17 October 2025
Welsh Budget presented
On 14 October 2025, the Welsh government presented its proposed Budget for the 2026-27 tax year. As in previous years, the Welsh government proposes to keep the devolved rates of income tax applicable to the non-savings, non-dividend income of taxpayers resident in Wales aligned with England and Northern Ireland. While no changes are proposed to the residential and non-residential rates and thresholds for Land Transaction Tax (LTT), the government announced plans to make further changes to Multiple Dwelling Relief (MDR). In addition, a new refund rule for the higher residential rates of LTT will be introduced and will apply where a private landlord leases a dwelling to a local authority through Leasing Scheme Wales. The government also announced plans to review the effectiveness of the existing LTT relief for registered social landlords and consider the appropriateness of an equivalent relief for local authorities buying property for social housing purposes.
HMRC appoint Research and Development Expert Advisory Panel
On 15 October 2025, HMRC announced the appointment of a new Research and Development Expert Advisory Panel (RDEAP) to provide sectoral insight and guidance to support the administration of R&D tax reliefs. The establishment of a panel was first announced at Spring Budget 2024, and the new government confirmed that it would proceed with the RDEAP in the Corporate Tax Roadmap. A new page on the RDEAP has been added to GOV.UK, which includes the panel’s terms of reference. The RDEAP comprises of six external appointees from across business, a Chair and Secretariat from HMRC’s Corporation Tax Innovation and Growth, as well as further representatives from HMRC and other government departments by invitation. The panel’s role includes providing insights into cutting-edge R&D to enhance HMRC’s understanding, reviewing existing guidance, and providing sectoral feedback to HMRC on R&D tax reliefs.
EU updates list of non-cooperative jurisdictions
EU finance ministers have confirmed the latest EU list of noncooperative jurisdictions for tax purposes (Annex I) and the ‘state-of-play’ document (Annex II). Jurisdictions are analysed by the European Council twice a year based on certain agreed criteria. Those that fail to meet the criteria are included in Annex I; whilst countries that have made acceptable commitments to modify their tax legislation are included in Annex II. Compared to the previous version of February 2025, there are no changes to Annex I, which comprises: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Russia, Samoa, Trinidad & Tobago, the US Virgin Islands, and Vanuatu. Four jurisdictions, Greenland, Jordan, Montenegro and Morocco, have been added to Annex II, and Vietnam has been removed. The updated Annex II now comprises: Antigua & Barbuda, Belize, the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Seychelles and Türkiye.
OECD framework for the automatic exchange of readily available information on immovable property for tax purposes
On 15 October 2025, the OECD published a report titled Framework for the Automatic Exchange of Readily Available Information on Immovable Property for Tax Purposes. The report contains the text of a voluntary competent authority agreement – the Multilateral Competent Authority Agreement on the Exchange of Readily Available Information on Immovable Property (IPI MCAA) – which could facilitate the exchange of ‘Readily Available Information’ on immovable property transactions, holdings and recurrent income, between the tax authorities of interested jurisdictions. The IPI MCAA includes two modules for interested parties to consider opting into. The first module focuses on ownership visibility, including a one-off exchange of information on immovable property holdings and subsequent annual automatic exchanges on acquisitions. The second module focuses on enhancing transparency on income from immovable property, with annual automatic exchanges of information on disposals and recurrent income.
OECD publishes Inclusive Framework stocktake report on the BEPS Initiative
On 15 October 2025, the OECD Inclusive Framework released a report titled A Decade of the BEPS Initiative: An Inclusive Framework Stocktake Report to G20 Finance Ministers and Central Bank Governors. The report looks at the progress made in implementing the Base Erosion and Profit Shifting (BEPS) Package over the past decade, and the economic impact of those changes. The report finds that significant progress has been made in implementing the four BEPS Minimum Standards (Action 5 – countering harmful tax practices, Action 6 – prevention of tax treaty abuse, Action 13 – country-by-country reporting (CbCR), and Action 14 – mutual agreement procedures (MAP)), and “widespread and impactful” implementation of non-minimum standards.
The report highlights evidence pointing towards the positive impact of the BEPS Initiative, including the better alignment of profits and substance, a decline in the sensitivity of the location of profits to tax rates, stabilisation of statutory corporate tax rates in the last five years, greater transparency surrounding the tax planning of multinational groups, and a steady expansion in the use of MAP to resolve disputes. However, the report identifies that there is “more work to do”, with data showing that “taxation is still not entirely aligned with the place of value creation”.
Lands Luo Limited: Application for late appeal
The First-tier Tribunal (FTT) has considered an application to make a late appeal. Unusually, the tribunal included Lord Justice Dingemans, Senior President of Tribunals, in addition to the tribunal judge and tribunal member. Lands Luo Limited (LL) applied for permission to make a late appeal to the FTT against an HMRC decision to deny repayment of an input tax claim. The FTT considered whether LL had made an application to appeal in time, and concluded that the documents LL provided or purported to provide to HMRC did not constitute a request to appeal. Accordingly, LL needed permission to bring a late appeal. The FTT noted that it had a duty to apply the Upper Tribunal’s (UT’s) relevant decisions, but that the UT had set out different approaches to this issue in its decisions in Martland and Medpro Healthcare Limited. The FTT doubted that the different approaches would lead to different results in many cases. The three-stage test for determining whether to grant permission is common ground between the two decisions, but Martland set out a stricter approach. The FTT considered it should apply Martland, as the approach is consistent with the Court of Appeal’s approach in BPP Holdings Limited, which was affirmed, or permitted, by the Supreme Court. On that basis, the FTT concluded that LL should be permitted to appeal out of time. The FTT then cross-checked the decision against the Medpro approach, and confirmed that the conclusion would have been the same. The UT also recently considered the two approaches in Tajinder Pawar, concluding that it should follow Medpro as it was the more recent decision. The UT in Tajinder Pawar noted that HMRC were considering whether to apply for permission to appeal Medpro, and the issue may therefore be resolved at a higher court. (Contact: Rob Holland)
EMEA Dbriefs webcasts
As a reminder, the next EMEA Dbriefs tax webcast is on Monday 20 October 2025 at 12.00 BST/13.00 CEST. In Global trade update, hosted by Amanda Tickel, our panel will share insights into navigating the complexities of the evolving global trade environment. We will discuss the latest developments in global trade and their impact, how companies are adapting to higher US tariffs, and the implications for tax and transfer pricing strategies.
On Thursday 23 October 2025 at 12.00 BST/13.00 CEST Mike Thorne will be hosting Understanding US listings. In the webinar our panel will discuss current market sentiment and factors to consider for US listings, as well as sharing key insights and the practical implications for tax, executive remuneration, finance, controls and transaction management.