Other news in brief

A new penalty system for late payment of tax has applied for VAT taxpayers since 1 January 2023 and also now applies to Income Tax Self-Assessment taxpayers using the Making Tax Digital service (either in the pilot that has been running since April 2024, or from mandation from April 2026 onwards). On 14 May 2024, in relation to this new penalty regime, HMRC published “The Penalties for Failure to Pay Tax (Assessments) Regulations 2024” in draft for consultation. These draft regulations are aimed at taxpayers who “intentionally avoid a second Late Payment Penalty by not paying their tax before the end of the two year time limit”. This is possible because currently, the legislation only allows HMRC to assess the second late payment penalty once, when the amount of outstanding tax is paid in full, within a two year assessment time limit. The draft regulations will also allow HMRC to assess and charge the second late payment penalty where the outstanding tax has not been paid in full, towards the end of the two year time limit. The draft regulations are open for comment until 10 June 2024.

In the latest of their series of “Guidelines for Compliance”, on 13 May 2024 HMRC published “Help with football agents' fees and dual representation contracts –GfC6”. The guidance sets out HMRC’s views on dual representation contracts and also focuses on the Employer Duties and VAT aspects of football agents’ fees and dual contract representation. HMRC state that this guidance is aimed at football agents and football clubs, but may be useful for players and their advisers too. 

Finance (No. 2) Bill 2024 (widely referred to as the Spring Finance Bill) completed the Committee of the whole House stage on 8 May 2024. Clauses relating to income and corporation tax charges and rates, as well as the energy security investment mechanism passed without amendment. The Public Bill Committee then considered the remainder of the Bill on 21 May, completing its scrutiny in one day without making any amendments. The Bill is now due to have its report stage and third reading on a date which, at the time of writing, was still to be confirmed. Amendments can be made to the Bill at Report Stage.

The 2024 UK-Peru joint declaration was published on 17 May 2024, confirming that the UK and Peru have reached a conclusion in their Double Taxation Agreement negotiations and that the treaty will be signed in the coming months. 

HMRC have added the ‘synthesised’ text of the 2012 UK-Liechtenstein 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). The synthesised text was prepared in consultation with the tax authorities in Liechtenstein and “represents a shared understanding of the modifications made to the Convention by the MLI”.

KPMG’s latest survey of executive pay across FTSE 350 constituent companies, including basic salary, pension payments, annual bonus awards and long-term incentive arrangements, has now been published. The survey also covers non-executive directors’ fees. The report uses data published by companies up to 31 July 2023. Please register and download our survey.