Other news in brief

Finance Bill 2024-25 is currently undergoing its final stages in the parliamentary process. At the time of writing, all the remaining stages in the House of Lords were underway and scheduled to conclude on 19 March 2025. Although there is a debate, these stages are a formality as the Lords cannot make changes to a Finance Bill. The only remaining stage before enactment is Royal Assent, which is likely to take place before the end of March.

On 11 March 2025, the EU Economic and Financial Affairs Council (ECOFIN) reached political agreement on a DAC9 compromise text introducing a framework for the exchange of Pillar Two information between EU Member States. It has already been approved by the European Parliament so the Directive is expected to be formally adopted once legal linguistic revisions are completed. Member States will then be required to transpose the Directive into domestic law by 31 December 2025 and it will apply from 1 January 2026 with the first exchange of information required no later than six months after the filing of the first Top-up Tax information return. For calendar year taxpayers, this means the first exchange will need to take place by 31 December 2026, six months after their first filing deadline of 30 June 2026. KPMG’s EU Tax Centre has published a Euro Tax Flash that includes more detail on this and other topics discussed at the ECOFIN meeting on 11 March.

Another topic discussed at the ECOFIN meeting on 11 March was its tax decluttering and simplification agenda. The Council adopted its conclusions on tax decluttering and simplification, calling on the European Commission for a reduction in the reporting, administrative and compliance burden as well as the elimination of outdated and overlapping rules.

The Court of Appeal has just published its decision in Orsted West of Duddon Sands (UK) Limited & Ors v The Commissioners for HMRC [2025] EWCA Civ 279 (previously Gunfleet Sands Ltd). The taxpayer had appealed against the Upper Tribunal’s position on the eligibility of surveys and studies included in a capital allowance claim made in connection with the development of UK offshore windfarms. The Court of Appeal has partially allowed the appeal and an article discussing the decision in more detail will be included in the next edition of Tax Matters Digest. 

On 6 March 2025, the Public Accounts Committee (PAC) questioned three senior executives from HMRC on the cost of the tax system. The ‘witnesses’ from HMRC were Sir Jim Harra (First Permanent Secretary and Chief Executive), Justin Holliday (Chief Finance Officer) and Lucy Pink (Director HMRC Strategies). This was Sir Jim’s last appearance before the PAC before stepping down next month. There was some coverage in the press of the topics discussed, primarily around the question posed about why HMRC have more senior members of staff than other government departments. The PAC will publish its report on this session with its recommendations in due course.

Following HMRC’s announcement in February that the UK will suspend Double Taxation Treaties with Russia and Belarus, legislation revoking the original Orders giving effect to the UK-Russia and UK-Belarus Double Taxation Treaties has now been introduced via statutory instruments.

Urrffa Rafiq, Director and Head of Public Service Pensions at KPMG in the UK, has recently co-authored an article looking at the complexities around pensions that need to be considered by local authorities when outsourcing services. The article was published on the Lawyers in Local Government (LLG) website.