HMRC confirm all SA109 taxpayers exempt from Making Tax Digital until April 2027

HMRC have confirmed to ATT and CIOT, along with other stakeholders, that they will treat any taxpayer who included 'SA109' pages in their 2024/25 tax return as automatically temporarily exempt from Making Tax Digital for Income Tax (MTD) until April 2027. Any taxpayer who did not include SA109 pages in their 2024/25 tax return but reasonably expects to do so in their 2025/26 or 2026/27 tax return can apply for temporary exemption until April 2027. 

HMRC previously announced that taxpayers who complete the residence, remittance basis etc (SA109) pages of their self assessment tax return would not be required to comply with MTD until April 2027.  This was to allow time for the significant changes to the taxation of non-UK domiciled individuals to be incorporated into MTD. 

The legislation for this, and other temporary 2026/27 exemptions, was recently published in The Income Tax (Digital Obligations) Regulations 2026. On applying the legislation in practice, concern was raised by our members that the regulations did not exempt all taxpayers who had completed a SA109 in their 2024/25 return. 

However, HMRC have now confirmed to ATT, CIOT and other stakeholders that all taxpayers who completed SA109 pages in their 2024/25 tax return will not need to comply with MTD until the 2027/28 tax year at the earliest. 

Taxpayers who reasonably expect their 2025/26 or their 2026/27 tax return to include SA109 pages, but who did not include SA109 pages in their 2024/25 tax return, are also temporarily exempt from MTD until April 2027, however these taxpayers must apply to HMRC for their exemption. 

HMRC are currently working on updating their exemptions guidance and hope to have the updated guidance published mid April.  Taxpayers or agents needing to apply for MTD exemptions should ensure they do so at the appropriate time. 

Further MTD resources can be found on ATT’s Making Tax Digital Hub.