In this week’s detailed miscellaneous updates which you can read more about below, HMRC will be publishing a new guidance manual to cover the implementation of the OECD’s Pillar Two rules in the UK and the first deadline for in scope groups to register to report for Pillar Two is next Monday 30 June 2025. HMRC has also provided us with an update on the ongoing Class 2 national insurance contributions (NICs) issue which has resulted in incorrect tax calculations being issued to some taxpayers for 2024/25.
In other news this week:
- HMRC has published the latest Agent Update: Issue 132,
- The Government has published an updated policy paper ‘Tax Policy Making Principles’, which sets out its approach to delivering tax policy changes through the single major fiscal event cycle, and how it will engage with stakeholders during tax policy development. This is the first update on this from the new Government since it came to power last year. Note that we are not aware of any stakeholders being consulted on this,
- The Public Accounts Committee has held an evidence session with HMRC about the steps they are taking to ensure wealthy individuals pay their taxes as part of its ongoing inquiry in this area,
- The latest version of the Tax agents handbook has been published, and
- The minutes of the most recent meeting of the HMRC Guidance Strategy Forum are available on GOV.UK.
Pillar Two manual to be published
HMRC will be publishing a new guidance manual to cover the implementation of the UK’s Pillar Two rules. Over the last two years, draft content for this manual has been published in tranches for consultation. Four separate tranches have been published as follows:
Earlier this month, HMRC advised that consultation responses have been reviewed and will be reflected in the HMRC guidance manual where appropriate. In the introduction to the consultation on the fourth tranche of draft guidance, HMRC states “the guidance manual will be published in full in late spring” so we should expect to see this soon.
The deadline to register to report for Pillar Two is also approaching. Groups in the scope of the Pillar Two rules in the UK must register within six months of the end of the first accounting period which started on or after 31 December 2023. This means impacted groups with an accounting period ended 31 December 2024 must register by 30 June 2025. Registration and reporting must be done using HMRC’s online service for this.
2024/25 Class 2 NICs issue
From 2024/25, self-employed people with profits below the 2024/25 limit of £6,725 can opt to pay Class 2 NICs voluntarily for certain contributory state benefit purposes. Those with profits above this limit no longer have to pay Class 2 NICs to access the affected benefits.
HMRC has been investigating why some taxpayers, including some paying voluntarily, have received a self-assessment tax calculation (SA302) from HMRC that includes a liability for Class 2 NICs.
HMRC has advised us that the nature of the error depends on individual circumstances, but in general, some taxpayers have seen a Class 2 NICs liability added to their account when it should not have been. This issue mainly affects taxpayers with self-employed profits above £12,570. In some cases, HMRC has been able to correct this and the taxpayer will have been notified. In most cases, the impact is an incorrect Class 2 NICs charge of £358.80, but in some circumstances, the amount is less.
HMRC will notify the taxpayer when they correct their record and has confirmed that anyone who has made a payment will either be refunded or, have a credit added to their Self-Assessment statement. The root cause of the issue has been identified, and a fix is expected to be implemented by the end of July.
Once the fix is in place, HMRC will correct the affected tax calculations. This will happen before any incorrect amounts due impact the tax owed for 2024/25.
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