Tax news

Midweek Tax News

A weekly update on tax matters to 30 April 2024

Midweek Tax News provides you with a succinct overview of the key tax developments that have occurred each week to allow you to stay up-to-date on tax issues that may have an impact on your business.

If you would like to discuss an article in more detail, please speak to the relevant contact listed at the end of this issue or to your usual EY contact. Alternatively, you can use our ‘contact us’ form. If you give us a brief description of your query (not just on this week’s content), we will send it to a relevant person in EY.

Due to upcoming work on the ey.com website, this page will not be updated with the 14 and 21 May editions of Midweek Tax News. If you regularly read this online here and do not wish to miss them then please subscribe to receive them by email here (you can unsubscribe at any time once we resume online publishing).

  • OECD releases Consolidated Commentary to GloBE Model Rules and updated Illustrative Examples

    On 25 April, the OECD/G20 Inclusive Framework on BEPS released the Consolidated Commentary to the Pillar Two Global Anti-Base Erosion (GloBE) Model Rules. This Consolidated Commentary replaces the original Commentary to the rules, which was issued in March 2022.

    The Consolidated Commentary incorporates the contents of the three Agreed Administrative Guidance documents issued in February, July and December 2023, which addressed matters covering the design of Qualified Domestic Minimum Top-up Taxes (QDMTT), the introduction of permanent and transitional safe harbours, and clarification of and guidance on the interpretation and application of the GloBE Rules for Multinational Enterprise (MNE) Groups and tax administrations.

    In addition, the Illustrative Examples document, originally published on 14 March 2022, has been updated to include the illustrative examples developed for the three sets of Agreed Administrative Guidance.

  • Progress of the Spring Finance Bill

    As previously highlighted, selected clauses of the Spring Finance Bill – those relating to income tax and corporate tax rates and the energy profits levy security investment mechanism – are due to be considered by a Committee of the whole House. This has been scheduled to take place on 8 May. The remaining clauses will be considered by a Public Bill Committee which will conclude by 23 May 2024.

Other UK developments

  • Regulations are made which amend treatment of trade losses in event of transfer of business by mutual societies

    On 24 April, following a period of consultation, regulations were made which amend the existing regulations relating to the use of trade losses in the event of transfers of business by mutual societies. The new rules apply to transfers of businesses taking place on or after 1 January 2023, and allow greater flexibility for the offset of post-1 April 2017 trade losses, subject to some restrictions in the first 5 years after the transfer of business. A policy paper is available.

  • HMRC issues notice extending application of Common Reporting Standard

    On 22 April 2024, the International Tax Compliance (Amendment) Regulations 2024 were made. These regulations amend the International Tax Compliance Regulations 2015 (the principal regulations), which give effect to agreements and arrangements reached between the United Kingdom and other jurisdictions in relation to international tax compliance, including the Common Reporting Standard (CRS).

    The amending regulations provide that the extension of the principal regulations to new arrangements should take place by the issue of a notice by HMRC (rather than via a statutory instrument as was previously the case). A notice was then issued by HMRC on 23 April specifying the arrangements entered into by the United Kingdom with other territories for the exchange of tax information for the purposes of the adoption and implementation of the CRS. The arrangements are those entered into as at 17 April 2024. The notice has effect from 14 May 2024.

  • EY 2024 Mobility Reimagined Conference: 7 – 8 May

    Economic headwinds and an increasingly complex race for global talent require organisations to reimagine workforce mobility as a cross-functional driver of growth and positive change for the business and for individuals. In this free virtual conference taking place on 7 – 8 May, attendees will explore the findings of the EY 2024 Mobility Reimagined Survey, revealing insights from mobility professionals, leaders and mobile employees illustrating trends, practices, tools and strategic priorities for new ways of working. The conference will include strategic and operational sessions on topics including mobility strategy; integrating with talent; sustainable and inclusive mobility; mobility operating models; AI and mobility; hybrid mobility; employee experience; and managing risks. For further information and registration please click here.

  • 2023/24 UK Annual Share Reporting returns: alert available

    Companies are required to report certain events concerning employment-related securities in respect of the 2023/24 tax year to HMRC by 6 July 2024. In addition to looking at the returns from an employment tax perspective, HMRC continues to use them to consider whether companies are correctly calculating their UK corporation tax deduction. HMRC has recently issued new guidance on the timing and availability of CT deductions for net settled awards and this is likely to be an area of increasing focus. 

    Our alert provides further detail and outlines key considerations for the 2023/24 annual reporting cycle.

Other International developments

  • EY global tax alerts

    We have included links to a selection of our tax alerts below. Additional articles are available in our global tax alert library.

    Germany: An online platform for the German Single-Use Plastics Fund levy is now available. Companies which take goods into the German “economic circuit” are required to register on the platform by the end of calendar year 2024.

    Poland: Draft legislation implementing the EU Directive on minimum taxation in in Poland was released on 25 April 2024. The draft provisions provide for Qualified Domestic Minimum Top-Up Tax (QDMTT) in addition to the Income Inclusion Rule (IIR) and the Undertaxed Profit Rule (UTPR). According to the draft law, the relevant Act would be in force from 1 January 2025, with optional application of QDMTT Safe Harbour and IIR as of 1 January 2024.

    Canada: Canada’s 2024 Federal Budget introduced several revisions to the proposed changes to the alternative minimum tax regime introduced in the 2023 federal budget. The amendments contain mostly welcome changes that address some concerns identified by stakeholders.

    Honduras: The Government has issued an Agreement establishing the obligation to file country-by-country reports (CbCRs), in accordance with Action 13 of BEPS.

Publications

  • TradeWatch Issue 1, 2024

    In this first issue of the year, EY’s global trade publication, TradeWatch, sets out the top seven trade trends expected to have a significant impact on international trade over the course of 2024. The publication assesses the outcomes from the recent World Trade Organisation’s 13th Ministerial Conference (MC13), and explores some key themes impacting global trade, including hot topics such as CBAM developments in the EU and UK.

  • Pillar Two developments tracker: updated to 12 April

    The latest version of EY’s Pillar Two development tracker, now updated to 12 April 2024, is available. The tracker provides a summary listing of administrative and legislative developments around the world relating to the implementation of the global minimum tax rules being developed under Pillar Two.

  • Non-dom newsletter: Labour responds to proposed changes to the non-dom tax regime

    The third edition of our new EY non-dom newsletter provides an overview of Labour's reaction to the Government’s proposal. While Labour supports most aspects of the proposed replacement of the current non-dom rules, including the four-year arrival window and the principle of a ten-year window for inheritance tax, it proposes a number of changes, including that all non-UK assets held in a trust should fall within UK inheritance tax, and that there should be no 50% discount on personally received foreign income in the first year of the new rules for non-doms.

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Further information

If you would like to discuss any of the articles in this week's edition of Midweek Tax News, please contact the individuals listed below, Nicola Sullivan (+44 20 7951 8228) or your usual EY contact.


OECD releases Consolidated Commentary to GloBE Model Rules and updated Illustrative Examples
Jack Gifford (+44 20 7806 9697)

For other queries or comments please email eytaxnews@uk.ey.com.