Corporation tax on Feed-In Tariffs June 2025

In December 2024 HMRC updated its guidance in the manuals concerning the corporation tax treatment of Feed-In Tariff income (PIM1051, PIM2076 and PIM4300).

This subject provides significant complexity for housing associations who generate £80,000 or more from such sources. Previous guidance stated that HMRC considered in most circumstances it should be treated as miscellaneous income, and therefore taxable for charitable housing associations which otherwise benefit from charitable exemptions.

Prior to the release of the December updates, some housing associations had been expecting to see a material change to the position. However, our understanding is that HMRC was asked to consider how the previous guidance applied to a specific set of facts, and their updated guidance provides further clarification on those facts only and does not represent a material change on the overall position.

The updated guidance focuses on whether there is a supply by the landlord to their resident which includes a supply of energy, and so the complexity remains.

The NHF and its tax advisors BDO remain in discussion with HMRC about whether further clarity can be provided. In the meantime, registered providers who are unclear about whether the revised guidance might change their analysis should review based on their individual situation.

It remains open to them to contact HMRC should they wish to seek clarity on their own position.