ACCA ATX-UK — Advanced Taxation Syllabus 2026
ATX at a Glance
ATX-UK (formerly P6) builds significantly on TX and tests your ability to provide senior-level tax advice in complex, multi-party scenarios. It encompasses inheritance tax, trusts, advanced corporate tax planning, and international taxation — all applied with professional judgement and ethical sensitivity.
Complete ATX-UK Syllabus 2026 — Section by Section
Section A — Knowledge & Understanding of the Tax System
- Professional responsibilities and the ethics of tax advice.
- HMRC powers: enquiries, information notices, penalties for errors and late filing.
- Tax avoidance vs evasion; the GAAR and disclosure of tax avoidance schemes (DOTAS).
Section B — Advanced Income Tax & NIC
- Complex employment income: termination payments, disguised remuneration, off-payroll working (IR35).
- Complex trading income: opening/closing year rules; overlap profits; change of accounting date.
- Losses for individuals: complex set-off scenarios and carry-back claims.
- Trusts: income tax treatment of interests in possession and discretionary trusts.
Section C — Advanced Capital Gains Tax
- Complex share matching: own shares, rights issues, EIS/SEIS holdings.
- Advanced reliefs: BADR (formerly Entrepreneurs' Relief), IR, Gift Relief, PRR in detail.
- Furnished holiday lettings: special CGT treatment.
- CGT for trusts and settlements.
Section D — Inheritance Tax
- IHT basics: chargeable lifetime transfers, potentially exempt transfers, death estate.
- Business Property Relief (BPR) and Agricultural Property Relief (APR).
- IHT and trusts: discretionary trusts, relevant property regime, ten-year charges.
- Planning: use of nil rate band, transferable nil rate band, annual exemptions.
Section E — Advanced Corporation Tax
- Groups: group relief, capital gains groups, degrouping charges.
- Close companies: loans to participators, associated company rules.
- Corporate venturing: EIS shares held by companies.
- Corporate tax planning: choice of business medium, incorporation, extraction of profits.
Section F — International Taxation
- Residence: statutory residence test (SRT) for individuals; corporate tax residency.
- Double tax relief: credit method, exemption method.
- Transfer pricing: OECD arm's length principle applied to UK multinationals.
- Controlled Foreign Companies (CFC) rules.
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ATX — Frequently Asked Questions
How different is ATX from TX?
TX applies tax rules to given data. ATX demands advisory-level thinking — you must identify planning opportunities, consider ethical issues, and structure advice clearly in professional formats (like a tax report or memo). The technical content is also significantly broader, adding IHT, trusts, international taxation, and complex corporate scenarios.
Do the Finance Act rates change every year for ATX?
Yes. ACCA specifies which Finance Act applies to each sitting. Always check the ACCA website for applicable tax rates and legislation before your exam. The rules change annually, particularly for NIC thresholds, pension limits, and CGT annual exempt amounts.