Further to its 2023 framework on determining the price of minerals, the OECD has now published a consultation on a transfer pricing (TP) framework for copper, applying the same TP principles. One of the main aims of this work is to address some of the challenges developing countries face in raising revenue from their mining sectors and the OECD is working in partnership with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) to develop a series of practice notes and tools for governments. The consultation is open until 5 September 2025 and comments have been requested “regarding the application and usability of this toolkit to ensure that they are fit for purpose and appropriately tailored to the needs and requirements of developing countries”.
OECD publishes consultation on a transfer pricing framework for copper
Scottish Government publishes consultation on the interaction between investment funds and LBTT
On 11 July 2025, the Scottish Government published a consultation looking at the interaction of Scottish Land and Buildings Transaction Tax (LBTT) and property investment funds. The core focus of the consultation is on draft legislation which seeks to exempt the exchange of participant rights within a Co-Ownership Authorised Contractual Scheme (CoACS) where Scottish property is held as an underlying asset of the scheme. The Government is seeking views on this draft legislation to ensure it will work as intended. The consultation then goes on to consider the Stamp Duty Land Tax (SDLT) regime that has been put in place for Reserved Investor Funds (RIFs) and whether a similar regime should be introduced for LBTT and also considers the need for LBTT seeding relief for Property Authorised Investment Funds (PAIFs), CoACS and RIFs. Finally, there is a section looking at tax avoidance issues arising from the proposals within the consultation. Comments have been requested by 5 September 2025.
Draft Building Safety Levy regulations laid in Parliament
Draft regulations (The Building Safety Levy (England) Regulations 2025) setting out how the Building Safety Levy will operate were laid in Parliament on 10 July 2025. The regulations remain subject to Parliamentary approval. The levy will come into operation on 1 October 2026 and will be payable by developers in respect of certain residential developments. Broadly, the levy applies to works that result in new dwellings and/or new bedspaces in purpose-built student accommodation and change of use to residential purposes. The amount payable varies depending on the building’s size, use and location. There are exemptions from the levy for certain uses of buildings such as social housing. In addition, there are a number of exempt classes of buildings including school accommodation, care homes, hospitals and hotels. There is also a discounted rate for developments on land that meets the definition of previously developed. The levy will be collected by local authorities but will be transferred to central government where it will be used to contribute to fixing building safety defects across England. There has been mixed reaction from the property industry to the levy. Criticisms raised include that it is likely that the cost of the levy will be passed onto homebuyers which may make it harder for many to become homeowners, and requiring local authorities to act as collection agents may also be cumbersome and costly. Some have wondered if expanding the scope of the Residential Property Developers Tax would have been a better way of raising the revenue, which is essentially another tax on housing developers intended to fund the remediation of buildings following Grenfell.
HMRC publish 2024/25 annual report and accounts and business customer surveys
On 17 July 2025, HMRC published their annual report and accounts for the year ended 31 March 2025. The accounts show total tax revenue collected of £875.9 billion (an increase of 3.9 percent on the previous year) with £48.0 billion of tax protected “from fraud and other forms of non-compliance”. Also published on the same day were three of HMRC’s most important annual research studies: the Large Business Customer Survey 2024; the Agents, Small and Mid-sized Business Customer Survey 2024; and the Individuals Customer Experience and Perceptions Survey 2024.
KPMG Talking Tax – Recent statement by G7
Watch the latest episode of KPMG Talking Tax presented by Global Head of Tax Policy for KPMG International, Grant Wardell-Johnson. This episode delves into the G7 statement outlining an understanding of the principles of a ‘side-by-side approach’ in relation to the interplay between the US international tax system and the Pillar Two regime which was discussed in an article in the last edition of Tax Matters Digest.
New Pensions Commission to report in 2027
The Government has ‘revived’ the Pensions Commission whose recommendations led to the introduction of auto-enrolment (which was also known as the Turner Commission). The Government has highlighted concerns about current pension saving, with retirees in 2050 on course to have 8 percent less private pension than today’s retirees, and 45 percent of working age adults saving nothing at all into a pension. The new Pensions Commission will address concerns about under saving for retirement and “examine the pension system as a whole and look at what is required to build a future-proof pensions system that is strong, fair and sustainable”. The reformed commission comprises Professor Nick Pearce (who will be responsible for steering its work), Baroness Jeannie Drake (who was a member of the Turner Commission), and Sir Ian Cheshire. The Department for Work & Pensions and HM Treasury press release states that the Commission will issue its final report in 2027, with recommendations for change beyond the current Parliament.
Government publishes update to Labour Market Enforcement Strategy
The Government published its update on the Labour Market Enforcement Strategy on 21 July 2025. It identifies ways in which to tackle labour exploitation and to harness the strength of three existing enforcement bodies: HMRC National Minimum Wage; the Gangmasters and Labour Abuse Authority; and the Employment Agency Standards Inspectorate. There is a dedicated section to the foundations set by the Employment Rights Bill to create the Fair Work Agency to bring together these three enforcement bodies as well as expanding its enforcement powers to holiday pay and statutory sick pay. The Director of Labour Market Enforcement makes three recommendations specifically in relation to the Fair Work Agency: it must (i) have sufficient resources commensurate with its task and ambition; (ii) have transparent governance; and (iii) identify and build on learnings from existing enforcement bodies particularly around communications, intelligence gathering and enforcement /investigation approaches.