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      Tax Matters Digest: 27 November 2025 Edition

      To go straight to the articles in the latest edition please scroll down and expand the section/s below that are of interest to you. For a preview of these articles, read the introduction to the latest edition from Sharon Baynham here:

      You have a clear advantage over me for this edition of Tax Matters Digest. I am writing this introduction on Tuesday afternoon – before the Budget. But you will be reading it on Thursday morning – after the Budget. All the twists, turns and u-turns that have happened over the past few weeks mean that whatever I say here may well be wrong by the time you read it!

      Suffice to say, at the time of writing (‘heavy emphasis’), we are expecting the heavy lifting of tax rises to be done via threshold freezes with manifesto breaching increases to the rates of income tax off the table. If it turns out we are wrong and Ms Reeves adds 5p to the higher and additional income tax rates, please be kind.

      Sharon Baynham

      Director, Tax Policy

      KPMG in the UK

      On Monday we will be sending out a special Budget edition of Tax Matters Digest. This will include detailed articles on the key tax announcements so please watch out for that in your in-boxes. In the meantime, this regular edition of Tax Matters Digest is slimmer than normal.

      Our spotlight article links to the Budget delights that you can find on our Budget Insights Page. If you haven’t already discovered this then please do take a look. Whether you want to read commentary on the tax measures, listen to a playback of our post-Budget LinkedIn Live event, register for our deep dive Budget webinar on Friday or download a summary of key measures, this page is for you.

      Our second article stays with the theme of the Budget as we provide a link to Tim Sarson’s recent column in City AM where he asks whether Budget speculation is a helpful way to test policy or a chaotic distraction for the economy, especially when it reaches the levels it has done in recent weeks.

      Our next article looks at changes to the OECD Model Tax convention on Income and on Capital and its associated Commentary which was published on 18 November. Since the pandemic there has been a significant uptick in people working remotely with associated concerns for taxpayers that this could create permanent establishment issues. Our article focusses on the update to guidance on remote working and flags a number of considerations for affected businesses. It also provides a brief summary of other changes.

      In Other News In Brief, we highlight the Court of Appeal decision in the case of AD Bly Groundworks and Civil Engineering Ltd v HMRC concerning the issue of when employee remuneration costs may be disallowed as not being incurred ‘wholly and exclusively’ for the purposes of the employer’s trade. We also highlight the Scottish Government’s response to its recent consultation on options for approaching cross-border taxation for Scottish Aggregates Tax, and final Building Safety Levy regulations for England that have now been published.

      Finally, we include our usual Indirect Tax Weekly Talking Points and our Week in Tax summaries covering key tax developments from around the world.



      Tax matters for business

      Articles of interest to businesses
      group

      Our initial thoughts on Autumn Budget 2025

      Find our written commentary, a recording of our LinkedIn Live and a registration link for Friday’s webinar on our Budget 2025 insights hub

      CityAM: Is Budget speculation a bad thing?

      In his latest column for City AM written before the Budget, Tim Sarson discusses the ‘feeding frenzy’ of speculation we have seen this year

      Update to the OECD Model Tax Convention

      The 2025 update includes, amongst others, clarification of when home working by an employee could constitute a ‘place of business’

      Indirect Tax Weekly Talking Points – 19 November 2025

      This week’s edition covers an HMRC Brief on insurance intermediaries following the Hastings case, and a round-up of UK and European cases

      Indirect Tax Weekly Talking Points – 26 November 2025

      This week’s edition references a quiet week with no noteworthy VAT cases and instead previews the Budget




      Tax matters for employers

      Articles of interest to employers
      conversation

      Our initial thoughts on Autumn Budget 2025

      Find our written commentary, a recording of our LinkedIn Live and a registration link for Friday’s webinar on our Budget 2025 insights hub

      CityAM: Is Budget speculation a bad thing?

      In his latest column for City AM written before the Budget, Tim Sarson discusses the ‘feeding frenzy’ of speculation we have seen this year

      Update to the OECD Model Tax Convention

      The 2025 update includes, amongst others, clarification of when home working by an employee could constitute a ‘place of business’




      Tax matters for Individuals

      Articles of interest to individuals
      conversation

      Our initial thoughts on Autumn Budget 2025

      Find our written commentary, a recording of our LinkedIn Live and a registration link for Friday’s webinar on our Budget 2025 insights hub

      CityAM: Is Budget speculation a bad thing?

      In his latest column for City AM written before the Budget, Tim Sarson discusses the ‘feeding frenzy’ of speculation we have seen this year

      Update to the OECD Model Tax Convention

      The 2025 update includes, amongst others, clarification of when home working by an employee could constitute a ‘place of business’




      Other news in brief

      • Appeal dismissed in case considering the meaning of ‘wholly and exclusively’
      • Conclusions reached on how to approach cross-border taxation for Scottish Aggregates Tax
      • Building Safety Levy regulations made

      Our tax insights

      View our previous editions of Tax Matters Digest


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