18 September 2026
Pillar Two: updated information return and further administrative guidance
On 11 September 2026, the G20/OECD Inclusive Framework published a collection of documents in relation to the Pillar Two global minimum tax rules. These include an updated GloBE information return (GIR) template for use for 2026 year ends onwards, further administrative guidance to address (i) the treatment of ‘explicitly conditional taxes’ and (ii) the use of local financial accounting standards under a qualified domestic minimum top-up tax (QDMTT), and the terms of reference and methodology for the full legislative review of countries’ implementing legislation. Further details are in Deloitte’s alert.
HMRC publish creative industries tax relief statistics
On 17 September 2026, HMRC published their creative industries tax relief statistics for financial years up to 31 March 2025. The statistics include the number and value of claims for film, high-end TV, animation, children’s TV, video games, theatre, orchestra, and museums and galleries exhibition tax reliefs. The latest statistics also include claims made for the new audio-visual expenditure credits (AVEC) and video game expenditure credits (VGEC). In 2024/25 a total of £2.45 billion of relief was paid out across all creative industries tax reliefs and expenditure credits, with over a third (38%) attributable to high-end TV tax relief (including AVEC) and 29% to film tax relief (including AVEC and independent films).
OECD launches new version of INNOTAX portal
The OECD has announced the launch of a new version of the INNOTAX portal. The INNOTAX portal provides information on the availability, design, generosity and cost of tax incentives that support research and development (R&D) and innovation in over 50 countries. The updated portal covers both expenditure-based incentives and income-based R&D tax incentives, such as patent boxes and innovation boxes.
HMRC publish Guidelines for Compliance 20: Help with VAT on fund management services
HMRC have issued a new Guidelines for Compliance (GfC), Help with VAT on fund management services — GfC20. The GfC sets out HMRC’s recommended approach to determining the VAT treatment of outsourced fund management services, and in particular, whether such services should be treated as a single supply or multiple supplies. Fund managers frequently outsource fund management services to third parties, often under master service agreements (MSAs), with separate contracts for more detailed information regarding services and fees for individual funds.
The GfC states that a supply of services by a third party to a fund manager is only VAT exempt if the fund is a ‘qualifying fund’ and the services form a distinct whole that is specific to and essential for the management of that qualifying fund. This places significant focus on the single/multiple supply analysis, given that each supply can only have a single VAT liability – and many taxpayers will be looking to avoid a situation where a single supply of management services is made in relation to both qualifying and non-qualifying funds, resulting in the whole supply being treated as taxable. The GfC sets out four indicators to consider in determining whether a supply with multiple elements constitutes multiple supplies, namely: the number of suppliers; the view of the typical customer; the contractual terms and economic reality; and the legislative intention (that is, “these rules must not be used to extend the VAT exemption beyond what the law allows”). The GfC concludes that businesses providing fund management services can use the guidelines to help determine whether the supply of services is a single supply or multiple supplies, and then apply the VAT exemption rules accordingly. (Contact: Alex Beattie)
EMEA Dbriefs webcasts
The next EMEA Dbriefs webcast will take place on Wednesday 23 September 2026 at 14.00 BST/15.00 CEST. In EU Pay Transparency in Practice: Taking Stock and Taking Action, we will bring together Deloitte specialists from across Europe to discuss the latest developments in relation to the EU Pay Transparency Directive. We will cover EU Member States’ progress in implementing the Directive into national law, lessons emerging from early movers and the actions employers should be prioritising as 2027 approaches.