Land Remediation Relief (LRR): HM Treasury Proposes Major Reforms

In July 2026, HM Treasury issued a consultation paper detailing structural options to reform Land Remediation Relief (LRR). Governed by Part 14 of the Corporation Tax Act 2009, LRR provides an additional 50% deduction for eligible revenue expenditure (150% total) and a 150% deduction for eligible capital expenditure, with loss-making companies able to claim a 16% cash tax credit.  

Following initial reviews, the government concluded that while LRR benefits heavily contaminated or marginally viable sites, it is not fully achieving its goal of driving brownfield remediation. The proposed reforms aim to make the regime clearer, more accessible, and closely aligned with practical development processes.  

What are the benefits of Land Remediation Relief?

Land Remediation Relief (LRR) is a UK corporation tax incentive designed to encourage the redevelopment of contaminated and derelict land.It provides up to 150% tax deduction to companies in order to incentivise them to remediate dereliction or contamination such as asbestos, ground gases, hydrocarbons and other contaminants where they were caused as a result of industrial activity or natural contaminants such as Japanese knotweed, radon, and arsenic. 

The remediation works may form part of new developments or remediation of existing properties. This means that companies can deduct the value of the qualifying LRR costs from their profit, whilst calculating their tax liability. 

Other key points are as follows:

• Developers who treat their expenditure as revenue cost already deductible for tax purposes can claim 50% uplift instead of 150%.
• The 150% tax deduction is equivalent to 37.5% tax saving benefit (37.5p for every £1 spent) based on the current 25% Corporation Tax rate.
• The 50% uplift tax deduction is equivalent to 12.5% tax saving benefit (12.5p for every £1 spent) based on the current 25% Corporation Tax rate.
• As opposed to a tax reduction, the relief can take the form of a 16% tax credit (cash receipt) to the company if losses arise because of the qualifying LRR.

Key pillars of the proposed reform package 

1. Aligning tax rules with planning processes 

Under current legislation, proving land contamination for tax purposes requires navigating standalone tax definitions that often conflict with local planning frameworks. To eliminate this duplication, the government proposes aligning Land Remediation Relief (LRR) directly with established environmental and planning definitions:  

• Projects requiring planning permission: Developers undertake site remediation in accordance with local council planning conditions. The formal discharge notice issued by the Local Authority upon completion serves as the required evidence to support the LRR claim submitted to HMRC.  
• Projects not requiring planning permission: Remediation work that falls outside the planning system remains eligible for LRR. HMRC will maintain a streamlined list of qualifying contaminants, allowing businesses to claim directly provided they did not cause the pollution (adhering to the ‘polluter pays’ principle).  

2. Modernising derelict land rules 

The government recognises that requiring land to have been continuously derelict since 1^st April 1998 has become an arbitrary restriction:  

• Removal of the 1998 cut-off: The 1998 requirement will be removed and replaced with a new statutory definition of a “derelict state” to prevent abuse.  
• Revised dereliction definition: Land will qualify if buildings or structures prevent productive use due to abandonment, redundancy, substantial damage, structural unsoundness, or advanced disrepair. Merely vacant, underused, or land held for future development by the same entity for over 5 years will be explicitly excluded.  
• Restructured relief rates: Sites made derelict up to 2027 will qualify for the 150% relief rate. To prevent land price inflation, expenditure on sites that become derelict after 2027 will qualify for a 100% deduction. 

3. Accelerating relief timing for property developers 

Under current tax rules, property developers must hold remediation costs as trading stock (Work in Progress), deferring tax relief until the completed properties are sold, resulting in an average lag of 3 to 5 years.  

• Immediate year-incurred election: The proposed reform introduces an elective option allowing developers to deduct qualifying LRR revenue expenditure in the period the expense is incurred rather than at the point of sale.  
• Accounting treatment: The elected spend is deducted from the Work in Progress balance in the accounting period. A deferred tax liability is recognised on the balance sheet to account for the timing difference, which unwinds when the units are eventually sold. 

Consultation and legislative timeline 

How Leyton can help

The proposed package represents a fundamental shift in how land remediation tax relief is structured and claimed. At Leyton, we are closely monitoring these legislative developments to help our clients navigate changing eligibility criteria. 

To discuss how these upcoming changes could affect your current or planned projects, contact the Leyton team today. 

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