13 February 2026
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.
Finance Bill and National Insurance Contributions Bill: progress update
The Public Bill Committee’s consideration of Finance (No. 2) Bill 2024-26 has now concluded. 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.
The National Insurance Contributions (Employer Pensions Contributions) Bill, which will create a power for the Treasury to apply NICs to salary-sacrificed pension contributions that exceed £2,000 per annum from April 2029, had its First Reading in the House of Lords on 22 January 2026, and its Second Reading on 4 February 2026. The Bill will now proceed to its Lords Committee stages. The first sitting of the Grand Committee is scheduled for 24 February 2026.
HMRC manuals: deferred remuneration
HMRC have updated the part of their manuals (see INTM163155) covering the income tax treatment of deferred remuneration under a double tax treaty. It sets out how such remuneration (e.g. bonus or share options) should be taxed when employees change their state of residence before receiving the remuneration, clarifying that the UK’s right to tax such income depends on whether it is the state of source or the state of residence under the treaty at the time the remuneration is received.
UK tax treaty with Peru now in force
As expected, HMRC have updated their page Peru: tax treaties to confirm that the 2025 UK-Peru Double Taxation Convention and Protocol entered into force on 21 January 2026. The provisions of the treaty will have effect in line with the provisions in its entry into force article. According to HMRC, the convention is effective in the UK from 1 January 2027 for taxes withheld at source, 6 April 2026 for income tax and capital gains tax, and 1 April 2026 for corporation tax. The convention is effective in Peru from 1 January 2027.
UK double tax conventions: synthesised texts published
HMRC have published new ‘synthesised texts’ showing how the operation of the 1996 Argentina-UK Double Taxation Convention, 1994 Azerbaijan-UK Double Taxation Convention, 2015 UK-Bulgaria Double Taxation Convention, and 2013 UK-Panama Double Taxation Convention are modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the ‘MLI’).
UK-India social security agreement
The UK government has published the UK-India Double Contributions Convention (DCC). This agreement, similar to existing DCCs, aims to prevent double social security contributions for eligible employees temporarily working in the other country for up to 36 months. Businesses will need to apply for a Certificate of Coverage (CoC) to confirm home country social security participation once the agreement is in force. The DCC includes provisions for remote work by personal choice with employer agreement, allowing CoCs for such arrangements. HMRC anticipate that the DCC will come into effect “by summer 2026”.
Business rates reliefs announced for pubs and live music venues in England and Wales
HM Treasury has announced a package of measures to support British pubs, including a new 15% business rates 'pubs and live music venues relief', available to eligible ‘pubs’ and ‘live music venues’ in England in 2026-27. In 2027-28 and 2028-29, eligible businesses will see the increase to their business rates bill limited to inflation.
Further to HM Treasury’s announcement, a Welsh government written statement confirms that the Welsh government will provide non-domestic rates relief for food and drink hospitality properties, including pubs, restaurants and live music venues in 2026-27. Eligible ratepayers will receive 15% non-domestic rates relief, capped at £110,000 per business across Wales.
CBAM: Draft regulations and policy summary
The Carbon Border Adjustment Mechanism (CBAM) will place a carbon price on specified goods imported into the UK. CBAM will come into effect on 1 January 2027. CBAM seeks to ensure that “highly traded, carbon intensive products from jurisdictions outside the UK face a comparable carbon price to that paid by UK manufacturers, so that UK decarbonisation efforts lead to a true reduction in global emissions rather than simply displacing carbon emissions overseas.” HMRC have published a consultation on draft CBAM regulations seeking feedback from stakeholders to ensure the regulations deliver the policy correctly and effectively for CBAM to operate as intended. The draft regulations deal with the administrative aspects of CBAM, including registration, returns, and record keeping, and the determination of the calculation of the CBAM rate and carbon price relief. The consultation will close on 24 March 2026. HMRC have also issued a policy summary on how CBAM will operate, including the core policy framework set out in Finance (No.2) Bill 2024-26 and details set out in the draft regulations and notices. The document will be updated to reflect future changes.
EMEA Dbriefs webcasts
We have three Dbriefs tax webcasts over the next month: Navigating EU Pay Transparency: Essential readiness for US companies with EU operations (23 February 2026); EU CBAM: key requirements in the definitive period (26 February 2026); and Dispute Resolution – New OECD Manual on Effective Mutual Agreement Procedures (5 March 2026). Please visit our Dbriefs website for more information, and to view any other recent webcasts on demand.