On 30 July 2025, the OECD published updated frequently asked questions for the Crypto-Assets Reporting Framework (CARF or DAC8 in the EU) and the amended Common Reporting Standard (CRS2.0) which both come into force in the UK and EU from 1 January 2026. The updates will primarily be of interest to cryptonatives, fintechs and others in the digital assets ecosystem as they address a few core issues, including an optional deferral of the rules for fully decentralised providers (‘de-fi’). The publication of the FAQs by the OECD follows the finalisation by the UK of the statutory instruments implementing CARF and CRS2.0, leaving no doubt that the UK will proceed with adoption in 2026. An updated CARF XML Schema was also published.
OECD publishes updated CARF and CRS2.0 FAQs
OECD publishes further XML Schema and user guide for the GloBE Information Return
In January this year the OECD Inclusive Framework on BEPS released a series of documents on the application of the Global Anti-Base Erosion (GloBE) Rules which included the GloBE Information Return (GIR) XML Schema and User Guide for Tax Administrations, designed to facilitate the exchanges of GIR information between tax administrations – our earlier article provides further information. On 30 July 2025, the OECD published the additional ‘GIR Status Message XML Schema’ to facilitate the reporting back to the sending administration of errors identified by the receiving administration in the GIR information that has been exchanged.
HMRC Notice on Pillar Two top-up taxes relevant territories and taxes published
Earlier this year regulations were published setting out lists of territories with qualifying income inclusion rules and of qualifying domestic top-up taxes in relation to the UK’s Pillar Two Multinational Top-up Tax (MTT) – our earlier article provides further information. On 24 July 2025, HMRC published a notice making additions to the lists of territories, adding Guernsey and Spain. The full list can be found at page MTT09970 of the HMRC Multinational Top-up Tax and Domestic Top-up Tax manual, which has just been published as we go to press.
HMRC warning on ‘bogus’ stamp duty land tax repayment claims following Mudan case
On 31 July 2025, HMRC issued a press release following the recent Court of Appeal decision in Mudan & Anor v HMRC [2025] EWCA Civ 799 which confirmed that the higher residential rates of stamp duty land tax (SDLT) should be charged on the purchase of a residential property where renovation work was needed before it was capable of being occupied. The release states that “This decision confirms HMRC’s long-standing view that if a property requires repairs but retains the fundamental characteristics of a dwelling, it is still suitable for use as a dwelling and attracts residential rates of SDLT.” It also warns taxpayers to be vigilant of tax agents offering to secure SDLT repayments for a fee on the basis that such properties are uninhabitable and should be subject to the lower non-residential rate of SDLT. The release continues to indicate that HMRC are taking decisive action, using civil and criminal powers, to deal with the “minority that undermine the tax system”.
Synthesised text of the Multilateral Instrument and UK-Barbados Double Taxation Convention published
HMRC have added the ‘Synthesised text of the Multilateral Instrument and the 2012 UK-Barbados Double Taxation Convention’ to the collection of published tax treaties on their website. The synthesised text reflects the changes made to that treaty by the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly known as the Multilateral Instrument or MLI).
National Minimum and Living Wage rates: Low Pay Commission remit published
The Department for Business & Trade issued the 2025 remit for the Low Pay Commission (LPC) on 5 August 2025. This asks the LPC to recommend what National Minimum Wage (NMW) and National Living Wage (NLW) rates should apply from 1 April 2026. Points the LPC is specifically asked to consider include: ensuring that the NLW rate remains at least two-thirds of UK median earnings for NLW workers; consulting on how best to move to a single adult minimum wage rate; and using the results of that consultation to inform the LPC’s recommendations for the 18 to 20-year-olds NMW rate from April 2026. The LPC will report by the end of October 2025.