Other news in brief

The rules for the UK’s Pillar Two Multinational Top-up Tax (MTT) recognise taxes paid under certain other jurisdictions ‘qualifying’ income inclusion rules and domestic top-up taxes. Such rules and taxes are qualifying if they are consistent with the OECD model rules and commentary. Under the MTT rules, regulations setting out lists of territories with qualifying income inclusion rules and of qualifying domestic top-up taxes are needed to provide certainty and, as a consequence The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 were laid on 31 March 2025. These regulations provide:

• A list of each territory that is specified as a ‘Pillar Two territory’ under section 241 Finance (No.2) Act 2023, reflecting its implementation of a qualifying income inclusion rule, along with the date from which it is specified under the UK rules;
• A list of each tax that is a ‘qualifying domestic top-up tax’ under section 256 Finance (No.2) Act 2023 (and the respective territories of those taxes) along with the date from which it is specified under the UK rules;
• A list of each qualifying domestic top-up tax that is specified as being ‘accredited’ for the qualifying domestic top-up tax safe harbour in Schedule 16A to Finance (No.2) Act 2023 (and the respective territories of those taxes) along with the date from which it is so accredited under the UK rules; and
• For HMRC to have the power to specify additions to each list by notice.

Resolutions for the 2024 Autumn Budget provided businesses with a temporary mechanism to recognise taxes and territories which were expected to meet, and then did meet, internationally agreed standards to enable those with accounting periods ending 31 December 2024 to make accurate provisions for Pillar Two taxes in their 2024 accounts. The regulations now provide certainty to business by introducing lists of territories and taxes into UK legislation.

Since 1 April 2024, it has been a requirement to submit an additional information form alongside the Company Tax Return for all claims for creative industry tax reliefs or creative industry expenditure credits. On 1 April 2025, HMRC published an updated form following some minor changes to the requirements made in The Relief for Creative Industries (Additional Information Requirements and Miscellaneous Amendments) (Amendment) Regulations 2025. The changes include new additional information items that need to be provided so that HMRC can check claims to the enhanced reliefs for low-budget films or visual effects (VFX) costs that apply from 1 April 2025. HMRC have also confirmed that the planned launch of ‘CT600P Creative Industries supplementary page’ to the Company Tax Return has been postponed until April 2026.

As originally announced at Autumn Budget 2024 as part of a package of measures to close the tax gap, from 6 April 2025 the rate of interest HMRC will apply to late payments of most taxes and duties will increase from 7 percent to 8.5 percent. This is following the introduction of regulations which make amendments to various pieces of legislation to apply the Bank of England (BoE) official rate of interest plus 4 percent going forward, rather than the BoE official rate plus 2.5 percent.

On 24 March 2025, the Government published its response to the technical consultation on the Building Safety Levy that ran during January and February last year. This response confirms that the levy will come into effect in autumn 2026, (which is a year later than originally proposed) to give local authorities and developers time to prepare. The levy rates are also included in Annex A. The delay and publication of rates will be a very welcome development for many developers who need to cost the levy into projects that will be going through planning at the moment.

Just after our last edition went to press, on 20 March 2025, Finance Bill 2024-25 received Royal Assent and is now Finance Act 2025. In other news in Parliament, the National Insurance Contributions (Secondary Class 1 Contributions) Bill 2024-25, which brings in the employers’ National Insurance changes announced at the Autumn Budget, has completed its passage through the House of Lords and, following a process of ‘ping pong’ whereby the Lords proposed amendments and the Commons refused to accept them, the Bill is now agreed and awaits Royal Assent.

A Double Tax Convention between the UK and Peru was signed in London on 20 March 2025. It will enter into force once both countries have completed their parliamentary procedures and exchanged diplomatic notes.