconciliations weekly will reduce the risk of missing income, duplicating sales or submitting incomplete quarterly updates.

Apply the new UK VAT group refund process correctly

HMRC Revenue and Customs Brief 8 (2026), published on **8 September 2026**, changes how non-UK businesses in a UK VAT group claim UK VAT refunds.

A non-UK business that incurred the VAT must now submit its own refund claim. The UK VAT group’s representative member cannot claim the VAT unless it incurred that cost itself.

For the prescribed year from **1 July 2025 to 30 June 2026**, transitional arrangements allow claims from either:

  • The individual non-UK group member that incurred the VAT.
  • The representative member.

The deadline for these claims is **31 De