Business Tax Briefing

A weekly round-up of corporate, employment and indirect tax news

6 February 2026

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OECD publishes revised Manual on Effective Mutual Agreement Procedures

On 2 February 2026, the OECD published an updated version of its Manual on Effective Mutual Agreement Procedures (MEMAP). The 2026 edition of the manual builds on the original 2007 edition, refreshing and expanding it to include further practical developments, as well as incorporating the BEPS Action 14 work on making dispute resolution mechanisms more effective. The manual is designed as a practical guide to the mutual agreement procedure (MAP) and provides a detailed explanation of the stages of the MAP process. It includes a list of 59 best practices for MAP (50 for countries, and nine for businesses), templates for the MAP process (including MAP applications), and the steps and timeframe of an ideal MAP process. For further details, please see our alert. Deloitte’s EMEA Dbriefs series will hold a webcast on Thursday 5 March 2026 at 12.00 GMT to discuss these updates.

Finance Bill completes Committee Stage

The Public Bill Committee’s consideration of Finance (No. 2) Bill 2024-26 concluded this week. Across two further sittings on the morning and afternoon of 3 February 2026, the remaining government amendments  were approved by the Committee. No amendments or new clauses tabled by opposition MPs on the Committee were passed. An updated version of the Finance Bill, as amended in the Committee, has been published.

The amended Finance Bill will now return to the House of Commons for its remaining Commons stages (Report Stage and Third Reading). No dates for these stages have been announced yet.

UK-Bulgaria Double Tax Convention: synthesised text published

On 4 February 2026, HMRC published a new ‘synthesised text’ showing how the operation of the 2015 UK-Bulgaria Double Taxation Convention is modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’). According to HMRC, the provisions of the MLI took effect with respect to the 2015 Convention: in the United Kingdom and Bulgaria, for taxes withheld at source, from 1 January 2023; in the UK, from 1 April 2024 for corporation tax and from 6 April 2024 for income tax and capital gains tax; and in Bulgaria, for other taxes, for taxable periods beginning on or after 1 January 2024.

Investment zones tax site regulations published

HM Treasury has published new investment zone regulations to designate specified areas, located within the North East of Scotland and Glasgow City Region Investment Zones, as special tax sites with effect from 26 February 2026. The designation will allow for special rates of structures and buildings allowances, plant and machinery capital allowances, and Class 1 employer NICs to apply to qualifying activities in these sites. It will also allow for business rates relief and land and buildings transaction tax (LBTT) relief on qualifying acquisitions. The Scottish government has laid a draft order that would give effect to the devolved LBTT reliefs. Maps of the North East of Scotland and Glasgow City Region Investment Zones and their tax sites have been published by HMRC.

Navigating HMRC’s new Advance Tax Certainty service

First announced at Spring Statement 2025, HMRC’s new Advance Tax Certainty for Major Projects service will be operational from July 2026. A recent Deloitte insights article provides an overview of the new clearance service, highlighting its key features, the application process, certain limitations, and ongoing taxpayer responsibilities.

EMEA Dbriefs webcasts

As a reminder, the next EMEA Dbriefs webcast will take place on Tuesday 10 February at 14.00 GMT/15.00 CET. In Remote working and permanent establishments – plus other updates to the OECD Model Treaty and Commentary, hosted by Alison Lobb, our panel will discuss updates to the OECD Model Treaty and its Commentary, including to the definition of a ‘fixed place of business’ permanent establishment in situations of cross-border remote working, in particular home working.

In a second EMEA Dbriefs webcast next week,UK tax update – February, our panel will discuss topical tax developments of relevance to UK businesses in relation to corporate taxes, employment taxes and indirect taxes. The webcast will take place on Wednesday 11 February 2026 at 12.00 GMT/13.00 CET.