14 November 2025
New tax treaties with Andorra and Portugal: UK ratification progress update
Draft Statutory Instruments have been laid before the House of Commons in respect of the new UK-Andorra Double Taxation Convention and the new UK-Portugal Double Taxation Convention and Protocol. Each draft Statutory Instrument is accompanied by a draft explanatory memorandum (Andorra, Portugal), which includes brief HMRC commentary on each article of the treaty. The new UK-Andorra tax treaty, signed in February 2025, will be the first double taxation agreement between the UK and Andorra. The new UK-Portugal tax treaty, signed in September 2025, will replace the existing 1968 treaty once in force. The next stage in the UK ratification process is consideration by a House of Commons Delegated Legislation Committee, for which no timing has yet been announced. Each treaty will enter into force after both countries complete their domestic parliamentary procedures for ratification and notify each other accordingly.
BEPS MLI – Montenegro signs
The OECD has announced that Montenegro signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) on 12 November 2025, becoming the 107th jurisdiction to join the BEPS MLI. Montenegro’s provisional list of notifications is available here. In respect of Montenegro the 1981 UK/Yugoslavia Double Taxation Convention is regarded as having remained in force. It is expected that the operation of the treaty will be modified in due course once the MLI is ratified by Montenegro.
RCB 6 (2025): VAT deduction on insurance intermediary services supplied outside the UK
HMRC have published Revenue and Customs Brief 6 (2025) on input tax recovery for insurance intermediary services supplied outside the UK, following the First-tier Tribunal (FTT) decision Hastings Insurance Services Ltd. Although insurance intermediary services are VAT exempt, the EU Principal VAT Directive (PVD) allows input tax recovery for services supplied to customers outside the EU. This was implemented in the UK in the Value Added Tax (Input Tax) (Specified Supplies) Order 1999. In 2019, the Order was amended so that UK insurance intermediaries were only able to recover VAT where the party insured was based outside the UK. In Hastings, the FTT found that the 2019 amendment was incompatible with the PVD, and Hastings was able to rely on the direct effect of the PVD to recover input tax.
In RCB 6 (2025), HMRC accept that insurance intermediaries can rely on the direct effect of EU law “to recover relevant input tax incurred prior to 1 January 2024, whether the insured party is in the UK or not”. However, the RCB gives HMRC’s view that, from 1 January 2024, the provisions of the Retained EU Law (Revocation and Reform) Act 2023 mean that direct effect can no longer be relied upon, and UK legislation cannot be disapplied on the basis that it is inconsistent with EU law. The RCB states that under section 28, Finance Act 2024, UK VAT law will continue to be interpreted in the same way as it was before 1 January 2024, with the exception that it is no longer possible to rely on the direct effect of EU law. Insurance intermediaries affected by the RCB are invited to review their input tax recovery and make a claim for under-recovered input tax if appropriate.
EMEA Dbriefs webcasts
An EMEA Dbriefs legal webcast Employment Rights Bill update: The Fair Work Agency and the evolving enforcement landscape for workers’ rights, will take place on Thursday 20 November 2025 at 12.00 GMT/13.00 CET. The webcast, hosted by Kathryn Dooks, will cover significant upcoming changes to the enforcement of worker rights over the next 12-24 months. Our panel will discuss topics including the implications of the formation of the Fair Work Agency and the proposed enforcement powers for holiday pay, sick pay and national minimum wage, strategic shifts in The Pensions Regulator's enforcement approach, and proactive measures businesses can take to mitigate risk.
The Chancellor of the Exchequer, Rachel Reeves, will present her Budget on Wednesday 26 November 2025. This will be accompanied by an update from the Office for Budget Responsibility (OBR) on the latest state of the country’s finances. The Chancellor will face the challenge of addressing the fiscal gap while simultaneously aiming to boost growth and encourage investment. For insights on the Budget announcements, visit our Autumn Budget 2025 page. There will be an EMEA Dbriefs webcast on Thursday 27 November 2025 at 12.00 GMT/13.00 CET, hosted by Amanda Tickel, Deloitte’s Global Head of Tax and Trade Policy, during which our panel of experts will provide an update on the previous day’s announcements and their implications for businesses and individuals.