June 17, 2026

Article

What farming and rural business owners need to know

HMRC has launched a consultation that could change how transactions between companies and their directors/ shareholders must be reported in future. 

While no changes have been finalised yet, the proposals are highly relevant to farming businesses and landed estates who trade through a limited company.

What is being proposed?

HMRC is considering introducing a new reporting requirement for transactions between close companies and their shareholders or directors (known as “participators”).

A close company includes most farming and family companies – broadly any company controlled by five or fewer shareholders, or by shareholders who are also directors.

The proposals would require companies to report detailed information about payments and transfers of value between the business and its owners, going well beyond the current disclosures for loans to participators.

Why is HMRC doing this?

HMRC believes that transactions between companies and their owners are a key contributor to the small business corporation tax gap.

This is aimed at where participators are withdrawing funds beyond what they are legally entitled to, and not repaying this outstanding balance to the company.

HMRC wants greater visibility of these transactions to reduce error and misuse.

How would reporting work?

HMRC is consulting on whether information would be reported:

  • Annually through the corporation tax return, or
  • Via a separate digital reporting process, possibly more frequently

HMRC is also considering whether specific penalties should apply for late or incorrect reporting.

What should farming businesses do now?

Although this is only a consultation, the direction of travel is clear.

Businesses should:

  • Ensure loans to directors, shareholders, or businesses they are associated with, including partnerships and sole trades, are properly tracked so correct tax reporting is made
  • Speak to their adviser before transferring funds or assets

We are feeding back to HMRC to encourage proportionate, practical rules that recognise how genuine farming and family businesses operate.

We will keep clients fully informed and provide guidance well in advance of any new reporting requirements coming into force.

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