Multinational top-up tax

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STOP PRESS relating to new MTT and DTT draft legislation: The government has published draft legislation (together with explanatory notes and a policy paper) for inclusion in Finance Bill 2026 amending the MTT and DTT rules contained in Finance (No 2) Act 2023. The draft legislation introduces technical amendments and simplifications as well as reflecting the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will ‘mainly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers’. For more information, see News Analysis: Legislation Day: Draft Finance Bill 2026—Tax analysis—International. To track the progress of the Finance Bill and any changes to the draft legislation, see:

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Latest Tax News

Tax weekly highlights—7 August 2025

This week's edition of Tax weekly highlights includes: (1) News Analysis of the Supreme Court’s decision in Delta Merseyside on private hire operators acting as agents, (2) News Analysis of the UT’s decision in Medpro Healthcare, and (3) HMRC publishing a new manual on MTT and DTT.

Legislation Day: Draft Finance Bill 2026—tackling non-compliance in the umbrella company market

Tax analysis: On Legislation Day 2025, draft Finance Bill 2026 legislation was published that, if enacted, would make agencies and end clients jointly and severally liable for Pay As You Earn (PAYE) and National Insurance Contributions (NICs) failings by umbrella companies. John Chaplin, partner at BDO, considers these new provisions.

Supreme Court holds that private hire operators outside London and Plymouth are entitled to accept bookings as agents (D.E.L.T.A. Merseyside Ltd and another v Uber Britannia Ltd)

Tax analysis: In D.E.L.T.A. Merseyside Limited and another v Uber Britannia Limited, the Supreme Court unanimously dismissed Uber Britannia’s appeal and found that private taxi operators may structure their arrangements to act as agents, thereby reducing the amount of the fare that may be subject to VAT.

UT considers whether the decisions in Martland and Katib are binding on the FTT (Medpro Healthcare Ltd & Another v HMRC)

Tax analysis: In Medpro Healthcare Ltd, the Upper Tribunal (UT) allowed an appeal against a First-tier Tax Tribunal (FTT) decision to refuse permission to commence late appeals against penalties and personal liability notices. The UT found that the FTT had erred in law and remitted the case to be heard again by a differently constituted FTT.

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