13 February 2026
HMRC manuals: deferred remuneration
HMRC have updated the part of their manuals (see INTM163155) covering the income tax treatment of deferred remuneration under a double tax treaty. It sets out how such remuneration (e.g. bonus or share options) should be taxed when employees change their state of residence before receiving the remuneration, clarifying that the UK’s right to tax such income depends on whether it is the state of source or the state of residence under the treaty at the time the remuneration is received.
National Insurance Contributions Bill: progress update
The National Insurance Contributions (Employer Pensions Contributions) Bill, which will create a power for the Treasury to apply NICs to salary-sacrificed pension contributions that exceed £2,000 per annum from April 2029, had its Second Reading in the House of Lords on 4 February 2026. The Bill will now proceed to its Lords Committee stages. The first sitting of the Grand Committee is scheduled for 24 February 2026.
HMRC publish new Guidelines for Compliance on group structure information
On 9 February 2026, HMRC published the latest in their Guidelines for Compliance (GfC) series. GfCs are intended to help taxpayers and their advisers understand HMRC’s view on particular issues and include best practice examples. New GfC17, Help with sharing group structure information, sets out guidance for businesses to use when sharing information about their group structure and transactions with HMRC. The GfC includes the information HMRC need to understand a group or transaction, and details on standard symbols and shapes.
UK double tax conventions: synthesised texts published
HMRC have published new ‘synthesised texts’ showing how the operation of the 1996 Argentina-UK Double Taxation Convention, 1994 Azerbaijan-UK Double Taxation Convention, and 2013 UK-Panama Double Taxation Convention are modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’).
According to HMRC, unless stated otherwise in the relevant document, the provisions of the MLI have effect with respect to the Conventions as follows:
UK-India social security agreement
On 11 February 2026, the UK government published the UK-India Double Contributions Convention (DCC). This agreement, similar to existing DCCs, aims to prevent double social security contributions for eligible employees temporarily working in the other country for up to 36 months. Businesses will need to apply for a Certificate of Coverage (CoC) to confirm home country social security participation once the agreement is in force. The DCC includes provisions for remote work by personal choice with employer agreement, allowing CoCs for such arrangements. HMRC anticipate that the DCC will come into effect “by summer 2026”.
Welsh government announces non-domestic rates relief for food and drink hospitality
On 3 February 2026, the Welsh government published a written statement on non-domestic rates relief for food and drink hospitality in 2026-27. According to the statement, the Welsh government will provide relief for food and drink hospitality properties, including pubs, restaurants and live music venues. Eligible ratepayers will receive 15% non-domestic rates relief in 2026-27, capped at £110,000 per business across Wales. The UK government announced a new business rates relief for pubs and live music venues in England earlier this year (see our previous Business Tax Briefing).
CBAM: Draft regulations and policy summary
The Carbon Border Adjustment Mechanism (CBAM) will place a carbon price on specified goods imported into the UK. CBAM will come into effect on 1 January 2027. CBAM seeks to ensure that “highly traded, carbon intensive products from jurisdictions outside the UK face a comparable carbon price to that paid by UK manufacturers, so that UK decarbonisation efforts lead to a true reduction in global emissions rather than simply displacing carbon emissions overseas.” HMRC have published a consultation on draft CBAM regulations seeking feedback from stakeholders to ensure the regulations deliver the policy correctly and effectively for CBAM to operate as intended. The draft regulations deal with the administrative aspects of CBAM, including registration, returns, and record keeping, and the determination of the calculation of the CBAM rate and carbon price relief. The consultation will close on 24 March 2026. HMRC have also issued a policy summary on how CBAM will operate, including the core policy framework set out in Finance (No.2) Bill 2024-26 and details set out in the draft regulations and notices. The document will be updated to reflect future changes. (Contact: Zoe Hawes)
EMEA Dbriefs webcasts
The next EMEA Dbriefs webcast will take place on Monday 23 February at 17.00 GMT/18.00 CET. In Navigating EU Pay Transparency: Essential readiness for US companies with EU operations, hosted by Deepinder Lampa, our panel will discuss the EU Pay Transparency Directive. Our EU Pay Transparency specialists will cover a range of topics to help organisations think through their readiness ahead of June 2026, including the impact of the Directive on US multinationals, key reporting obligations, the transposition status of the Directive, operational impacts, and developing a compliance roadmap.