How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax administration and maintenance day” (or TAMD). Admittedly, the current UK government has not used this term, but its “tax update” of 28 April 2025 amounted to the same thing. A number of consultations, consultation responses and other documents were released. 

• It was accompanied by this Ministerial Statement from the Exchequer Secretary to the Treasury.
• This summary of what was published (and certain measures that were announced without an accompanying publication) will be handy.
• Here's a link to the full list of documents (which also includes links to “Tax policy papers, consultations, and calls for evidence since Autumn Budget 2024”).

Which measures caught my eye, you may ask? Here are two headlines. 

Stamp taxes reform

Stamp taxes (and the way in which they can delay the registration of a purchaser as the new owner of the shares in a private M&A transaction) have long baffled those not yet familiar with the UK's system. It is, therefore, welcome that the government has confirmed its intention to proceed with a long-anticipated reform of the UK's framework for stamp taxes on shares. 

In its summary of responses to a consultation published in April 2023 (which we mentioned in the relevant TAMD post), the government confirms its intention to publish draft legislation for a single tax on securities that would replace the current system of stamp duty and stamp duty reserve tax. 

The new tax would be self-assessed, and the government intends to consult with stakeholders on the design of an online portal for reporting and paying the tax. The intention is that this would go live in 2027 alongside the new legislative framework. 

It is envisaged that this would resolve the above-mentioned timing issues in private M&A transactions. A unique transaction reference number would be issued through the portal once the transaction has been reported on which basis the target company's registrar could update the register of members (without risking a fine for registering an unstamped transfer).

There are points yet to be worked out (for instance, how the geographical scope will be defined) and points where it remains to be seen how precise proposals would work in practice (for example, setting the tax point at the earlier of substantial performance and completion). So, there's a lot left to look out for, once more detailed proposals are available. 

In the meantime, you could read the consultation on proposals for the modernisation of the 1.5% charge which is open for comments until 21 July 2025.

Reform of transfer pricing, diverted profits tax and permanent establishment legislation

The proposals for the reform of the  UK's transfer pricing, DPT and permanent establishment legislation are significantly further advanced (we previously covered the consultation and summary of responses). 

The government is consulting until 7 July 2025 on various pieces of draft legislation and accompanying draft explanatory notes. Measures include changes to expand the participation condition for the application of the transfer pricing rules and to UK-to-UK transfer pricing, an alignment of the UK's permanent establishment definition with the OECD model and replacing DPT with a charge on “unassessed transfer pricing profits”.

A separate consultation (also open until 7 July 2025) addresses proposals to expand the scope of the UK's transfer pricing legislation to cover medium-sized companies and introduce a requirement to report cross-border related party transactions in an “International Controlled Transactions Schedule (ICTS)”.