UK: Update on Finance Bill 2025-2026
Government amendments to a variety of direct and indirect tax measures
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february 5, 2026
The Public Bill Committee stage for Finance Bill 2025-26 began on January 27, 2026, and prior to that a number of government amendments (along with updated explanatory notes on some of the amendments) were introduced on the following measures:
- Pillar Two (Schedule 8): Extension of deadline for making both long term and annual multinational top-up tax elections from the date the information return or overseas return notification for the period is due, to one year from that date
- Umbrella companies (clause 24): Allowance of disclosure to parties jointly and severally liable to pay PAYE under the umbrella company rules
- Loan charge (clauses 25 and 27): Clarification of parameters of the loan charge settlement scheme such that where a settlement offer is made to a person who is not an individual, the calculation of the settlement amount can be adapted
- Vaping products duty (clause 138): Amendments to commencement and transitional provisions, mainly to clarify that criminal offences can apply to vaping products produced or imported before the Act is passed or regulations are made
- Carbon border adjustment mechanism (CBAM) (clause 146): Clarification that scheme years in which there were no sectoral emissions should be ignored when determining the baseline free allocation percentage in relation to a CBAM sector
- Tax adviser registration (clause 225 and Schedule 21): Amendments to confirm that tax agent eligibility conditions would only be breached where a penalty for non-disclosure under the Disclosure of Tax Avoidance Schemes (DoTAS) or Disclosure of Avoidance Schemes for VAT and Other Indirect Taxes (DASVOIT) regimes remains unpaid by the due date, rather than on the imposition of the non-disclosure penalty
There were also minor drafting changes to the measures on transfer pricing (Schedule 6), enterprise management incentives (EMI) (clause 13), venture capital trusts (clause 15), economic crime levy (clause 110) and the disapplication of Aggregates Levy (Schedule 23) as a result of devolution of this tax to Scotland.
Read a February 2026 report prepared by the KPMG member firm in the UK