Other news in brief

On 21 April 2026, HM Treasury announced changes to the Electricity Generator Levy (EGL) which are designed to break the link between gas and electricity prices. The EGL was introduced from 2023 and applies to businesses generating electricity from nuclear, renewable and biomass sources when their revenue is above a benchmark price – this will be the case when gas prices are high as they can sell the electricity they generate at higher prices. Two changes were announced: (i) the rate of EGL will increase from 45 to 55 percent from 1 July 2026, and (ii) EGL will be extended past its current end date of April 2028. The hope is that these changes will encourage a switch for Renewable Obligation generators onto ‘Contracts for Difference’ which provide a fixed price for low carbon generators that is not subject to EGL. It will also generate higher government revenues while the electricity prices are high from those generators who choose to continue to sell at market rates. The change to EGL was part of a wider package of announcements from the Government in response to the current instability in the Middle East.

In a recent edition of HMRC’s Agent Update there was a short article about a change in approach to the Business Risk Review (BRR+) process for Large Businesses that has been implemented from April 2026. The change appears to affect only those businesses that are retaining a low risk status who are likely to see shorter BRR+ reports going forward. No reason for the change is given but it is likely to be to allow HMRC to target limited resources on businesses they view as higher risk by reducing the amount of ‘paperwork’ required to produce reports for lower risk businesses. The article says that businesses affected by this change will be informed by their Customer Compliance Manager (CCM).

The Government has announced that it will act to counter the unintended Stamp Duty Land Tax (SDLT) burden imposed on private renters by the Renters Rights Act (RRA) reported in our recent article. In a Written Statement, HM Treasury has pledged to introduce legislation in the next Finance Bill to exempt from SDLT the rent on assured tenancies of residential property. The exemption will apply retrospectively from when the RRA takes effect (expected 1 May 2026) such that existing leases which become leases for an indefinite term from this date, as well as new leases, should benefit from the SDLT exemption. This should have the effect of exempting high rent leases that are already within the charge, if they become treated as for an indefinite term under the new rules. However, how the exemption might work in detail has not yet been revealed.

HMRC have updated the intangible assets manual to reflect the main changes made by Finance Act 2026 (FA2026) which came into effect in relation to transfers and grants of rights in Intangible Fixed Assets (IFAs) made on or after 1 January 2026. The main changes were discussed in our previous article “Finance Bill: Reform of international tax rules”. These include the adoption of a single valuation standard being the arm’s length value for transactions within the scope of the transfer pricing rules that also meet the definition of a ‘cross-border’ transaction, and market value for all other cases, both for related parties transactions (starting at CIRD45000) and a number of other scenarios including shares schemes and realisations for non-monetary consideration (starting at CIRD48320). There is also an update to CIRD12780 which focuses on the acquisitions of intangible assets at nil or negligible value and re-casting to either arm’s length or market value (as appropriate). Points of particular note are HMRC’s acknowledgement of the ‘one-way street’ approach to adjustments of related party licences (at CIRD45050), in contrast to transfers of intangibles which have retained their ‘two-way street’ approach. Additionally, CIRD12780 includes additional comments on the application of this section to merger accounting which can result in assets being acquired at their book rather than fair value and was previously complex to analyse under the IFA regime. 

HMRC have added synthesised text of the Multilateral Instrument and the UK-Mexico Double Taxation Convention and Protocol, the UK-Qatar Double Taxation Convention and Protocol , the UK-Croatia Double Taxation Agreement and the UK-Spain Double Taxation Convention to the collection of published tax treaties on their website. The synthesised text reflects the changes made to those treaties 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).

KPMG’s Global Mobility Services team has recently published the third instalment of See It Differently, a three-part series exploring mobility trends, challenges and innovative approaches in the field of internationally mobile employment. Part Three, entitled "Connecting the dots in global mobility programs", includes the following articles:

• Elevating global mobility partnerships for strategic impact: The right partner ecosystem can be a key differentiator as mobility looks to drive value;
• Global mobility taps into AI as payroll data challenges proliferate: Embracing the power of automation to modernise outdated manual processes;
• Proactive compliance becomes integral amid geopolitical volatility: The intersection of global mobility, immigration and geopolitics; and
• Designing target operating models for a changing mobility landscape: The right model can provide a blueprint for efficiency and value.