Other news in brief

After a lull in proceedings following completion of the Committee stage on 3 February 2026, Parliament’s focus appears to be returning to Finance Bill 2025-26 and a flurry of government amendments were tabled on 3 March. These cover a variety of topics including the planned changes to inheritance tax (in relation to both unused pensions and business property relief), the tax treatment of carried interest, and temporary non-residence of individuals. We are working through these proposed amendments to understand their implications. Report stage and third reading, when final amendments will be debated (and those tabled by the Government will almost certainly be agreed), are scheduled for 11 March 2026.

On 31 March 2025, 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 and this Notice is being updated periodically. The latest update was on 25 February 2026, when Hong Kong and Qatar were added to all three lists and Bahrain was added to list 1.2 (qualifying domestic top-up taxes) and 1.3 (accredited qualifying domestic top-up taxes). HMRC maintain a full list (i.e. the territories included in the original regulations plus all the territories in the updated Notice) at page MTT09970 of the HMRC Multinational Top-up Tax and Domestic Top-up Tax manual.

HMRC have announced that they no longer require share awards covered by Appendix 4 Short Term Business Visitor (STBV) agreements to be reported in Employment Related Securities (ERS) annual returns. However, awards held by STBVs must still be reported if they give rise to UK income tax or NIC liabilities (e.g. awards granted during a period of UK residence before the relevant individual became an STBV). This relaxation follows HMRC’s previous statement that share awards covered by an Appendix 4 STBV agreement should be reported in ERS annual returns. This is a welcome easement, and avoids employers being required to report potentially extensive data to HMRC where no UK income tax or NIC is in fact due.

On 27 February 2026, the NAO published a new value for money report on the work done by HMRC’s large business directorate which focuses on around 2,000 of the country’s largest corporate taxpayers, principally groups with an annual turnover in the UK of more than £200 million and those considered to have particularly complex tax affairs or operating in a complex business sector. The report covers the taxes paid by large businesses, HMRC’s approach to working with large businesses and the effectiveness of HMRC’s approach. The overall conclusions are broadly positive, highlighting the additional £15.8 billion of taxes collected by this directorate which equates to £95 for every £1 spent on staff pay, alongside the finding that large businesses rate their experience of dealing with HMRC highly relative to other taxpayer groups. The report cites the directorate’s ‘cooperative compliance approach’ as being key to HMRC’s success with large businesses and makes an interesting comment that HMRC are considering expanding this model to cover more businesses, targeting those that are more complex and higher risk. The NAO’s recommendations include a comment that HMRC should carry out detailed planning and analysis to inform their approach to this expansion, including analysis to help identify how many and which businesses to roll out cooperative compliance to. Other recommendations include developing detailed plans to make effective use of upcoming IT improvements and exploring barriers preventing the use of the ‘special measures’ regime which was introduced in Finance Act 2016 but has never been utilised.

KPMG’s Global Mobility Services (GMS) team has recently published the second instalment of See It Differently, a three-part series exploring mobility trends, challenges and innovative approaches in the field of internationally mobile employment. Part Two, entitled “Evolving mobility to meet a changing landscape", includes the following articles:

• Cross-border challenges for board members and highly complex employees: Executives on the move raise high stakes for mobility compliance; 

• Compliance audits unlocked: Global mobility needs to be audit-ready as scrutiny by authorities increases; 

• EU regulators and social security: Initiatives sharpen focus on efficiency, compliance and fair treatment of posted workers; and 

• Has national tax policy distorted the global talent competition? Amid fierce competition for valuable skills, striking the right balance poses challenges.

Part Three will follow soon and will include articles on a wide variety of topics, including strategic partnerships; global payroll challenges; immigration and geopolitics; and an article on whether target operating models will make mobility famous. Watch this space for further details.