5 September 2025
Date of Autumn Budget confirmed
On 3 September 2025, the Chancellor of the Exchequer, Rachel Reeves MP, announced that the Autumn Budget will take place on Wednesday 26 November 2025. The Budget will be presented alongside the latest economic and fiscal forecasts commissioned from the Office for Budget Responsibility (OBR). HM Treasury is inviting Budget representations from interested stakeholders until 15 October 2025.
HMRC publish Guidelines for Compliance on checking documents filed with HMRC are correct and complete
On 1 September 2025, HMRC published the latest in their Guidelines for Compliance (GfC) series. GfCs are intended to help taxpayers and their advisers understand HMRC’s view on particular issues and include best practice examples. New GfC13, Help ensuring documents filed with HMRC are correct and complete sets out HMRC’s view on the meaning of ‘correct and complete’. HMRC state that their policy has not changed and that they expect most taxpayers with simple tax affairs will be unaffected. GfC13 applies to all HMRC submissions that include a declaration that they are correct and complete, including, but not limited to, self-assessment returns for income tax, corporation tax, and VAT.
Lists of countries with qualified status for Pillar Two purposes updated
On 18 August 2025, the OECD Inclusive Framework updated its central record of Pillar Two legislation with transitional qualified status. The central record lists jurisdictions whose local implementation of the Pillar Two global minimum tax rules has so far been assessed as ‘qualified’ in accordance with the Inclusive Framework’s simplified transitional qualification mechanism. See our Alert from January for further details. Additions to the list of jurisdictions with a qualified domestic minimum top-up tax that meets safe harbour standards include Brazil, Gibraltar, the Isle of Man, Japan and Singapore. Additions to the list of jurisdictions with a qualified income inclusion rule include Gibraltar, the Isle of Man, Jersey (which is not introducing a qualified domestic minimum top-up tax), Singapore and Switzerland.
The OECD has also added the Netherlands and Switzerland to its list of signatory jurisdictions to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). The GIR MCAA can form the legal basis for exchange relationships between tax authorities for the agreed dissemination approach for Pillar Two information returns (GIRs). For more background on the GIR MCAA see Deloitte Tax@Hand.
HMRC publish MLI synthesised texts of Latvia, China and Hong Kong tax treaties
HMRC have published new ‘synthesised texts’ showing how the operation of the 1996 UK-Latvia Double Taxation Convention, the 2013 UK-China Double Taxation Agreement and Protocol, and the 2010 UK-Hong Kong Double Taxation Agreement and Protocol, is modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’). In addition, The Malaysian Inland Revenue Board has published a synthesised text of the 2010 Malaysia-UK Double Taxation Agreement and Protocol and the MLI, however no such text has yet been published by HMRC on the relevant page of GOV.UK.
Advisory fuel rates including new rate for public charging of electric cars
On 22 August 2025, HMRC published the new advisory fuel rates for company cars applicable from 1 September 2025. The previous mileage rates, effective from 1 June 2025, can be used for up to one month from the date the new rates apply. The rates for diesel engines sized 1600cc or less, and over 2000cc have increased by 1 pence per mile. The rates for diesel engines sized 1601cc to 2000cc, and all petrol and LPG engine sizes are unchanged from the previous quarter. On 1 September 2025, two separate rates for fully electric cars were introduced, depending on charging location. The rate for home charging is 8 pence per mile and the rate for public charging is 14 pence per mile (the initially published public charging rate was subsequently updated on 26 August).
HMRC publish creative industries tax relief statistics
On 28 August 2025, HMRC published their official creative industries tax relief statistics for financial years up to March 2024. 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) to date. In 2023/24 a total of £2.4 billion of relief was paid out across all creative industries tax reliefs and expenditure credits, with almost half (46%) attributable to high-end TV tax relief.
Arcomet Towercranes SRL: VAT and transfer pricing adjustments
SC Arcomet Towercranes SRL (Arcomet Romania) acquired cranes for sale or lease to customers in Romania. Arcomet Romania’s parent company, Arcomet Service NV Belgium (Arcomet Belgium), provided commercial support to Arcomet Romania. A 2010 transfer pricing study set an operating margin for Arcomet Romania of between -0.71% and 2.74%, in accordance with the Transactional Net Margin Method. From 2011 to 2013, Arcomet Romania’s profits exceeded this amount, and Arcomet Belgium accordingly issued invoices to Arcomet Romania. Arcomet Romania applied the reverse charge to the first two invoices, but for the third invoice, considered that the transaction was outside the scope of VAT.
The Romanian tax authorities (RTA) took the view that all three invoices related to intra-EU purchases of services and so should have been subject to the reverse charge, and that Arcomet Romania had failed to produce sufficient evidence of the nature or necessity of the services to justify deduction of the reverse-charged VAT. The CJEU has held that, for VAT purposes, Arcomet Belgium’s activities constituted taxable supplies; there was a legal relationship with reciprocal performance, and a direct link between the services supplied and the amounts paid. The fact that the amounts were calculated by way of a transfer pricing methodology, and could vary, did not affect this analysis. The CJEU rejected the RTA’s arguments that Arcomet Romania had to demonstrate that the services were necessary or appropriate, but agreed that the RTA could require evidence, additional to the invoices, to support the substantive conditions for VAT deductibility, namely that the services were supplied to and were used by Arcomet Romania for the purposes of its taxable activities. (Contact: Nicole Faith)
EMEA Dbriefs webcasts
The next EMEA Dbriefs tax webcast is on Tuesday 9 September 2025 at 12.00 BST/13.00 CEST. In UK Tax Update our panel will discuss topical tax developments of relevance to UK businesses in relation to corporate taxes, employment taxes and indirect taxes.
On Wednesday 10 September 2025, at 12.00 BST/13.00 CEST, Deepinder Lamba will be hosting EU Pay Transparency Directive – Are you ready to comply? In the webcast, our panel will discuss the EU Pay Transparency Directive and provide an update on the status of local legislation across Europe.