STA — Taxation Advisory Professional
STA Taxation Advisory Professional (UK) replaces ATX-UK Advanced Taxation at Strategic Professional Options level. Both papers are 3 hr 15 min, 100 marks, 50% pass mark, covering the same broad UK tax scope — income tax, NIC, CGT, IHT, corporation tax, VAT and stamp taxes. Key changes: (1) restructured from ATX-UK's tax-type-based layout to a scenario-type-based layout (Individuals, Businesses, Overseas, Compliance+ethics); (2) ATX-UK's 5 separate ethics marks in Section A removed — ethics now explicit in Section D2; (3) Section E Employability and technology skills removed entirely; (4) stamp taxes integrated contextually rather than as a standalone section. Finance Act 2026 applies for Sep 2027–Mar 2028 examinations.
Exam Format
Section A: 1 × 50-mark scenario (40 technical + 10 professional skills) · Section B: 2 × 25-mark questions (20 technical + 5 professional skills each) · 3 hr 15 min · 100 marks · all compulsory
Key Changes vs Legacy Paper
- Restructured from tax-type-based layout (ATX-UK: IT, CGT, IHT, CT, Stamp taxes, VAT) to scenario-type-based layout (STA: Individuals, Businesses, Overseas, Compliance+ethics)
- ATX-UK's 5 separate ethics marks in Section A removed — ethics now explicit in Section D2 with named learning outcomes
- Section E Employability and technology skills removed entirely (consistent with 2027 qualification redesign)
- Stamp taxes no longer a standalone section — integrated contextually in business and overseas sections
- Trust content significantly narrowed to discretionary trusts only (ATX-UK had extensive trust type distinctions)
- FIG regime replaces remittance basis; long-term UK residence replaces domicile/deemed domicile for IHT
- Off payroll working (IR35) now a named outcome under owner managed businesses
- Finance Act 2026 applies for Sep 2027–Mar 2028 examinations
Syllabus Comparison — ATX → STA
| Change | Area / Topic | Detail |
|---|---|---|
| CHANGED | Section A exam marks | 35 technical + 5 ethics + 10 professional skills = 50 → 40 technical + 10 professional skills = 50 (ethics marks removed from exam allocation; ethics now a syllabus section D2) |
| CHANGED | Syllabus structure | Organised by tax type (IT, CGT, IHT, CT, Stamp taxes, VAT/admin) → Organised by scenario context (Individuals, Businesses, Overseas, Compliance+ethics) |
| CHANGED | Employability skills | Section E: 4 outcomes on using computer technology in the exam → Removed entirely |
| CHANGED | Stamp taxes | ATX-UK A5 standalone section: stamp duty on shares; SDLT on land; SDRT; group relief from SDLT; excluded topics: leases, LBTT → No standalone section. The overall aim states stamp taxes remain examinable; stamp duty on shares covered in B2d/B4; SDLT contextualised in B4 real property transactions |
| CHANGED | VAT partial exemption & capital goods scheme | ATX-UK A6: advise on partial exemption and capital goods scheme [3] → STA B1n: partial exemption for businesses [3] — retained but now in business context |
| CHANGED | Special VAT schemes | ATX-UK A6: advise on special schemes — flat rate, annual accounting, cash accounting [3] (via TX-UK F3 reference) → STA B1o: explicit outcome for VAT schemes to help smaller businesses [3] |
| CHANGED | Off payroll working (IR35) | ATX-UK A1c(iii): personal service companies and tax consequences [3] → STA B1e: "off payroll working rules" as a named outcome [3] — renamed and reframed |
| CHANGED | CGT reliefs | ATX-UK A2g: EIS/SEIS reinvestment; BADR associated disposals; transfer to limited company (unnamed as "incorporation relief") → STA A3g: same reliefs but "incorporation relief" is now named explicitly; full list includes: BADR+associated disposals; investors' relief; gift holdover; rollover; private residence relief; incorporation relief; EIS/SEIS reinvestment; negligible value claims |
| CHANGED | IHT long-term residence | ATX-UK A3b(i): introduced in Jun 2026–Jun 2027 update replacing domicile/deemed domicile → STA C1g–C1h: "long-term UK residence" and LTR/non-LTR IHT rules retained [3] |
| CHANGED | FIG regime | ATX-UK A1b(ii)/A2b(iii): FIG regime introduced in Jun 2026–Jun 2027 update replacing remittance basis → STA C1b: FIG regime for qualifying UK tax resident individuals for IT and CGT [3] |
| CHANGED | Ethics in tax planning | ATX-UK C5: "ethical and professional issues arising from giving of tax planning advice [3]" — 5 separate ethics marks in exam Section A → STA D2: full subsection with 5 named outcomes on ethical obligations — no separate ethics mark allocation in exam; ethics assessed as part of 40 technical marks |
| CHANGED | Trusts | ATX-UK A1e(iii) IT from trusts; A2c CGT and trusts (transfers into/from trust); A3e IHT from trusts and on property within trusts — extensive trust content at [2]/[3] → STA A3o: CGT and IHT consequences of transfers of property into a discretionary trust [3] — trusts coverage is narrowed to discretionary trusts only; IT from trusts and detailed trust type distinctions (bare, interest in possession, etc.) removed |
| CHANGED | Trust type distinctions | ATX-UK A3d–A3e: define a trust; distinguish between different types of trust; IHT on trust property; occasion when IHT payable by trustees → Not present in STA as named outcomes |
| CHANGED | Variation of wills | ATX-UK A2g(v): CGT implications of variation of wills; A3d(viii): IHT effects and advantages of variation of wills → STA A3r: "Advise on the use of a deed of variation for IHT and CGT purposes [3]" — consolidated into one outcome |
| CHANGED | Lease vs hire purchase vs purchase | ATX-UK B3c: "explain the tax differences between decisions to lease, use hire purchase or purchase outright [3]" → STA B1p: retained, moved to owner managed businesses context [3] |
Syllabus Breakdown
Taxation of Individuals
Personal and family tax planning
- Evaluate the post-tax income generated by different sources of income, including marginal income tax calculations
- Evaluate the tax implications of investing in ISAs, debt, equity and property
- Evaluate the tax implications of contributions made to a pension scheme
- Evaluate the tax consequences of drawing a pension
- Advise on the tax implications of EIS, SEIS and VCTs
- Advise on income and capital tax planning opportunities for spouses/civil partners
Employment income
- Evaluate employment packages, including post-tax income calculation
- Advise on the tax treatment of termination payments and other lump sum receipts
- Assess whether a share scheme is tax advantaged
- Advise on the tax treatment of SAYE, CSOP, EMI, SIP, and non-tax advantaged share schemes
Capital taxes
- Advise on CGT implications of disposals of assets, including small part disposals of land, leases, wasting assets, and assets damaged/lost/destroyed
- Advise on CGT implications of disposals of shares, gilts and QCBs, including takeovers
- Advise on optimal use of annual exemption and capital losses to minimise CGT
- Assess post-tax proceeds available on a disposal of assets
- Advise on tax implications of differing dates of disposal and recommend appropriate disposal date
- Recommend courses of action to maximise post-tax proceeds/minimise tax payable
- Evaluate CGT reliefs: BADR (incl. associated disposals), investors' relief, gift holdover, rollover, private residence relief, incorporation relief, EIS/SEIS reinvestment relief, negligible value claims
- Advise on planning to minimise IHT due
- Recommend appropriateness of IHT reliefs: BPR, APR, fall in value relief, quick succession relief
- Advise on charitable donations for IHT including reduced rate for charitable giving
- Advise on gifts with reservation of benefit
- Advise on post-tax value of an inheritance
- Advise on value of gifts for CGT and IHT purposes
- Advise on CGT and IHT consequences of gifts during lifetime
- Advise on CGT and IHT consequences of transfers into a discretionary trust
- Advise on CGT and IHT consequences on gifts of assets left on death
- Recommend which choice of gift is more efficient for IHT and CGT
- Advise on use of a deed of variation for IHT and CGT purposes
- Recommend whether an asset should be gifted during lifetime or on death
- Advise on external finance required after post-tax proceeds/post-tax inheritance
Taxation of Businesses and Corporate Entities
Owner managed businesses
- Evaluate employed vs self-employed classification and tax consequences
- Recommend employee vs partner engagement and evaluate net tax cost of each
- Evaluate whether an individual is trading and the tax consequences
- Advise on appropriate business structure: sole trade vs partnership vs company
- Evaluate whether off payroll working rules apply and tax implications
- Evaluate the post-tax cost of a project
- Evaluate tax implications of revenue and capital expenditure
- Assess the post-tax income from a business
- Advise on best use of trading losses given business objectives
- Advise on tax implications of raising finance
- Advise on tax efficient withdrawal of funds from the business
- Advise on tax consequences of incorporation
- Evaluate close company status and advise on tax implications of close/CIHC
- Advise on tax implications of partial VAT exemption
- Advise on special VAT schemes for smaller businesses
- Evaluate tax differences between lease, hire purchase or purchase outright
Single companies
- Evaluate tax relief available on planned corporate expenditure
- Advise on tax planning for R&D spending
- Evaluate tax consequences of purchase, ownership, disposal and reinvestment in IFAs
- Advise on tax implications of sale of shares, land/buildings, plant/machinery and IFAs
- Advise on reliefs to reduce or defer tax on disposals
- Advise on tax implications of a company purchasing its own shares
- Advise whether a company has an investment business and calculate its CT
- Evaluate tax reliefs for losses and recommend optimal use: trading losses, property losses, capital losses, NTLR deficits
- Advise on restriction on use of losses on change in company ownership
Groups of companies
- Advise on allocation of AIA between group or related companies
- Advise on tax implications of transfer of intangible assets
- Advise on merits of forming a VAT group
- Evaluate tax reliefs for groups and consortiums and recommend optimal use of losses
- Advise on tax planning for chargeable gains groups
- Advise on impact of transfer pricing and thin capitalisation rules
Expansion, restructuring and winding up
- Evaluate which expansion strategy is more tax efficient, including post-tax cost calculation
- Advise on timing of expenditure to maximise tax relief
- Advise on tax implications of purchasing shares vs trade and assets of another company
- Advise on tax due on sale of shares including SSE
- Advise on sale of trade and assets including degrouping charge
- Evaluate tax implications of sale of shares in subsidiary vs sale of trade and assets
- Advise on tax implications of transfer of trade and assets under common control
- Advise on impact of corporate restructuring on CT rate and payment dates including group payment arrangements
- Evaluate best use of losses in a group restructuring
- Evaluate significance of accounting periods on administration or winding up
- Advise on tax implications of a company ceasing to trade
- Advise on tax implications of a company winding up
- Advise on tax treatment of returns to shareholders after winding up
Overseas Tax Issues
Individuals
- Advise on residence and its relevance to income tax and CGT
- Advise on the FIG regime for qualifying UK tax resident individuals for IT and CGT
- Advise on tax position of individuals coming to and leaving the UK for IT and CGT
- Advise on income tax treatment of overseas trading, employment and investment income
- Advise on UK taxation of foreign gains
- Advise on UK taxation of gains on disposal of UK land/buildings owned by non-residents
- Advise on long-term UK residence in relation to IHT
- Evaluate whether an individual is LTR or non-LTR and advise on UK IHT
- Advise on double taxation relief available to individuals
Companies
- Evaluate tax residence of a company and advise on impact on UK CT payable
- Advise on consequences of setting up an overseas permanent establishment and elections to mitigate tax
- Advise on tax consequences of setting up an overseas subsidiary
- Advise on tax consequences of a UK resident company receiving overseas income
- Advise on tax position of overseas companies trading in the UK
- Advise on double taxation relief available to companies
- Evaluate impact of an overseas company within a group on group tax planning
- Advise on VAT implications of imports and exports
- Evaluate whether a company is a CFC and advise on tax implications
Tax Compliance and Ethical Obligations
Tax compliance
- Advise on when tax returns should be made, when tax should be paid, consequences of late filing/payment, and associated interest and penalties
- Evaluate how a taxpayer's actions could impact how much tax is due and when it should be paid
- Assess the time limits for any relevant claims or elections recommended
Ethical obligations
- Recommend appropriate safeguards to threats to the fundamental principles of the ACCA Code of Ethics and Conduct
- Evaluate potential conflicts of interest and advise on actions to be taken
- Advise on appropriate procedures and actions when taking on a new client
- Advise on actions to be taken on discovery of an error in a tax return/unexpected refund
- Advise on tax avoidance and tax evasion and associated penalties
Professional Skills
Communication
- Inform concisely, objectively and unambiguously, adopting a suitable style and format
- Advise using compelling and logical arguments, demonstrating ability to counter argue
- Clarify and simplify complex issues for the intended audience
Analysis and evaluation
- Investigate relevant information from a range of sources using appropriate analytical techniques
- Consider information, evidence and findings carefully, reflecting on implications
- Assess and apply appropriate judgement on ethical, professional or technical issues
- Appraise information objectively to prioritise issues, identify missing information and explore alternatives
Scepticism
- Explore underlying reasons for issues, applying a questioning mind beyond what is immediately apparent
- Question opinions, assertions and assumptions by seeking justifications and sufficient evidence
- Challenge and critically assess information or decisions where justified in the wider professional, ethical or public interest
Commercial acumen
- Demonstrate awareness of organisational, external and non-tax factors affecting tax decisions
- Recognise key issues and use judgement in proposing commercially viable solutions
- Show insight and perception in understanding key tax drivers, demonstrating acumen in recommendations




