12 September 2025
HM Treasury publishes interim report on transforming business rates
On 11 September 2025, HM Treasury published the Transforming Business Rates: Interim Report. The interim report includes a summary of engagement on the discussion paper, published at Autumn Budget 2024, as well as the government’s response and next steps. The interim report sets out the government’s priority areas for further exploration to improve the operation of the business rates system and incentivise investment and growth, including consideration of a new business rates structure based on marginal tax rates. The government will also consider, inter alia, enhancing small business rates relief and improvement relief. The report emphasises that it does not represent a set of policy decisions, and states that the government will provide a further update on its plans to reform the business rates system, including details of a transitional relief package for the 2026 revaluation, at the Autumn Budget.
Corporate Criminal Offences statistics updated
The Corporate Criminal Offences (CCO) for the failure to prevent the facilitation of tax evasion were introduced by the Criminal Finances Act 2017. HMRC have this week updated their statistics on compliance activities in relation to CCO investigations. As at 30 June 2025, HMRC had 11 live CCO investigations, with one charging decision secured. A further 27 identified cases were under review as to whether they should proceed to an investigation. The cases identified span 13 business sectors. To date, HMRC have reviewed and rejected an additional 121 cases, however HMRC note that some of these previous investigations have led to satisfactory explanations that have caused CCO investigations to be dropped but have instead led to other potential tax and regulatory offences being pursued.
HMRC publish MLI synthesised texts of Vietnam and Thailand tax treaties
HMRC have published new ‘synthesised texts’ showing how the operation of the 1994 UK-Vietnam Double Taxation Agreement and the 1981 UK-Thailand Double Taxation Convention are modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’).
OECD publishes annual report on tax policy reforms
The OECD has published the latest in its annual series of tax policy reports, Tax Policy Reforms 2025. The report describes tax reforms announced and enacted in 2024 across 86 OECD and Inclusive Framework jurisdictions, and highlights how governments have continued to move away from broad tax relief measures, instead focussing on reforms to raise revenues for specific spending needs, such as those relating to climate change. This year’s report highlights data suggesting that a recent trend of decreasing corporate income tax rates has continued to reverse, with more jurisdictions implementing corporate tax rate increases than decreases for the second consecutive year.
Jersey multinational corporate income tax registration now open
The registration portal for Jersey’s new 15% domestic ‘multinational corporate income tax’ (MCIT) is now open. MCIT registration will be required in respect of all Jersey entities that are part of an in-scope Pillar Two multinational group. Registration with Revenue Jersey should be completed by the group’s ‘Jersey reporting entity’ or an agent authorised to act in relation to MCIT. MCIT registration will be required before the end of the first accounting period starting on or after 1 January 2025. For further details see tax@hand.
Prudential Assurance Company Ltd: VAT groups and continuous supplies
In November 2007, Silverfleet Capital Ltd completed a management buy-out and left the Prudential VAT group. Since 2002 it had been providing fund management services to one of Prudential’s with-profits funds, and was entitled to a performance-related fee in the event that the fund exceeded certain benchmarks. Those benchmarks were eventually met in 2014 and 2015, triggering performance payments of £9.3m. Given that Silverfleet carried out its fund management services before it left the VAT group, but received payment several years afterwards, should it charge VAT? Silverfleet’s management qualified as a continuous supply of services, and HMRC therefore considered that VAT had to be charged by reference to when the performance fee was invoiced and paid.
The Supreme Court has found in favour of HMRC that VAT should be chargeable. The Supreme Court found that the purpose of the VAT grouping provisions is to promote organisational fiscal neutrality between corporate groups, but that it must be read alongside the time of supply rules. In this case, Regulation 90 of the 1995 VAT Regulations provides that continuous supplies of services are treated as separately and successively supplied at the earlier of each time payment is made or a VAT invoice is issued, and the UK law does not go further than is permitted by the relevant provisions of the EU Principal VAT Directive. This meant that there was a chargeable event when the invoice for the success fee was issued or paid, and that was when Prudential and Silverfleet were no longer in the same VAT group. There is no basis for inferring a separate rule for VAT groups that depends on when the services were actually performed. (Contact: Andrew Clarke)
EMEA Dbriefs webcasts
The next EMEA Dbriefs tax webcast is on Wednesday 24 September 2025 at 12.00 BST/13.00 CEST. In Tax Transformation Trends 2025, hosted by James Paul, our panel will discuss Deloitte's latest Tax Transformation Trends report, based on a survey of over 1,000 senior tax and finance leaders. We will consider topics including the increasing demand for granular data, cost pressures, strategic adoption of AI, and the rise of outsourcing.