Other news in brief

The main provisions of the OECD’s Model Reporting Rules for Digital Platforms were brought into force in the UK from 1 January 2024, requiring operators of digital platforms to collect and report to HMRC information about people selling goods and services on their platforms. On 4 November 2024, The Platform Operators (Due Diligence and Reporting Requirements) (Amendment) Regulations 2024 were published to make two changes “to ensure that the UK rules are fully aligned with the original policy intent of the OECD model rules”. The first change ensures that where there is a UK reporting platform operator, it must report UK seller information to HMRC – there was previously an exception to this requirement where it had obtained adequate assurances that another Platform Operator would report the information required to the tax authorities. The second change is that various thresholds pertaining to whether a seller is an ‘excluded seller’ are no longer to be proportionally reduced in certain circumstances. These changes come into force on 25 November 2024.

In December 2023, an independent expert panel was established to develop a proposal to change the legal framework to allow companies incorporated overseas to become UK companies, whilst retaining the same legal personality. On 1 October 2024 this panel published a report setting out its proposals to allow overseas companies to re-domicile to the UK and vice versa. The Government has stated that it “welcomes the panel’s report and intends to consult in due course on a proposed regime design”.

On 1 November 2024, HMRC published the maps of the first Freeport customs sites for Humber and Inverness and Cromarty Firth Green, as well as the fourth, fifth and sixth Freeport customs sites for the Liverpool City Region. The incentives for making investments in these areas include simplified VAT and customs arrangements.

At the Autumn Budget the Chancellor announced that, following earlier consultation, with effect from 6 April 2025 the minimum tax rate on carried interest will increase to 32 percent and from 6 April 2026 the taxation of carried interest will be further reformed. A short summary prepared on Budget Day, provides further details on the proposals.

A recent KPMG Flash Alert discusses the implications of the UK Autumn Budget for globally mobile individuals and their employers. It focuses on the impact of the removal of the remittance basis regime and the concept of domicile and the replacement with a new Foreign Income and Gains regime, including a discussion on the impact of the changes to Overseas Workday Relief.

The Investment Association (IA) has published its long-awaited update to the Principles of Remuneration 2025 in relation to Executive Pay. The update marks a significant development in the Principles and there are several important changes that UK listed companies should be aware of, particularly as the annual reporting season is fast approaching.