12 June 2026
UK and New Zealand sign new double tax treaty
On 10 June 2026, HMRC updated their page New Zealand: tax treaties to state that a new UK-New Zealand double taxation convention was signed on 1 June 2026. The new agreement, which is not yet in force, will replace the existing 1983 UK-New Zealand Double Taxation Convention, as amended by the 2003 and 2007 protocols and the BEPS Multilateral Instrument. The new agreement includes, inter alia, a reduction to the existing 15% treaty dividend withholding tax rate to 5% where the beneficial owner is a company that owns at least 10% of the voting power for a 12-month period ending on the date of the dividend declaration. In some cases, the dividend withholding tax rate may be reduced to 0%.
The new agreement will enter into force and effect, in accordance with the timings in Article 28, only once both countries have completed their domestic parliamentary procedures for ratification and have notified each other accordingly.
Government announces mandatory foreign permanent establishment exemption
The government has announced that UK-resident companies will be required to exclude profits and losses attributable to foreign permanent establishments (together with credits for associated overseas tax suffered) from their corporation tax computation, effectively making the existing elective foreign branch exemption mandatory.
For most companies, the new requirement is intended to apply for corporation tax accounting periods beginning on or after 1 January 2027. An earlier start date will apply to UK-resident companies with foreign permanent establishments that carry on activities in connection with the exploration or exploitation of oil and gas, with the new rules applying with specific effect from 1 September 2026. Draft legislation for these changes is expected to be published “over the summer”. Further details are on Deloitte tax@hand.
HMRC manuals: Anti-avoidance rules for share exchanges and reconstructions
HMRC have added an appendix to their Capital Gains Manual that sets out further guidance on the changes to the anti-avoidance rules for share exchanges and company reconstructions, which were announced at Budget 2025, and took effect on 26 November 2025.
The appendix sets out, inter alia, how HMRC expect the rules to apply to certain preparatory reorganisations, including to prepare a business for entry into certain tax-advantaged regimes such as the Real Estate Investment Trust (REIT) regime, or to ensure that a share sale will qualify for a relief or exemption, such as the Substantial Shareholding Exemption (SSE).
OECD publishes consultation on transfer pricing of intra-group services
The OECD has published a public consultation document, Special Considerations for Intra-group Services, on potential revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in respect of the transfer pricing of intra-group services. The discussion draft seeks views on updating and modernising existing guidance on applying the arm’s length principle to services, including an annex with more than 20 new examples. Comments are invited by 22 July 2026 and a public meeting is expected to be held at the OECD in Paris in November 2026. For further details, please see our alert.
OECD publishes support for global minimum tax central filing obligations; HMRC guidance
The G20/OECD Inclusive Framework on BEPS has published a collection of documents in relation to the Pillar Two global minimum tax rules. These include a ‘common understanding’ among implementing countries addressing compliance and co-ordination challenges for the central filing of global minimum tax information returns (GIRs) that could otherwise arise from any potential delays in the availability of fully operational filing portals or activated exchange relationships before the 30 June 2026 first filing deadline. Please see Deloitte’s Alert for further details.
HMRC have published guidance confirming that the UK supports the common understanding approach, and that HMRC will act in accordance with it for GIRs filed overseas where the approach’s conditions are met. HMRC state that this transitional approach will apply where the filing deadline for the information return is no later than 31 December 2026.
Global minimum tax: Updated 2026 version of consolidated commentary released
The OECD/G20 Inclusive Framework on BEPS has also published an updated version of its consolidated commentary to the Pillar Two global minimum tax model rules. The updated version incorporates administrative guidance approved and published by the OECD Inclusive Framework up to May 2026. Please see Deloitte tax@hand for more details.
Temporary reduced VAT rate for children’s meals, children’s tickets, and family attractions announced
The government has announced that a temporary reduced VAT rate of 5% will apply to the supply of children’s meals, children’s tickets, and family attractions from 25 June 2026 to 1 September 2026. Details are set out in Revenue and Customs Brief 5 (2026), with an accompanying fact sheet. The Value Added Tax (Reduced Rate) (Hospitality and Tourism) Order 2026 has been made to implement the temporary reduced rate. The temporary rate will apply to: certain supplies of children’s meals; children’s and family admission to theatres, cinemas, concerts, exhibitions, and shows; and admission tickets to qualifying attractions suitable for families with children.
EMEA Dbriefs webcasts
We have three Dbriefs tax webcasts over the next month: Your European cross border workforce: what’s changing, what matters, & what’s next? (16 June 2026), Operational excellence in global mobility: from risk management to quality assurance (17 June 2026), and The EU directive on Faster and Safer Tax Relief of Excess Withholding Taxes (FASTER) (25 June 2026) Please visit our Dbriefs website for more information, and to view any other recent webcasts on demand.