29 May 2026
Global minimum tax: Updated 2026 version of consolidated commentary released
On 28 May 2026, the OECD/G20 Inclusive Framework on BEPS published an updated version of its consolidated commentary to the Pillar Two global minimum tax model rules. The consolidated commentary was last updated in May 2025. The updated version incorporates administrative guidance approved and published by the OECD Inclusive Framework up to May 2026, including the guidance contained in the ‘side-by-side package’ of 5 January 2026, and the brief further administrative guidance published earlier in May 2026 on the application of the transitional UTPR safe harbour to groups with 52-53 week fiscal years. Please see Deloitte tax@hand for more details.
HMRC manuals: UK-India social security agreement
HMRC have added a section to their National Insurance Manual (see NIM33250) on the new UK-India Double Contribution Convention (DCC). The 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 new manual pages include clarification that employees already on secondment between the UK and India at the point the agreement comes into force will not be eligible for a CoC. In addition, HMRC state that an employee of a UK company working in India who ceases to be liable to mandatory National Insurance Contributions (NIC) will not be eligible to pay voluntary UK NIC. Other areas covered include potential split liability scenarios and possible exceptions to the normal rules under the convention. (Contact: Tony Woodcock or Laura Benn)
HMRC statistics: VCTs, EIS and SEIS
HMRC have published the latest update in their series of Venture Capital Trusts (VCTs) statistics and Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS) statistics, covering the first estimates for the 2024-25 tax year. VCTs issued shares to a value of £881 million in 2024-25 (2023-24: £872 million). The number of VCT investors who claimed income tax relief decreased by 8% to 22,430, however the total amount of investment on which they claimed tax relief increased by 1% to £825 million.
In 2024-25, 3,735 companies raised a total of £1,575 million under the EIS. The number of investors claiming income tax relief through Self Assessment under the EIS decreased to 33,220 in 2024-25 (2023-24: 35,675); the total investment on which tax relief was claimed also decreased. The amount raised under the SEIS increased by 14% to £276 million in 2024-25 (2023-24: £242 million), which HMRC attribute to relaxations to SEIS qualification limits, effective since April 2023. In 2024-25, the number of investors claiming income tax relief through Self Assessment under the SEIS increased to 11,200 (2023-24: 10,290), and the amount of relief claimed increased by 3%.
Advisory fuel rates
On 22 May 2026, HMRC published the new advisory fuel rates for company cars applicable from 1 June 2026. The previous mileage rates, effective from 1 March 2026, can be used for up to one month from the date the new rates apply. The rates for all diesel, petrol and LPG engine sizes have increased from the previous quarter. The advisory electricity rates for home charging and public charging are unchanged from the previous quarter.
HMRC publish MLI synthesised text of UK tax treaty with Ukraine
HMRC have published a new ‘synthesised text’ showing how the operation of the 1993 UK-Ukraine Double Taxation Convention as amended by the 2017 Protocol is modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’).
According to the text, unless stated elsewhere in the document, the provisions of the MLI have effect with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; in the UK, from 1 April 2021 for corporation tax and from 6 April 2021 for income tax and capital gains tax; and with respect to all other taxes levied by Ukraine, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
Call for input on tariff suspensions
On 27 May 2026, the government published a call for input on a proposed list of goods for temporary tariff suspension. The indicative list covers three categories of goods: agri-foods (including olive oil, chocolate, and certain fruits), fertilisers and kerosene. Where implemented, suspensions would apply on a most favoured nation basis and would expire in December 2028, except for fertilisers which would be subject to a one-year suspension.
The government has been considering targeted tariff relief since March 2026, when the Chancellor announced work to assess where suspensions could help mitigate the impact of rising costs for food and energy. A first tranche of agri-food tariff suspensions (including certain fruit and juices) was announced in April 2026 and will be implemented in the coming weeks. The government states that its final decision on tariff suspensions will weigh the potential consumer benefit against implications for domestic producers, food security and international commitments. The government is also inviting suggestions for additional products not currently included in the indicative list. The call for input closes on 24 June 2026.
EMEA Dbriefs webcasts
As a reminder, the next EMEA Dbriefs webcast will take place on Wednesday 10 June 2026 at 12.00 BST/13.00 CEST. In UK tax update - June, our panel will discuss topical tax developments of relevance to UK businesses in relation to corporate taxes, employment taxes and indirect taxes.