The release, by HM Treasury and HMRC on 2 April 2025, of a came as something of a surprise to many in the waste industry. There had been an earlier ‘call for evidence� back in the spring of 2021 but many believed that attempt to modernise the tax had fizzled out � or at least been put on the backburner for the foreseeable future. The publication of the consultation exercise has given many old Landfill Tax debates new life, however, and there are almost as many views on the proposed reforms as there are landfill sites in the two countries.
The fact that only two countries within the UK are involved is the product of devolution of the old UK Landfill Tax to Scotland in 2015 and Wales in 2018. At first, the three taxes were essentially on all fours with each other � as you would expect in a small state with land borders (and the potential for ‘waste tourism�) between its constituent parts � but they have already begun to drift apart, certainly in terms of statutory interpretation and more recently in terms of the legislation itself. That creates the first conundrum posed by this consultation: where England and Ireland go first, will Scottish Landfill Tax and the Welsh Landfill Disposals Tax follow? Running three similar but not identical taxes is already hard work for landfill site operators and, given that the UK changes will surely be followed but perhaps not copied wholesale by Revenue Scotland and the Welsh Revenue Authority, there could be further complexities at every level.