Strategic ProfessionalOptions

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.

FormatSession CBE · 3 hours 15 minutes · 100 marks

Pass Mark50%

Legacy PaperATX-UK — Advanced Taxation (United Kingdom)

Sections5 sections (A, B, C, D, E)

Current-syllabus equivalentOur paper mapping links STA to ATX — Advanced Taxation. The current structure's last sitting is June 2027.

Transition Planner

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

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