24 October 2025
New UK-Portugal double tax treaty published
On 17 October 2025, the English language text of the new 2025 UK-Portugal Double Taxation Convention and Protocol, signed on 15 September 2025, was published on GOV.UK. The new treaty includes several changes of note when compared to the existing 1968 UK-Portugal Double Taxation Convention (as modified by the BEPS Multilateral Instrument), including to the dividends, interest, and capital gains articles.
The new treaty will enter into force after both countries complete their domestic parliamentary procedures for ratification and notify each other accordingly. Following ratification, individual articles will then take effect in the UK and Portugal in accordance with the timings set out in Article 28.
UK lists of countries with qualified status for Pillar Two purposes updated
HMRC have updated their notice to specify further countries with a qualified income inclusion rule (IIR) and/or a qualifying domestic top-up tax (QDMTT) that meets safe harbour standards. The update follows changes to the OECD Inclusive Framework’s central record of countries whose local implementation of the Pillar Two rules have so far been assessed as ‘qualified’ in August 2025. Additions to HMRC’s list of countries with a QDMTT that meets safe harbour standards include Brazil, Gibraltar, the Isle of Man, Japan and Singapore. Additions to the list of countries with a qualified IIR include Gibraltar, the Isle of Man, Jersey, Singapore and Switzerland.
OECD publishes updated transfer pricing country profiles
The OECD has published updated transfer pricing country profiles reflecting the current transfer pricing legislations and practices of various countries. Included is an updated profile for the UK. According to the OECD, the profiles focus on countries' domestic legislation regarding key transfer pricing aspects, including the arm's length principle, methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures. The updated profiles include new sections on the simplified and streamlined approach for baseline marketing and distribution activities (resulting from the work on Amount B of Pillar One) and the transfer pricing treatment of hard-to-value intangibles.
New profiles have been published for Cabo Verde, Guatemala, Thailand, the United Arab Emirates, and Zambia. In addition to the UK, updated profiles have also been published for Argentina, Australia, Chile, China, the Czech Republic, Estonia, Finland, France, Germany, Hungary, Italy, Japan, Kenya, Malta, Nigeria, Peru, Poland, Portugal, Romania, Slovenia, Sweden, Switzerland, Ukraine, and the US.
Late claims for input tax – HMRC manual
HMRC have amended their VAT Input Tax internal manual to update their guidance on How to treat input tax: late claims for input tax. The new guidance includes the circumstances in which HMRC will exercise their discretion to allow late claims for input tax. As well as situations where the supporting evidence has not been received, late claims will be allowed where the business has been carrying out due diligence to get their tax affairs right, and where the late claim is due to internal accounting procedures and governance (such as a cut-off date for processing invoices). HMRC will allow late input tax claims in these circumstances and in specific cases, provided HMRC are satisfied that late claims would not lead to input tax being overclaimed or less VAT being payable than if the input tax was claimed in the proper period. HMRC will not allow late claims where there is evidence of careless error or repeated late claims. (Contact: Andrew Clarke)
EMEA Dbriefs webcasts
The next EMEA Dbriefs tax webcast is on Tuesday 28 October 2025 at 12.00 GMT/13.00 CET. In The UK's new R&D tax reliefs - What do you need to know? hosted by Sarah Lord, our panel will discuss significant changes to the UK's R&D tax reliefs. We will cover the new merged R&D expenditure credit (RDEC), enhanced relief for R&D-intensive loss-making SMEs (ERIS), the new rules on contracted-out R&D and the overseas exemption. We will consider the additional complexities as companies transition into the new regime, as well as HMRC’s administration of the reliefs.