Finance Act 2025

NC1

Review of impact of section 1 on recipients of the full rate of the new state pension (1) The Chancellor of the Exchequer must, within three months of this Act being passed, publish a review of the expected impact of section 1 of this Act on recipients of the full rate of the new state pension. (2) The review must include analysis setting out, for the tax year 2025-26— (a) the total number of people in receipt of the full rate of the new state pension paying tax under section 1 of this Act, and (b) the tax liability of state pension income under section 1 of this Act of those in subsection (2)(a). (3) For comparative purposes, the review must take account of equivalent projected figures for subsections (2)(a) and (2)(b) for the tax years 2026-27, 2027-28, 2028-29 and 2029-30.

NC2

Energy (oil and gas) profits levy: impact assessment of increase in rate (1) The Chancellor of the Exchequer must, within six months of this Act coming into force, commission and publish an assessment of the expected impact of Sections 15 to 17 of this Act on- (a) domestic energy production and investment; (b) the UK's energy security; (c) energy prices, and; (d) the UK economy. (2) The assessment must examine the impact of provisions in this Act in comparison with what could have been expected had the energy (oil and gas) profits levy remained unchanged.

NC3

Review of impact of tax changes in this Act on households (1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the changes in this Act on household finances. (2) The assessment in subsection (1) must consider how households at a range of different income levels are affected by these changes.

NC4

Review of impact of Act on small and medium sized enterprises (1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained within this Act on small and medium sized enterprises. (2) The report must include an assessment of the impact of the Act on the following matters- (a) the number of people employed across the UK by small and medium enterprises; (b) the number of small and medium sized enterprises ceasing to trade; and (c) the number of new small and medium sized enterprises established.

NC5

Review of the Impact of Tax Changes on Household Finances (1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the tax changes introduced by this Act on household finances. (2) The assessment must evaluate how households across different income levels are affected by these changes.

NC6

Report on fiscal effects: relief for investment expenditure The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained in clause 16 of this Act on tax revenue.

NC7

Pupils with SEND without an Education Health and Care Plan: review of VAT provisions (1) The Chancellor of the Exchequer must, within six months of this Act and every six months thereafter, lay before Parliament a review of the impact of the measures contained in sections 47 to 49 of this Act on pupils with special educational needs and disabilities. (2) The review must consider in particular the impact of those measures on— (a) children with special needs who do not have an education health and care plan (EHCP); and (b) the number of children whose families have applied for an EHCP.”

NC8

Review of sections 63 and 64 (1) The Chancellor of the Exchequer must, within six months of the passing of this Act and every six months thereafter, review the impact of the measures contained in sections 63 and 64 of this Act. (2) Each review must consider the impact of the measures on- (a) Scotch whisky distilleries, (b) small spirit distilleries, (c) wine producers and wholesalers, (d) the hospitality industry, and (e) those operating in the night-time economy. (3) Each review must include an estimate of administrative and operational costs for the preceding 12-month period for each of the sectors listed in subsection (2). (4) Each review must consider the impact of the measures on the retail price for consumers of products subject to alcohol duty. (5) Each review must also examine the expected effect of the measures on the domestic wine trade. (6) A report setting out the findings of each review must be published and laid before both Houses of Parliament.

67

Page 53, line 30, leave out Clause 47

68

Page 56, line 13, leave out Clause 48

69

Page 56, line 13, leave out Clause 49

1

The Chancellor of the Exchequer

Clause 26, page 17, line 32, leave out “the Chapter 3 credit amount” and insert “the adjusted VFX portion of those credits"

2

The Chancellor of the Exchequer

Clause 26, page 17, line 35, leave out from beginning to end of line 27 on page 18 and insert- "(4) Take the following steps to determine the adjusted VFX portion of previously claimed Chapter 3 credits— Step 1 (identify the total UK expenditure in the AVEC period) Determine the total amount of the company's relevant global expenditure (see section 1179CA(2)) that— (a) is UK expenditure (see section 1179AB), and (b) was incurred for accounting periods falling within the company's AVEC period. Step 2 (identify the amount of visual effects expenditure) Determine how much of the result of Step 1 is relevant visual effects expenditure. Step 3 (determine the extent to which the 80% cap applied) Determine the amount (if any) of the excess to be deducted at Step 3 in section 1179CA(1) for the most recent accounting period for which a claim for Chapter 3 credit was made (which may be the claim period). If that amount is nil go to Step 4, otherwise go to Step 5. Step 4 (where the 80% cap did not apply, calculate the adjusted VFX portion) If this Step applies, the adjusted VFX portion is the amount given by multiplying- (a) the sum of Chapter 3 credits claimed by the production company, by (b) the amount given by dividing the result of Step 2 by the result of Step 1. Step 5 (treat the 80% cap as affecting the VFX portion first) Subtract the result of Step 3 from the result of Step 2.If the result is nil or less, the adjusted VFX portion is nil. If not, go to Step 6. Step 6 (calculate the adjusted VFX portion, taking account of the 80% cap) If this Step applies, the adjusted VFX portion is the amount given by multiplying the result of Step 5 by 0.34.”

3

The Chancellor of the Exchequer

Clause 26, page 18, line 32, leave out "remainder” and insert "result of Step 5 in that subsection"

4

The Chancellor of the Exchequer

Clause 26, page 18, line 36, at end insert— “a company's “AVEC period” means the period beginning with the commencement of the first accounting period for which this Part applies further to the election by the company under section 1179B(1) and ending with the end of the claim period;"

5

The Chancellor of the Exchequer

Clause 37, page 28, line 17, leave out "and" and insert "to"

6

The Chancellor of the Exchequer

Clause 37, page 29, line 36, at end insert— "845CA Effect of claim, foreign employment election or foreign gain claim: costs of dwelling-related loan (1) This section applies where an individual- (a) has a relievable amount for a tax year in respect of an overseas property business for the purposes of section 274A (reduction for individuals: entitlement), and (b) makes a foreign income claim, a foreign employment election or a foreign gain claim for the tax year. (2) The individual is not entitled to relief under section 274A for that tax year in respect of that relievable amount. (3) For the purposes of section 274A, the individual's brought-forward amount for the following tax year in respect of the overseas property business is nil."

7

The Chancellor of the Exchequer

Clause 37, page 30, line 13, at end insert- "845DA Effect of claim on relief for contributions to registered pension schemes (1) Subsection (2) applies where— (a) an individual makes a foreign income claim for a tax year, (b) the individual is entitled to relief under section 188 of FA 2004 (relief for contributions) for that tax year, and (c) the maximum amount of relief to which the individual is entitled under that section for that tax year is greater than the basic amount within the meaning of section 190(4) of that Act. (2) The maximum amount of relief to which the individual is entitled under section 188 of that Act for that tax year is to be reduced by the lesser of— (a) the relevant amount, and (b) the amount that would reduce the maximum amount of relief to the basic amount. (3) The "relevant amount” is the amount of the relief to which the individual is entitled under section 845A(2) of this Act as a result of making the foreign income claim, so far as that amount reflects relevant qualifying foreign income. (4) An amount of qualifying foreign income is “relevant qualifying foreign income" if the income is relevant UK earnings within the meaning of section 189(2) of FA 2004."

8

The Chancellor of the Exchequer

Clause 37, page 34, line 1, leave out "section 38" and insert "section 34"

9

The Chancellor of the Exchequer

Clause 38, page 36, line 18, leave out “and” and insert “to”

10

The Chancellor of the Exchequer

Clause 38, page 40, line 17, at end insert— "41RA Effect of claim on relief for contributions to registered pension schemes (1) This section applies where an individual who is an active member of a registered pension scheme for the purposes of section 188 of FA 2004 (relief for contributions) makes a foreign employment relief claim for a tax year. (2) For the purposes of sections 189(1)(a) and 190 of that Act, references to the amount of the individual's relevant UK earnings chargeable to income tax for that year are to be read as references to that amount minus the relieved amount. (3) The "relieved amount” is the amount of the relief to which the individual is entitled under section 41P(2) of this Act as a result of making the foreign employment relief claim."

11

The Chancellor of the Exchequer

Clause 39, page 46, line 1, leave out "section 87” and insert "sections 87 and 89(2)"

12

The Chancellor of the Exchequer

Clause 39, page 46, line 4, after "87" insert "or 89(2)”

13

The Chancellor of the Exchequer

Clause 39, page 46, line 5, leave out “non-resident”

14

The Chancellor of the Exchequer

Clause 39, page 46, line 15, leave out "and 87A" and insert “, 87A and 89(2)"

15

The Chancellor of the Exchequer

Clause 39, page 46, line 34, leave out "and" and insert “to”

16

The Chancellor of the Exchequer

Clause 40, page 49, line 3, leave out "subsection (5)” and insert "subsections (4A) and (5)"

17

The Chancellor of the Exchequer

Clause 40, page 49, line 4, at end insert- "(4A) Paragraph 5A (relief for amounts remitted again on becoming UK resident) is to be treated as having always had effect."

18

The Chancellor of the Exchequer

Schedule 3, page 116, line 30, leave out paragraph (a)

19

The Chancellor of the Exchequer

Schedule 3, page 117, line 4, leave out paragraph (c) and insert- “(c) the payment has been certified in an approval notice given under section 30A(5)(b) or 30B(3)(b) of that Act."

20

The Chancellor of the Exchequer

Schedule 3, page 117, line 9, leave out sub-paragraph (3) and insert- "(3) For the purposes of sub-paragraph (2), a payment to a licensed company under an agreement to pay a required amount for the purposes of payment into the decommissioning fund is to be regarded as a payment into that fund. (3A) But the onward payment into the fund by that licensed company is not a qualifying payment."

21

The Chancellor of the Exchequer

Schedule 9, page 214, line 11, leave out from “in” to end of line 13 and insert "property situated outside the United Kingdom becoming situated in the United Kingdom.”

22

The Chancellor of the Exchequer

Schedule 9, page 214, line 13, at end insert- "(9B) Sections 275 to 275C of TCGA 1992 (location of assets) apply for the purposes of subsection (9A)(b) as they apply for the purposes of TCGA 1992. (9C) But subsection (9B) does not apply where the intangible property is a debt other than a judgment debt.”

23

The Chancellor of the Exchequer

Schedule 9, page 215, line 10, after “to” insert “income tax or capital gains"

24

The Chancellor of the Exchequer

Schedule 9, page 215, line 10, at end insert- “Relief for amounts remitted again on becoming UK resident 5A (1) This paragraph applies where- (a) income or chargeable gains of an individual have been remitted to the United Kingdom during a period that exceeds 5 years— (i) that ends before 6 April 2024, and (ii) in which there was no period for which the individual was UK resident, and (b) after the end of that period, but before 6 April 2025— (i) the same, or part of the same, income or chargeable gains ("the repeated remitted amount”) were again remitted to the United Kingdom, and (ii) a relevant charge has arisen in relation to that remittance. (2) A "relevant charge” in relation to a remittance means- (a) income tax becoming chargeable on that remittance, or (b) a gain accruing under paragraph 1(2) of Schedule 1 to TCGA 1992 on that remittance. (3) Any relevant charge that has arisen on the first occasion on which the repeated remitted amount is remitted in circumstances falling within sub-paragraph (1)(b) is to be treated as never having arisen. (4) But a remittance that is not charged to income tax or capital gains tax as a result of sub-paragraph (3) is to be treated as if it were charged to income or capital gains tax (as the case may be) for the purposes of section 809P(12) of ITA 2007. (5) This paragraph is to be treated as never having applied where— (a) for either, or each, of the tax years 2024-25 and 2025-26, the individual is not UK resident, or (b) either, or each, of those tax years is a split year as respects the individual. (6) References in this paragraph to amounts being remitted to the United Kingdom are to be construed in accordance with Chapter A1 of Part 14 of ITA 2007 (see, in particular, sections 809L to 8090 of that Act)."

25

The Chancellor of the Exchequer

Schedule 9, page 215, line 15, at end insert— “Transferable tax allowance for married couples etc 6A In section 55C of ITA 2007 (election to reduce personal allowance), in subsection (3)(b), for “domiciled in the United Kingdom” substitute “not a qualifying new resident”.”

26

The Chancellor of the Exchequer

Schedule 9, page 218, leave out lines 34 and 35

27

The Chancellor of the Exchequer

Schedule 9, page 219, leave out lines 2 to 29 and insert— "23 (1) In section 22 of F(No.2)A 1931 (Treasury power to issue securities with a FOTRA condition), in subsection (1)(b) for “neither domiciled nor" substitute "not". (2) In section 154 of FA 1996 (FOTRA securities), omit subsection (1). (3) Any security issued with a FOTRA domicile condition is treated in relation to times on or after 6 April 2025 as if— (a) it were a security issued with the post-1996 Act FOTRA conditions (and with no other FOTRA condition), and (b) the post-1996 Act FOTRA conditions had been authorised in relation to the issue of that security by virtue of section 22 of F(No.2)A 1931. (4) In sub-paragraph (3)— "a FOTRA condition” means a condition about exemption from taxation authorised by section 22 of F(No.2)A 1931; "a FOTRA domicile condition”, in relation to a security, means a FOTRA condition requiring the security to be in the beneficial ownership of persons who are not domiciled in the United Kingdom for an exemption from taxation to apply; "the post-1996 Act FOTRA conditions” means the FOTRA conditions with which 7.25% Treasury Stock 2007 was first issued.”

28

The Chancellor of the Exchequer

Schedule 10, page 221, line 14, leave out "or" and insert "and"

29

The Chancellor of the Exchequer

Schedule 10, page 222, line 38, leave out paragraphs (b) and (c)

30

The Chancellor of the Exchequer

Schedule 10, page 223, line 11, after "87" insert "and 89 TCGA 1992"

31

The Chancellor of the Exchequer

Schedule 10, page 223, line 12, leave out paragraph 3 and insert- "3 (1) This paragraph applies for the tax year 2025-26,2026-27 or 2027-28 in relation to an individual if- (a) chargeable gains are treated as accruing to the individual in that tax year as a result of section 87(2) or 89(2) of TCGA 1992 in relation to a capital payment from the trustees of a settlement for which the individual is a beneficiary, and (b) the settlement has a section 1(3) amount that is greater than nil for one or more tax years before 2025-26. (2) So much of the payment as is matched with section 1(3) amounts for tax years before 2025-26 is qualifying overseas capital. (3) For the purposes of matching those amounts, apply section 87A of TCGA 1992 as if- (a) the section 1(3) amount for each tax year after the tax year 2024-25 were nil, and (b) the reference in Step 2 in subsection (2) of section 87A of that Act to the total amount of capital payments received by the beneficiaries were to the total amount of capital payments— (i) received by the individual and other beneficiaries that are qualifying individuals for the relevant tax year, and (ii) to which section 87(2) or 89(2) of that Act applies. (4) For the purposes of this paragraph, ignore any reduction of a section 1(3) amount for the tax year 2024-25 or an earlier tax year resulting from the application of section 87 or 89(2) of TCGA 1992 in the tax year 2025-26 or any subsequent tax year. (5) Sub-paragraph (6) applies where- (a) an amount of a capital payment has been matched with a section 1(3) amount under sub-paragraph (2), and (b) that amount is designated as designated qualifying overseas capital. (6) The section 1(3) amount is to be taken to have been reduced (but not below nil) by so much of it as matches with the capital payment for the purposes of any subsequent application of this paragraph. (7) This paragraph is not to be taken as affecting the application of section 87A of TCGA 1992 for any purpose other than for the purposes of this paragraph and paragraphs 3A and 4 (and no section 1(3) amounts or capital payments are to be taken to have been reduced as a result of the application of this paragraph for any other purpose). (8) For the purposes of this paragraph— (a) "section 1(3) amount” has the meaning is has in section 87 of TCGA 1992, and (b) section 97 of TCGA 1992 (supplementary provisions) applies as it applies for the purposes of sections 86A to 96 of that Act. (9) For the purposes of this paragraph, and paragraphs 3A and 4, an individual is a qualifying individual in a tax year if the individual- (a) is UK resident for the purposes of income tax and capital gains tax for that tax year, and (b) was subject to the remittance basis for at least one tax year (being a tax year before the tax year 2025-26).”

32

The Chancellor of the Exchequer

Schedule 10, page 223, line 32, at end insert- “Capital payments made by settlement: offshore income gains cases 3A (1) This paragraph applies for the tax year 2025-26, 2026-27 or 2027-28 in relation to an individual if- (a) chargeable gains are treated as accruing to the individual in that tax year as a result of section 87(2) of TCGA 1992, as it applies in relation to OIG amounts as a result of regulation 20 of the OFT Regulations, in relation to a capital payment from the trustees of a settlement for which the individual is a beneficiary, and (b) the settlement has an OIG amount that is greater than nil for one or more tax years before 2025-26. (2) So much of the payment as is matched with OIG amounts for tax years before 2025-26 is qualifying overseas capital. (3) For the purposes of matching those amounts, apply section 87A of TCGA 1992 as if- (a) the OIG amount for each tax year after the tax year 2024-25 were nil, and (b) the reference in Step 2 in subsection (2) of 87A of that Act to the total amount of capital payments received by the beneficiaries were to the total amount of capital payments— (i) received by the individual and other beneficiaries that are qualifying individuals for the relevant tax year, and (ii) to which section 87(2) of that Act applies in relation to OIG amounts (as a result of regulation 20 of the OFT regulations). (4) For the purposes of this paragraph, ignore any reduction of an OIG amount for the tax year 2024-25 or an earlier tax year resulting from the application of section 87 or 89(2) of TCGA 1992 in the tax year 2025-26 or any subsequent tax year. (5) Sub-paragraph (6) applies where— (a) an amount of a capital payment has been matched with an OIG amount under sub-paragraph (2), and (b) that amount is designated as designated qualifying overseas capital. (6) The OIG amount is to be taken to have been reduced (but not below nil) by so much of it as matches with the capital payment for the purposes of any subsequent application of this paragraph. (7) This paragraph is not to be taken as affecting the application of section 87A of TCGA 1992 for any purpose other than for the purposes of this paragraph and paragraphs 3 and 4 (and no OIG amount or capital payments are to be taken to have been reduced as a result of the application of this paragraph for any other purpose). (8) For the purposes of this paragraph- (a) the "OFT Regulations” means the Offshore Funds (Tax) Regulations 2009, (b) "OIG amount” is to be construed in accordance with the OFT Regulations, and (c) section 97 of TCGA 1992 (supplementary provisions) applies as it applies for the purposes of sections 86A to 96 of that Act.”

33

The Chancellor of the Exchequer

Schedule 10, page 223, line 34, leave out paragraph 4 and insert- "4 (1) This paragraph applies for the tax year 2025-26,2026-27 or 2027-28 in relation to an individual if- (a) chargeable gains are treated as accruing to the individual in that tax year as a result of paragraph 8(1) of Schedule 4C to TCGA 1992 in relation to a capital payment from the trustees of a relevant settlement for which the individual is a beneficiary, and (b) the section 1(3) amount in the Schedule 4C pool is greater than nil for one or more tax years before 2025-26. (2) So much of the payment as is matched with section 1(3) amounts in the Schedule 4C pool for tax years before 2025-26 is qualifying overseas capital. (3) For the purposes of matching those amounts, apply section 87A of TCGA 1992 as if- (a) the section 1(3) amount in the Schedule 4C pool for each tax year after the tax year 2024-25 were nil, and (b) the reference in Step 2 in subsection (2) of section 87A of that Act to the total amount of capital payments received by the beneficiaries were to the total amount of capital payments— (i) received by the individual and other beneficiaries that are qualifying individuals for the relevant tax year, and (ii) to which paragraph 8(1) of Schedule 4C to that Act applies in relation to section 1(3) amounts in the Schedule 4C pool. (4) For the purposes of this paragraph, ignore any reduction of a section 1(3) amount in the Schedule 4C pool for the tax year 2024-25 or an earlier tax year resulting from the application of paragraph 8(1) of Schedule 4C to TCGA 1992 in the tax year 2025-26 or any subsequent tax year. (5) Sub-paragraph (6) applies where- (a) an amount of a capital payment has been matched with a section 1(3) amount in the Schedule 4C pool under sub-paragraph (2), and (b) that amount is designated as designated qualifying overseas capital. (6) The section 1(3) amount in the Schedule 4C pool is to be taken to have been reduced (but not below nil) by so much of it as matches with the capital payment for the purposes of any subsequent application of this paragraph. (7) This paragraph is not to be taken as affecting the application of section 87A of TCGA 1992 for any purpose other than for the purposes of this paragraph and paragraphs 3 and 3A (and no section 1(3) amount in the Schedule 4C pool or capital payments are to be taken to have been reduced as a result of the application of this paragraph for any other purpose). (8) For the purposes of this paragraph- (a) "section 1(3) amount in the Schedule 4C pool” and “relevant settlement" are to be construed in accordance with Schedule 4C to TCGA 1992, and (b) section 97 of TCGA 1992 (supplementary provisions) applies as it applies for the purposes of sections 86A to 96 of that Act.”

34

The Chancellor of the Exchequer

Schedule 10, page 225, line 2, at end insert- “Deemed income under section 732 of ITA 2007 where pre-2025 gains available for matching 5A (1) Sub-paragraph (2) applies where— (a) an individual is treated as having an amount of income for any of the tax years 2025-26, 2026-27 or 2027-28 as a result of section 732 of ITA 2007 (individuals receiving a benefit as a result of relevant transactions), (b) the amount of income does not fall within paragraph 5(1)(c), and (c) the benefit by reference to which that income is treated as arising would, if it were not chargeable to income tax, be an amount of qualifying overseas capital of the individual by virtue of paragraph 3 or 4 (capital payments). (2) The amount is to be treated as an amount of qualifying overseas capital of the individual. (3) The amount may only be designated in a return for the tax year in which the income was treated as arising to the individual."

35

The Chancellor of the Exchequer

Schedule 10, page 226, line 26, at end insert "and relief"

36

The Chancellor of the Exchequer

Schedule 10, page 226, line 29, leave out sub-paragraph (2) and insert- "(2) No liability to income tax arises on an amount of income treated as qualifying overseas capital under paragraph 5 if the amount is designated. (2A) But such an amount is to be treated for the purposes of section 97(1) of TCGA 1992 (capital payments not to include amounts chargeable to income tax) as if it were chargeable to income tax. (2B) No liability to income tax arises on an amount of income treated as qualifying overseas capital under paragraph 5A if the amount is designated. (2C) Accordingly the amount- (a) will be a capital payment for the purposes of sections 86A to 96 of, and Schedule 4C to, TCGA 1992 (see section 97(1) of that Act), and (b) will, as a result of paragraph 3 or 4 (or both), be qualifying overseas capital. (2D) Any such qualifying overseas capital is to be treated as having been designated by the individual (under that paragraph or those paragraphs), but no liability to the TRF charge is to arise as a result of that deemed designation. (2E) Sub-paragraph (2F) applies where— (a) offshore income gains, within the meaning of the Offshore Funds (Tax) Regulations 2009, are treated as accruing to an individual in a tax year under section 87(2) of TCGA 1992 (as applied by regulation 20 of those regulations) as a result of a capital payment made to an individual, and (b) an amount of that capital payment is qualifying overseas capital that has been designated by the individual. (2F) The offshore income gains are to be reduced by the amount of that designated qualifying overseas capital.”

37

The Chancellor of the Exchequer

Schedule 10, page 226, line 32, at end insert- “Income tax exemptions: application of transfer of assets abroad rules in future years 8A (1) This paragraph applies where an amount of income that is treated as arising to an individual under section 732 of ITA 2007 ("the deemed income") is exempt from income tax by virtue of paragraph 8. (2) If the deemed income is qualifying overseas capital by virtue of paragraph 5(1)(c), Chapter 2 of Part 13 of ITA 2007 has effect as though the deemed income had been charged to tax under section 731 of that Act. (3) Accordingly- (a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of the deemed income will be deducted at Step 2 and at paragraph (a) of Step 5, and (b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of the deemed income will be deducted at paragraph (b) of Step 5. (4) If the deemed income is qualifying overseas capital by virtue of paragraph 5A, Chapter 2 of Part 13 of ITA 2007 has effect as though the benefit by reference to which the deemed income was treated as arising had never been provided. (5) Accordingly, in the application of section 733(1) of ITA 2007 to any individual for subsequent tax years— (a) that benefit will not be taken into account at Step 1, (b) no deduction in respect of the deemed income will be made at Step 2 or Step 5, and (c) the total untaxed benefits will not be reduced in respect of that benefit by virtue of section 734 (previous capital gains charge)."

38

The Chancellor of the Exchequer

Schedule 10, page 227, line 4, after "87(2)” insert "or 89(2)"

39

The Chancellor of the Exchequer

Schedule 10, page 227, line 7, after “individual” insert "under paragraph 3"

40

The Chancellor of the Exchequer

Schedule 10, page 227, line 23, leave out "paragraph 3(1)(c)” and insert “paragraph 3(2)"

41

The Chancellor of the Exchequer

Schedule 10, page 227, line 28, leave out "paragraph 3(1)(c)” and insert "paragraph 3(2)"

42

The Chancellor of the Exchequer

Schedule 10, page 227, line 36, after "individual” insert “under paragraph 4"

43

The Chancellor of the Exchequer

Schedule 10, page 228, line 11, leave out "paragraph 4(1)(b)” and insert "paragraph 4(2)"

44

The Chancellor of the Exchequer

Schedule 10, page 228, line 17, leave out “paragraph 4(1)(b)” and insert “paragraph 4(2)"

45

The Chancellor of the Exchequer

Schedule 10, page 228, line 29, leave out from “individual" to end of line 30 and insert “if—”

46

The Chancellor of the Exchequer

Schedule 10, page 228, line 31, leave out paragraphs (a) and (b) and insert- "(a) the tax year is tax year 2025-26, 2026-27 or 2027-28, (b) the individual- (i) makes a designation of qualifying overseas capital for that tax year, or (ii) the individual has made such a designation for a previous tax year, and (c) that section has not applied in relation to that individual for the tax year 2024-25 or an earlier tax year."

47

The Chancellor of the Exchequer

Schedule 10, page 234, line 13, leave out "at a relevant time"

48

The Chancellor of the Exchequer

Schedule 10, page 234, line 18, leave out "at a relevant time"

49

The Chancellor of the Exchequer

Schedule 10, page 239, line 37, at end insert— “No tax credits for pre 2016-17 dividends etc 16A Sections 397 to 398 of ITTOIA 2005 (which have been repealed and only have effect in relation to distributions made before tax year 2016-17) do not apply in relation to any amount of designated qualifying overseas capital.”

50

The Chancellor of the Exchequer

Schedule 12, page 253, line 36, at end insert— "(2B) For the purposes of subsection (1), if in a tax year— (a) income is treated as arising to an individual under section 732(2), and (b) the income is identified as qualifying foreign income on a foreign income claim, the income is treated for later tax years as not having been charged to income tax under section 731. (2C) It follows from subsection (2B) that- (a) in the application of subsection (1) to the individual for subsequent tax years, the amount of the income will be deducted at Step 2 and at paragraph (a) of Step 5, but (b) in the application of subsection (1) to any other individual for subsequent tax years, the amount of the income will not be deducted at paragraph (b) of Step 5. (2D) See paragraph 8A of Schedule 10 to FA 2025 (temporary repatriation facility) for special provision about income that is treated as arising under section 732 but that is exempt from income tax under that Schedule.”

51

The Chancellor of the Exchequer

Schedule 12, page 260, line 16, leave out paragraph 49

52

The Chancellor of the Exchequer

Schedule 12, page 260, line 31, leave out "(2A)(a), omit “, 87K, 87L"" and insert "(2A), omit paragraph (a)"

53

The Chancellor of the Exchequer

Schedule 12, page 264, line 7, leave out “(7)(b), omit “, 87K, 87L”” and insert "(7), omit paragraph (b) (but not the “and” after it)”

54

The Chancellor of the Exchequer

Schedule 12, page 264, line 8, leave out "(6)(c), omit “, 87K, 87L"" and insert "(6)— (a) after paragraph (a) insert “and”; (b) omit paragraph (c) and the “and” before it."

55

The Chancellor of the Exchequer

Schedule 12, page 265, line 27, leave out paragraph 71 and insert- "71 (1) The amendments made by paragraphs 1 to 54, 56 to 65 and 68 to 70 have effect for the tax year 2025-26 and subsequent tax years. (2) The amendment made by paragraph 55 to section 62 of TCGA 1992 (death: general provisions) has effect in relation to deaths occurring on or after 6 April 2025. (3) The amendments made by paragraphs 66 and 67 to sections 279A and 279C of TCGA 1992 (deferred unascertainable consideration: election for treatment of loss) have effect in relation to disposals made on or after 6 April 2025 of rights to which section 279A of that Act applies."

56

The Chancellor of the Exchequer

Schedule 13, page 268, line 19, leave out "at all times on and after 30 October 2024 and before the time when” and insert “immediately before"

57

The Chancellor of the Exchequer

Schedule 13, page 269, line 1, leave out "at all times on and after 30 October 2024 and" and insert "immediately"

58

The Chancellor of the Exchequer

Schedule 13, page 275, line 4, at end insert- "267ZF Double taxation conventions operating by reference to deemed domicile (1) This section applies to a case in which the application of any arrangements having effect under section 158 (double taxation conventions) depends (to any extent) on whether a person is treated as domiciled in the United Kingdom for the purposes of inheritance tax. (2) The person is treated as domiciled in the United Kingdom for the purposes of inheritance tax if they are a long-term UK resident. (3) Sections 276ZC to 267ZE (persons treated as long-term resident by virtue of election) are to be disregarded in applying this section in relation to any arrangements that are specified in an Order in Council made under section 158 of IHTA 1984 before 17 July 2013 (other than by way of amendment by an Order made on or after that date). (4) Nothing in this section affects the interpretation of any such arrangements as are mentioned in section 158(6) (certain pre-1975 arrangements).”

59

The Chancellor of the Exchequer

Schedule 13, page 276, line 13, leave out "gift” and insert “disposal and remained settled property at all times after the disposal and before the relevant time"

60

The Chancellor of the Exchequer

Schedule 13, page 276, line 17, leave out “at all times on and after 30 October 2024 and" and insert "immediately"

61

The Chancellor of the Exchequer

Schedule 13, page 276, line 29, at end insert- "(7C) In subsection (7A)(c), “for the purposes of the 1984 Act” includes for the purposes only of Chapter 3 of Part 3 of that Act (ten-year anniversary charges etc) because of the operation of section 81 of that Act (property moving between settlements).”

62

The Chancellor of the Exchequer

Schedule 13, page 279, line 22, leave out “not been resident in the United Kingdom for any tax year" and insert “been resident in the United Kingdom for no tax year"

63

The Chancellor of the Exchequer

Schedule 13, page 279, line 26, leave out “not resident in the United Kingdom for any" and insert "resident in the United Kingdom for none"

64

The Chancellor of the Exchequer

Schedule 13, page 279, line 28, leave out "not resident in the United Kingdom for more than 14" and insert "resident in the United Kingdom for fewer than 15"

65

The Chancellor of the Exchequer

Schedule 13, page 280, line 12, leave out paragraph (b)

66

The Chancellor of the Exchequer

Schedule 13, page 280, line 19, leave out sub-paragraph (3)

1

Schedule 4, page 125, line 28, leave out "untaxed amount” and insert “UK proportion"

2

Schedule 4, page 125, line 30, leave out "untaxed amount” and insert “UK proportion"

3

Schedule 4, page 133, line 20, at end insert— "Use of substituted values 11A(1) After section 137 insert- "137A Use of substituted values (1) Where any provision of this Part requires the substitution of a value recorded in the underlying profits accounts of a member of a multinational group for an accounting period, the substituted value- (a) is to be used for all purposes of this Part instead of the value recorded in the accounts (for example, where the carrying value of an asset has been substituted and the value of that asset is relevant to the member's deferred tax expense, that substituted value is to be used in connection with determining that expense), and (b) is to be updated (for example, in making adjustments for depreciation for subsequent accounting periods), in each case, in accordance with the accounting standard used in determining the underlying profits of the member. (2) But where the value in question is the value of an asset, no adjustments for impairment are to be made to it. (3) Where the impaired value of an asset recorded in the underlying profits accounts for any accounting period is less than the substituted value of the asset for that period, use the value from the underlying profits accounts instead for that period and all subsequent periods (and subsection (2) does not apply in relation to that value)." (2) In section 197 (eligible tangible asset amount), in subsection (3)— (a) after "means” insert "values", and (b) after "parent” insert “(and not values as substituted as a result of any other provision of this Part)"."

4

Schedule 4, page 146, line 34, at end insert- "Additional top-up amounts 33A In section 203 (additional top-up amounts where covered taxes less than expected), in subsections (4)(b), (5)(b), (6)(b) and (7)(b), for “reduction by relevant QDT credit” substitute “any reduction”. 33B(1) Section 206 (additional top-up amounts where recalculations required) is amended as follows. (2) In subsection (1)— (a) in the words before paragraph (a), after “members” insert “("the current members")", and (b) in paragraph (b), before “members” insert “current”. (3) In subsection (2)— (a) in paragraph (a), for “those members would have for a prior period” substitute "the standard members of the group in the territory in a prior period would have for that period", and (b) in the words after paragraph (b), before “members” insert “current”. (4) In subsection (3)— (a) in Step 1, for “those members would have had for the prior period” substitute "the standard members of the group in the territory for the prior period would have had for that period", (b) in Step 3, after "nil” insert "(and if there are no such results, the result of this step is nil)", and (c) in Step 4- (i) before "members” insert "current"", and (ii) for "Step 2" substitute "Step 3". (5) In subsection (4)— (a) for "those members” substitute “the current members”, and (b) for "in accordance with subsections (5) to (8)" substitute "as follows". (6) In subsection (5)— (a) in paragraph (a)— (i) for "standard" substitute "current", and (ii) before "period” insert “current”, (b) in paragraph (b), for “members for the members' territory” substitute "current members", and (c) in paragraph (c), for “reduction by relevant QDT credit” substitute "any reduction". (7) In subsection (6)— (a) in paragraph (a)— (i) for "standard" substitute "current", and (ii) before "period” insert “current”, (b) in paragraph (b), for "standard members in the territory” substitute "current members", and (c) in paragraph (c), for “reduction by relevant QDT credit” substitute "any reduction”. (8) In subsection (7)— (a) in paragraph (a)— (i) for "standard" substitute “current”, (ii) before "period”, in the first place it occurs, insert “current”, and (iii) for "members for the members' territory” substitute "the current members", and (b) in paragraph (b)— (i) for "reduction by relevant QDT credit" substitute "any reduction", and (ii) for "members for the member's territory” substitute "current members". (9) In subsection (8)— (a) in paragraph (a)— (i) for "standard" substitute "current", and (ii) for "members for the members' territory” substitute "the current members", (b) in paragraph (b)— (i) for "reduction by relevant QDT credit” substitute "any reduction", and (ii) for "members for the member's territory” substitute "current members", and (c) in the words after paragraph (b) for the words from “amount”, in the second place it occurs, to the end substitute "relevant amount.” (10) After subsection (8) insert- "(9) The relevant amount is the amount given by multiplying- (a) the sum of the amounts of qualifying domestic top-up tax accrued by the current members in the current period, by (b) the amount given by dividing- (i) the collective additional amount under this section, by (ii) the sum of that collective additional amount, any collective additional amount under section 203 and the total top-up amount for the current period.""

5

Schedule 4, page 147, line 6, at end insert— "(e) in paragraph (f), for "of which the entity is a member” substitute "referred to in paragraph (a)”.”

6

Schedule 4, page 147, line 12, at end insert- "(ia) after "Part”, in the second place it occurs, insert “”, this Chapter other than this section and section 226", and"

7

Schedule 4, page 147, line 33, leave out "where" and insert "if"

8

Schedule 4, page 147, line 35, leave out "of the group has" and insert "meets Condition A and Condition B for that period"

9

Schedule 4, page 147, line 37, after "group” insert “(the “relevant group")"

10

Schedule 4, page 147, line 39, leave out "of the group have,” and insert “meet Condition C for that period and— (i) all of those members are located in the United Kingdom, or (ii) the relevant group is a multinational group (see section 126 in Part 3), and at least one of the members is located in a Pillar Two territory.”

11

Schedule 4, page 147, leave out lines 40 and 41

12

Schedule 4, page 161, line 32, at end insert- "54A In section 211 (transfer of assets or liabilities to a member of a multinational group)- (a) in subsection (2)— (i) omit the “and” after paragraph (b), and (ii) after that paragraph insert- "(ba) the transferor and the transferee are not members of the same type located in the same territory, and", and (b) after subsection (4) insert- "(5) For the purposes of subsection (2) two members of a multinational group are of the same type if- (a) they are both standard members of the group, (b) they are both investment entities, or (c) they are both members of the same minority subgroup (see section 228).""

13

Schedule 4, page 162, line 7, at end insert— "58A In section 217(8), for paragraph (a) substitute- "(a) the aggregate covered tax balance of the standard members of the group in the territory of the member for the prior period is not reduced by 1 million euros or more, and". 58B In section 220 (top-up amount of investment entity)— (a) in subsection (1)— (i) in Step 8, after "entity” insert “, unless the entity has a positive undistributed income amount (see sections 214 and 215) for the period (in which case proceed to Step 9), and (ii) after that Step insert— "Step 9 Where this Step applies, the top-up amount for the entity is the sum of- (a) the result of Step 8, and (b) the positive undistributed income amount for the entity for the period multiplied by 15%.", and (b) omit subsection (2).”

14

Schedule 4, page 162, line 24, at end insert- "(f) paragraph 58B (top-up amount of investment entity).”

NC1

To move the following Clause- "Rate of vehicle excise duty for haulage vehicles other than showman's vehicles (1) In paragraph 7(3A) of Schedule 1 to VERA 1994 (which specifies the rate of vehicle excise duty applicable to haulage vehicles other than showman's vehicles), for £350" substitute “£365". (2) The amendment made by this section has effect in relation to licences taken out on or after 1 April 2025.”

66

Clause 63, page 68, line 10, leave out “£32.79” and insert “£31.64”

67

Clause 82, page 95, line 14, at end insert—
“(2) In doing so His Majesty’s Revenue and Customs must have regard to the desirability of requiring a digital tax stamp to be applied to e-cigarette liquids.”

This amendment requires HMRC to have regard for requiring a digital tax stamp to be applied to e-cigarette liquids.

NC10

To move the following Clause—
“Review of business taxes
(1) The Chancellor of the Exchequer must, within six months of this Act being passed—
(a) conduct a review of business taxes, and
(b) lay before the House of Commons a report setting out recommendations arising from the review.
(2) The review must make recommendations on how to—
(a) use business taxes to encourage and increase the investment of profits and revenue; and
(b) ensure businesses have more certainty about the taxes to which they are subject.
(3) In this section, “business taxes” includes any tax in respect of which this Act makes provision that is paid by a business.”

This new clause would require the Chancellor to conduct a review of business taxes, and to make recommendations on how to increase certainty and investment, before the next Finance Bill is published.

NC11

To move the following Clause—
“Review of impact of tax changes in this Act on households
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the changes in this Act on household finances.
(2) The assessment in subsection (1) must consider how households at a range of different income levels are affected by these changes.”

This new clause requires the Chancellor to publish an assessment of the changes in this Act on the finances of households at a range of different income levels.

NC12

To move the following Clause—
“Review of effects of the Act on small businesses
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the likely impact of the measures in this Act on small businesses.
(2) The report must assess the effect on small businesses of any taxes charged under this Act, in the context of other financial pressures currently facing small businesses.”

This new clause would require the Government to produce an impact assessment of the effect of the Act on small businesses.

15

Clause 21, page 11, line 21, after “is” insert “or has been”

This amendment makes it clear that new section 690 applies if an employee has been internationally mobile in a tax year, even if the employee is no longer internationally mobile.

16

Clause 21, page 12, line 4, after “being” insert “or having been”

This amendment is consequential on Amendment 15.

17

Clause 21, page 12, line 22, after “is” insert “or has been”

This amendment makes it clear that a notice under new section 690A can be given during the mobile tax year if the employee has been internationally mobile during that year, even if the employee is no longer internationally mobile.

18

Clause 21, page 13, line 22, leave out “public notice given” and insert “general direction made”

This amendment means that the requirements of notices under new section 690A will be specified in a general direction made by HMRC rather than a public notice.

19

Clause 21, page 15, line 38, at end insert—
“(3) Any direction given by an officer of Revenue and Customs under section 690 of ITEPA 2003 (employee non-resident etc) has no effect in relation to tax year 2025-2026 or any subsequent tax year.”

This amendment means that any direction given under the old section 690 will cease to have effect in relation to future tax years.

20

Clause 37, page 31, line 21, at end insert—
“

This amendment provides for income treated as arising to a settlor of a trust as a result of a capital payment made by the trustees to be eligible for relief to the extent that the deemed income arises from foreign income.

3

Schedule 4, page 133, line 20, at end insert—
“Use of substituted values
11A (1)After section 137 insert—
137AUse of substituted values
(1)Where any provision of this Part requires the substitution of a value recorded in the underlying profits accounts of a member of a multinational group for an accounting period, the substituted value—
(a)is to be used for all purposes of this Part instead of the value recorded in the accounts (for example, where the carrying value of an asset has been substituted and the value of that asset is relevant to the member’s deferred tax expense, that substituted value is to be used in connection with determining that expense), and
(b)is to be updated (for example, in making adjustments for depreciation for subsequent accounting periods),
in each case, in accordance with the accounting standard used in determining the underlying profits of the member.
(2)But where the value in question is the value of an asset, no adjustments for impairment are to be made to it.
(3)Where the impaired value of an asset recorded in the underlying profits accounts for any accounting period is less than the substituted value of the asset for that period, use the value from the underlying profits accounts instead for that period and all subsequent periods (and subsection (2) does not apply in relation to that value).”
(2)In section 197 (eligible tangible asset amount), in subsection (3)—
(a)after “means” insert “values”, and
(b)after “parent” insert “(and not values as substituted as a result of any other provision of this Part)”.”

This amendment clarifies how substituted values are to be used when determining profits for the purposes of multinational top-up tax (and domestic top-up tax).

21

Schedule 4, page 135, line 27, leave out “entities”

This amendment corrects a substitution.

22

Schedule 4, page 145, line 28, leave out from beginning to end of line 28 on page 146 and insert—
“198ZA Eligible payroll costs: flow-through entities
(1) A member of a multinational group that is a flow-through entity has a flow-through payroll amount for a territory for an accounting period if the member has costs that would be eligible payroll costs if the member were located in that territory and were not a flow-through entity and—
(a) there is at least one other member of the group—
(i) that is not a flow-through entity,
(ii) that is located in that territory, and
(iii) to whom a proportion of the underlying profits of the flow-through entity for the accounting period are allocated under section 168 (underlying profits of transparent entities) or, where the underlying profits of the entity are nil or less, would be so allocated if the flow-through entity had underlying profits of 100 euros, or
(b) the entity—
(i) is a flow-through entity to some extent for that period as a result of section 169 (certain non tax resident entities to be treated as flow-through entities),
(ii) is not a flow-through entity to some extent for that period, and
(iii) was created in that territory.
(2) Section 196 applies for the purposes of determining a flow-through payroll amount of a flow-through entity for a territory as it applies for the purposes of determining eligible payroll costs but as if—
(a) any reference in that section to the territory of the member were to the territory to which the flow-through payroll amount relates, and
(b) subsection (7) of that section were omitted.
(3) Where a member of a multinational group that is a flow-through entity has a flow-through payroll amount for a territory for an accounting period, the eligible payroll costs of each member of the group falling within subsection
(1)(a)
for that period (which may be nil) are to be increased by the amount given by multiplying the flow-through payroll amount by the relevant proportion in relation to that member for that period.
(4) The relevant proportion in relation to a member for an accounting period is the proportion of the underlying profits of the flow-through entity for that period—
(a) in a case where the flow-through entity has underlying profits that exceed nil for that period, that is allocated to that member under section 168, or
(b) in a case where the underlying profits of the flow-through entity for that period are nil or less, that would be allocated to that member if the flow-through entity had underlying profits of 100 euros.
(5) Where a flow-through entity—
(a) is a flow-through entity to some extent for an accounting period as a result of section 169,
(b) is not a flow-through entity to some extent for that period, and
(c) was created in a territory for which it has a flow-through payroll amount for that period,
the eligible payroll costs of that entity for that period (which may be nil) are to be increased by the amount given by multiplying that flow-through payroll amount by the relevant proportion in relation to that entity for that period.
(6) The relevant proportion in relation to that entity for an accounting period is the proportion of the underlying profits of the entity for that period—
(a) in a case where the entity has underlying profits that exceed nil for that period, that are not allocated to any other entity under section 168, or
(b) in a case where the underlying profits of the entity for that period are nil or less, that would not be allocated to any other entity under that section if the entity had profits of 100 euros.
(7) For the purposes of applying this section in relation to a multinational group whose ultimate parent is a flow-through entity, the ultimate parent is to be treated as not being a flow-through entity.
198ZB Eligible tangible asset amount: flow-through entities
(1) A member of a multinational group that is a flow-through entity that is not the ultimate parent has a flow-through tangible asset amount for a territory for an accounting period if the member holds one or more assets in that territory and—
(a) there is at least one other member of the group—
(i) that is not a flow-through entity,
(ii) that is located in that territory, and
(iii) to whom a proportion of the underlying profits of the flow-through entity for the accounting period are allocated under section 168 (underlying profits of transparent entities) or, where the underlying profits of the entity are nil or less, would be so allocated if the flow-through entity had underlying profits of 100 euros, or
(b) the entity—
(i) is a flow-through entity to some extent for that period as a result of section 169 (certain non tax resident entities to be treated as flow-through entities),
(ii) is not a flow-through entity to some extent for that period, and
(iii) was created in that territory.
(2) Sections 197 and 197A apply for the purposes of determining a flow-through tangible asset amount of a flow-through entity for a territory as they apply for the purposes of determining an eligible tangible asset amount but as if—
(a) any reference in those sections to the territory of the member were to the territory to which the flow-through tangible asset amount relates, and
(b) subsection (10) of section 197 were omitted.
(3) Where a member of a multinational group that is a flow-through entity has a flow-through tangible asset amount for a territory for an accounting period, the eligible tangible asset amount of each member of the group falling within subsection
(1)(a)
for that period (which may be nil) is to be increased by the amount given by multiplying the flow-through tangible asset amount by the relevant proportion in relation to that member for that period.
(4) The relevant proportion in relation to a member for an accounting period is the proportion of the underlying profits of the flow-through entity for that period—
(a) in a case where the flow-through entity has underlying profits that exceed nil for that period, that is allocated to that member under section 168, or
(b) in a case where the underlying profits of the flow-through entity for that period are nil or less, that would be allocated to that member if the flow-through entity had underlying profits of 100 euros.
(5) Where a flow-through entity—
(a) is a flow-through entity to some extent for an accounting period as a result of section 169,
(b) is not a flow-through entity to some extent for that period, and
(c) was created in a territory for which it has a flow-through tangible asset amount for that period,
the eligible tangible asset amount of that entity for that period (which may be nil) is to be increased by the amount given by multiplying that flow-through tangible asset amount by the relevant proportion in relation to that entity for that period.
(6) The relevant proportion in relation to that entity for an accounting period is the proportion of the underlying profits of the entity for that period—
(a) in a case where the entity has underlying profits that exceed nil for that period, that are not allocated to any other entity under section 168, or
(b) in a case where the underlying profits of the entity for that period are nil or less, that would not be allocated to any other entity under that section if the entity had profits of 100 euros.
(7) For the purposes of applying this section in relation to a multinational group whose ultimate parent is a flow-through entity, the ultimate parent is to be treated as not being a flow-through entity.
198ZC Eligible payroll costs and eligible tangible asset amount: flow-through ultimate parent
(1) In determining for an accounting period the eligible payroll costs or eligible tangible asset amount of a flow-through entity that is the ultimate parent of a multinational group, the amount given by section 196 or 197 is to be reduced by the section 170 proportion.
(2) In subsection (1), “the section 170 proportion” means the proportion of the adjusted profits of the flow-through entity for the accounting period that—
(a) in a case where subsection (1) of 170 (adjustments for ultimate parent that is a flow-through entity) applies, is excluded under that subsection, or
(b) in a case where that subsection does not apply as a result of the entity having not made a profit for that period, would be excluded under that subsection if the entity had adjusted profits of 100 euros.
(3) In subsection (2), “the adjusted profits” means the adjusted profits before the application of section 170.”

This amendment secures that eligible payroll costs and eligible tangible asset amounts are allocated from flow-through entities in a manner that is consistent with the Pillar Two model rules.

23

Schedule 4, page 146, line 28, at end insert—
“32A In section 196 (eligible payroll costs), after subsection (6) insert—
“(7) A member of a multinational group that is a flow-through entity that is a responsible member of the group but which is not the ultimate parent is to be regarded as having nil eligible payroll costs (subject to the application of section 198ZA).”
32B In section 197 (eligible tangible asset amount), after subsection (9) insert—
“(10) A member of a multinational group that is a flow-through entity that is a responsible member of the group but which is not the ultimate parent is to be regarded as having an eligible tangible asset amount of nil (subject to the application of section 198ZB).””

This amendment is consequential on Amendment 22.

4

Schedule 4, page 146, line 34, at end insert—
“Additional top-up amounts
33A In section 203 (additional top-up amounts where covered taxes less than expected), in subsections (4)(b), (5)(b), (6)(b) and (7)(b), for “reduction by relevant QDT credit” substitute “any reduction”.
33B (1)Section 206 (additional top-up amounts where recalculations required) is amended as follows.
(2)In subsection (1)—
(a)in the words before paragraph (a), after “members” insert “(“the current members”)”, and
(b)in paragraph (b), before “members” insert “current”.
(3)In subsection (2)—
(a)in paragraph (a), for “those members would have for a prior period” substitute “the standard members of the group in the territory in a prior period would have for that period”, and
(b)in the words after paragraph (b), before “members” insert “current”.
(4)In subsection (3)—
(a)in Step 1, for “those members would have had for the prior period” substitute “the standard members of the group in the territory for the prior period would have had for that period”,
(b)in Step 3, after “nil” insert “(and if there are no such results, the result of this step is nil)”, and
(c)in Step 4—
(i)before “members” insert “current””, and
(ii)for “Step 2“ substitute “Step 3”.
(5)In subsection (4)—
(a)for “those members” substitute “the current members”, and
(b)for “in accordance with subsections (5) to (8)” substitute “as follows”.
(6)In subsection (5)—
(a)in paragraph (a)—
(i)for “standard” substitute “current”, and
(ii)before “period” insert “current”,
(b)in paragraph (b), for “members for the members’ territory” substitute “current members”, and
(c)in paragraph (c), for “reduction by relevant QDT credit” substitute “any reduction”.
(7)In subsection (6)—
(a)in paragraph (a)—
(i)for “standard” substitute “current”, and
(ii)before “period” insert “current”,
(b)in paragraph (b), for “standard members in the territory” substitute “current members”, and
(c)in paragraph (c), for “reduction by relevant QDT credit” substitute “any reduction”.
(8)In subsection (7)—
(a)in paragraph (a)—
(i)for “standard” substitute “current”,
(ii)before “period”, in the first place it occurs, insert “current”, and
(iii)for “members for the members’ territory” substitute “the current members”, and
(b)in paragraph (b)—
(i)for “reduction by relevant QDT credit” substitute “any reduction”, and
(ii)for “members for the member’s territory” substitute “current members”.
(9)In subsection (8)—
(a)in paragraph (a)—
(i)for “standard” substitute “current”, and
(ii)for “members for the members’ territory” substitute “the current members”,
(b)in paragraph (b)—
(i)for “reduction by relevant QDT credit” substitute “any reduction”, and
(ii)for “members for the member’s territory” substitute “current members”, and
(c)in the words after paragraph (b) for the words from “amount”, in the second place it occurs, to the end substitute “relevant amount.”
(10)After subsection (8) insert—
(9)The relevant amount is the amount given by multiplying—
(a)the sum of the amounts of qualifying domestic top-up tax accrued by the current members in the current period, by
(b)the amount given by dividing—
(i)the collective additional amount under this section, by
(ii)the sum of that collective additional amount, any collective additional amount under section 203 and the total top-up amount for the current period.””

This amendment clarifies how to calculate top-up amounts in cases where amounts for a prior period have had to be recalculated.

5

Schedule 4, page 147, line 6, at end insert—
“(e) in paragraph (f), for “of which the entity is a member” substitute “referred to in paragraph (a)”.”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 6, 7, 8, 9, 10 and 11.

6

Schedule 4, page 147, line 12, at end insert—
“(ia) after “Part”, in the second place it occurs, insert “, this Chapter other than this section and section 226”, and”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 7, 8, 9, 10 and 11.

7

Schedule 4, page 147, line 33, leave out “where” and insert “if”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 6, 8, 9, 10 and 11.

8

Schedule 4, page 147, line 35, leave out “of the group has” and insert “meets Condition A and Condition B for that period”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 6, 7, 9, 10 and 11.

9

Schedule 4, page 147, line 37, after “group” insert “(the “relevant group”)”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 6, 7, 8, 10 and 11.

10

Schedule 4, page 147, line 39, leave out “of the group have,” and insert “meet Condition C for that period and—
(i) all of those members are located in the United Kingdom, or
(ii) the relevant group is a multinational group (see section 126 in Part 3), and at least one of the members is located in a Pillar Two territory.”

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 6, 7, 8, 9, and 11.

11

Schedule 4, page 147, leave out lines 40 and 41

This amendment forms part of a series of amendments designed to make sure that multinational top-up tax, and domestic top-up tax, apply properly in cases involving joint ventures. See also amendments 5, 6, 7, 8, 9, and 10.

24

Schedule 4, page 151, line 19, leave out “(e)” and insert “(d)”

This amendment corrects an incorrect cross-reference.

25

Schedule 4, page 153, line 12, after “establishment” insert “and that is incurred in the territory of the permanent establishment”

This amendment ensures the correct allocation of tax of an entity with a permanent establishment.

26

Schedule 4, page 154, line 36, leave out “(2)(a)(i)” and insert “
(2)(a)(ii)
”

This amendment corrects an incorrect cross-reference.

27

Schedule 4, page 159, line 42, leave out “territory” and insert “tax”

This amendment corrects an error.

28

Schedule 4, page 160, line 28, after second “return” insert “notification”

This amendment ensures the correct document is referred to.

29

Schedule 4, page 160, line 29, after “return” insert “or notification”

This amendment is consequential on Amendment 28.

12

Schedule 4, page 161, line 32, at end insert—
“54A In section 211 (transfer of assets or liabilities to a member of a multinational group)—
(a) in subsection (2)—
(i) omit the “and” after paragraph (b), and
(ii) after that paragraph insert—
“(ba) the transferor and the transferee are not members of the same type located in the same territory, and”, and
(b) after subsection (4) insert—
“(5) For the purposes of subsection (2) two members of a multinational group are of the same type if—
(a) they are both standard members of the group,
(b) they are both investment entities, or
(c) they are both members of the same minority subgroup (see section 228).””

This amendment removes the requirement for a transfer between members of a multinational group to be reflected on the arm’s length basis where the members are of the same type and in the same jurisdiction.

13

Schedule 4, page 162, line 7, at end insert—
“58A In section 217(8), for paragraph (a) substitute—
“(a) the aggregate covered tax balance of the standard members of the group in the territory of the member for the prior period is not reduced by 1 million euros or more, and”.
58B In section 220 (top-up amount of investment entity)—
(a) in subsection (1)—
(i) in Step 8, after “entity” insert “, unless the entity has a positive undistributed income amount (see sections 214 and 215) for the period (in which case proceed to Step 9), and
(ii) after that Step insert—
“Step 9 Where this Step applies, the top-up amount for the entity is the sum of—
(a) the result of Step 8, and
(b) the positive undistributed income amount for the entity for the period multiplied by 15%.”, and
(b) omit subsection (2).”

This amendment secures that a decrease in covered taxes in a previous accounting period is insignificant (and will therefore be ignored) only if the aggregate of covered taxes payable by the standard members is not reduced by 1 million euros or more, and also corrects an error in the calculation of multinational top-up tax payable in relation to investment entities that would have resulted in an excessive liability.

30

Schedule 4, page 162, line 16, at end insert—
“62A In Schedule 16A (multinational top-up tax: safe harbours), in paragraph 4(1)(b) omit “members of the group that are”.”

This amendment secures that the provision amended refers to members of a joint venture group, rather than the members of a group that owns the joint venture.

14

Schedule 4, page 162, line 24, at end insert—
“(f) paragraph 58B (top-up amount of investment entity).”

This amendment is consequential on Amendment 13 (and provides for part of the amendment made by that amendment to have effect for accounting periods beginning on or after 31 December 2023).

31

Schedule 4, page 162, line 34, leave out “by the filing member”

This amendment clarifies how the retrospection election is to be made.

32

Schedule 4, page 162, line 35, leave out “group or qualifying entity” and insert “a group, or a qualifying entity that is not a member of a group”

This amendment clarifies how the retrospection election is to be made.

33

Schedule 4, page 162, line 40, at end insert—
“(za) is to be made—
(i) in the case of a multinational group or group, by the filing member, or
(ii) in the case of a qualifying entity that is not a member of a group, by that entity,”

This amendment clarifies how the retrospection election is to be made.

34

Schedule 4, page 163, line 6, after “member” insert “, or former member,”

This amendment clarifies that consent may be required of former members of a group or multinational group where they could have a liability to domestic top-up tax.

35

Schedule 4, page 163, line 8, after “tax” insert “that has top-up amounts or additional top-up amounts for any accounting period commencing before 31 December 2024 as a result of the person’s membership of the multinational group or group”

This amendment and amendment 36 make sure that it is only members of a group actually liable to tax that must give consent for the retrospection election.

36

Schedule 4, page 163, line 9, after “entity” insert “that has top-up amounts or additional top-up amounts for any accounting period commencing before 31 December 2024 as a result of the entity’s membership of the multinational group or group”

This amendment and Amendment 35 make sure that it is only members of a group actually liable to tax that must give consent for the retrospection election.

37

Schedule 4, page 163, line 22, at end insert—
(9A)Sub-paragraph (9B) applies where—
(a)the filing member of a multinational group or group has made a retrospection election,
(b)at the time the election was made it was reasonable for the filing member to consider that the consent of a person was not required,
(c)that consent was not given,
(d)the filing member becomes aware that the consent of that person was, or may have been, required, and
(e)the written consent of that person is given within the period of 60 days beginning with the day on which the condition in paragraph (d) is first met.
(9B)The consent of that person is to be treated as having been given before the election was made.”

This amendment allows retrospective consent to be given in respect of elections.

38

Schedule 6, page 180, line 32, leave out “by a person (“P”) other than a company”

This amendment allows for the distributions relief to be given in circumstances where the capital gains tax relief for employee ownership trusts is not available because the vendor of the shares in the company to which the employee ownership trust relates is a company (provided the other conditions for the capital gains tax relief being given are met).

39

Schedule 6, page 181, line 2, at end insert—
“(d) the payment was made for the purposes of meeting the trustees’ acquisition costs.”

This amendment requires that the distribution that is the subject of the relief was actually made for the purposes of meeting acquisition costs.

40

Schedule 6, page 181, line 10, after “trusts)” insert “, but those requirements have effect for the purposes of this section as if references to “P” were to the person making the disposal whether or not that person is a company”

This amendment is consequential on Amendment 38, and secures that the capital gains tax relief requirements are capable of applying properly in circumstances where the vendor of the shares in the company to which the employee ownership trust relates is a company.

41

Schedule 6, page 181, line 11, leave out “subsection (2)” and insert “this section”

This amendment is consequential on Amendment 39 (and secures that “acquisition costs” is defined for the purposes of the whole section).

42

Schedule 6, page 181, line 12, after “are” insert “sums expended by the trustees on”

This amendment, and Amendment 43, expand the scope of acquisition costs that can benefit from the relief.

43

Schedule 6, page 181, leave out lines 13 to 19 and insert—
“(a) the acquisition of ordinary share capital in C by the trustees that resulted from the disposal;
(b) the repayment of any sums borrowed to fund that acquisition;
(c) the payment of interest on any such sums or in respect of any deferral of consideration for the disposal to the extent the payment is not in respect of interest exceeding a reasonable commercial rate;
(d) any valuation of C carried out in connection with the acquisition;
(e) any liability to stamp duty or stamp duty reserve tax on the acquisition;
(f) such other reasonable expenses as are directly connected with the acquisition (but this does not include any expenses incurred in connection with the ownership of the ordinary share capital once acquired).”

This amendment, and Amendment 42, expand the scope of acquisition costs that can benefit from the relief.

44

Schedule 8, page 194, line 33, leave out “qualifying” and insert “non-resident or qualifying”

This amendment is to make parenthetical description of sections 373 and 374 of ITEPA 2003 consistent with those sections as amended by Schedule 8.

45

Schedule 8, page 194, line 39, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee must not be a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005 to benefit from a deduction under section 341 of ITEPA 2003, as well as not being a qualifying new resident for the purposes of ITEPA 2003.

46

Schedule 8, page 195, line 4, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee must not be a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005 to benefit from a deduction under section 342 of ITEPA 2003, as well as not being a qualifying new resident for the purposes of ITEPA 2003.

47

Schedule 8, page 195, line 11, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee can benefit from deductions under section 355 of ITEPA 2003 where the employee is a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005, as well as where the employee is a qualifying new resident for the purposes of ITEPA 2003.

48

Schedule 8, page 195, line 13, leave out “qualifying” and insert “non-resident or qualifying”

This amendment is to make the parenthetical description of section 373 of ITEPA 2003 consistent with that section as amended by Schedule 8.

49

Schedule 8, page 195, line 36, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee can benefit from deductions under section 373 of ITEPA 2003 where the employee is a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005, as well as where the employee is a qualifying new resident for the purposes of ITEPA 2003.

50

Schedule 8, page 196, line 7, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee can benefit from deductions under section 374 of ITEPA 2003 where the employee is a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005, as well as where the employee is a qualifying new resident for the purposes of ITEPA 2003.

51

Schedule 8, page 196, leave out line 16

This amendment reinstates section 375 of ITEPA 2003 which defines “qualifying arrival date” for the purposes of sections 373 and 374 of ITEPA 2003.

52

Schedule 8, page 196, line 21, after “Part 2” insert “of this Act or Chapter 5 of Part 8 of ITTOIA 2005 (see section 845B of that Act)”

This amendment provides that an employee must not be a qualifying new resident for the purposes of Chapter 5 of Part 8 of ITTOIA 2005 to benefit from a deduction under section 376 of ITEPA 2003, as well as not being a qualifying new resident for the purposes of ITEPA 2003.

53

Schedule 8, page 197, line 17, at end insert—
“2A In Part 8 of Schedule 3 to the Social Security (Contributions) Regulations 2001 (S.I. 2001/1004), in paragraph 5 (travel costs and expenses where duties performed in the United Kingdom) —
(a) in the heading, for “non-domiciled” substitute “non-resident or qualifying new resident”;
(b) in paragraph (a), for “non-domiciled” substitute “non-resident or qualifying new resident”.”

This amendment makes the parenthetical descriptions of sections 373 and 374 of ITEPA 2003 contained in the Social Security (Contributions) Regulations 2001 consistent with those sections as amended by Schedule 8.

54

Schedule 8, page 198, line 32, leave out “public notice given” and insert “general direction made”

This amendment means that the requirements of notices under new section 690D will be specified in a general direction made by HMRC rather than a public notice.

55

Schedule 9, page 208, line 24, leave out “sections 56(5)(a), 61G(5)(a) and 61R(5)(a)” and insert “sections 56, 61G and 61R”

This amendment together with Amendment 56 omits subsections that have become redundant in light of the ending of the relevance of domicile to income tax.

56

Schedule 9, page 208, line 25, leave out from “payment)” to end of line 27 and insert “, omit subsections (4) and (5).”

This amendment together with Amendment 55 omits subsections that have become redundant in light of the ending of the relevance of domicile to income tax.

57

Schedule 9, page 210, line 34, at end insert—
“Premium trust funds
21A In section 174 of FA 1993 (premium trust funds), omit subsection (6)(a).
FOTRA securities
21B (1)In section 22 of F(No.2)A 1931 (Treasury power to issue securities with a FOTRA condition)—
(a)in subsection (1)(b), for “persons who are neither domiciled nor resident in the United Kingdom” substitute “exempt persons”;
(b)after subsection (1) insert—
(1A)For the purposes of subsection (1), the following persons are “exempt persons”—
(a)individuals who are not resident in the United Kingdom, and
(b)persons who are not individuals and are neither domiciled nor resident in the United Kingdom.”
(2)In section 154 of FA 1996 (FOTRA securities), in subsection (1)—
(a)after “applies,” insert “where the person with the beneficial ownership of the securities is not an individual and”;
(b)for “the person with beneficial ownership of the securities” substitute “that person”.
(3)Any security issued before 29th April 1996 with a FOTRA condition shall be treated in relation to times on or after 6 April 2025 as if—
(a)it were a security issued with the post-1996 FOTRA conditions (and with no other FOTRA condition), and
(b)the post-1996 FOTRA conditions had been authorised in relation to the issue of that security by virtue of section 22 of F(No.2)A 1931.
(4)In sub-paragraph (3) —
“a FOTRA condition” means a condition about exemption from taxation authorised by section 22 of F(No.2)A 1931;
“the post-1996 FOTRA conditions” means the conditions about exemption from taxation with which 7.25% Treasury Stock 2007 was first issued by virtue of section 22 of F(No.2)A 1931.”

58

Schedule 9, page 210, line 34, at end insert—
“Reliefs in respect of income from investments etc. of certain pension schemes
21C In section 614 of the Income and Corporation Taxes Act 1988 (exemptions and reliefs in respect of income from investments etc. of certain pension schemes), in subsections (4) and (5), omit “not domiciled and”.”

This amendment removes references to domicile in provisions of the Income and Corporation Taxes Act 1988 relating to relief on income from investments of certain pension schemes.

59

Schedule 10, page 214, line 6, leave out paragraph (a) and insert—
“(a) Part 2 of this Schedule (exemptions etc for designated qualifying overseas capital),”

This amendment corrects an incorrect reference.

60

Schedule 12, page 238, leave out lines 21 to 23 and insert—
“(b) the original recipient—
(i) is liable neither to income tax nor to capital gains tax by reference to the amount or value of the original benefit, or
(ii) is a qualifying new resident for the tax year in which the original benefit is provided,”

This amendment expands the scope of the onward gifting rule to circumstances where benefits are routed via individuals who are UK resident but who are not themselves within the scope of the benefits charge (because they are not the settlor or a close family member).

61

Schedule 12, page 239, line 41, at end insert—
“(5A) Where the original recipient is liable neither to income tax nor to capital gains tax by reference to the amount or value of part only of the original benefit, this section applies as if the two parts of the original benefit were separate benefits.”

This amendment supplements Amendment 60.

62

Schedule 13, page 266, line 35, at end insert—
(2A)In subsection (1)—
(a)in the definition of “excluded property”, for “6 and 48” substitute “6, 48 and 48ZA”;
(b)omit the definition of “formerly domiciled resident”.”

This amendment updates the definition of “excluded property” in section 272 of the Inheritance Tax Act 1984 in consequence of the amendments made by clause 45. It also removes the now-redundant definition of “formerly domiciled resident”.

63

Schedule 13, page 266, line 36, at beginning insert “Also”

This amendment is consequential on Amendment 62.

64

Schedule 13, page 267, line 25, at end insert—
““28A (1)Schedule A1 (non-excluded overseas property) is amended as follows.
(2)In paragraph 1, for “48(3)(a)” substitute “48ZA”.
(3)In paragraph 5(2)(a), for “or 48(3)(a), (3A) or (4)” substitute “, section 48(4) or section 48ZA”.”

This amendment is consequential on clause 45 (which amends section 48 of the Inheritance Tax Act 1984 and inserts new section 48ZA).

65

Schedule 13, page 271, line 39, at end insert—
(1A)In construing section 267 of IHTA 1984, so far as saved by sub-paragraph (1), the repeal of the definition of “formerly domiciled resident” by paragraph
28(2A)(b)
is also to be disregarded.”

This amendment clarifies that the definition of “formerly domiciled resident”, which is being removed from the Inheritance Tax Act 1984 by Amendment 62, will still be relevant in construing section 267 (which by virtue of paragraph 48 of Schedule 13 will continue to apply for certain limited purposes).

NC9

To move the following Clause—
“Pupils with SEND without an Education Health and Care Plan: review of VAT provisions
(1) The Chancellor of the Exchequer must, within six months of the passing of this Act and every six months thereafter, lay before Parliament a review of the impact of the measures contained in sections 47 to 49 of this Act on pupils with special educational needs and disabilities.
(2) The review must consider in particular the impact of those measures on—
(a) children with special needs who do not have an education health and care plan (EHCP); and
(b) the number of children whose families have applied for an EHCP.”

This new clause would require the Government to produce an impact assessment of the effect of the VAT provisions in the Act on pupils who have special educational needs but do not have an Education Health and Care Plan.

NC8

To move the following Clause—
“Statements on charging VAT on private school fees
(1) The Secretary of State must, within six months of this Act being passed, make a statement to Parliament about the removal of the exemption for private school fees introduced by section 47 of this Act, and other changes to private school fees introduced by sections 48 and 49 of this Act.
(2) The statement under subsection (1) must include details of the impact on—
(a) pupils with special educational needs and disabilities,
(b) small rural schools, and
(c) faith schools.
(3) The Secretary of State must, within 18 months of this Act being passed, make a statement about the impact of the removal of the exemption on schools that take part in the music and dance scheme.”

This new clause requires the Secretary of State to make a statement about the impact of charging VAT on private school fees.

NC6

To move the following Clause—
“Sections 50 and 51: impact on private rental sector
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the changes introduced by sections 50 and 51 of this Act on the private rental sector in England and Northern Ireland.
(2) The assessment in subsection (1) must consider—
(a) the effects of the provisions of sections 50 and 51 of this Act on the cost of private rent in each region within England and in Northern Ireland,
(b) the effects of the provisions of sections 50 and 51 of this Act on the supply of private rental properties in each region within England and Northern Ireland,
(c) any other implications of the changes introduced by sections 50 and 51 of this Act.”

This new clause requires the Chancellor to review the impact increased rates of stamp duty for additional dwellings are having on the private rental sector in England and Northern Ireland.

NC7

To move the following Clause—
“Review of effects of sections 50 and 51 on housing market
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the changes introduced by sections 50 and 51 of this Act, on the housing market in England and Northern Ireland.
(2) The assessment in subsection (1) must consider—
(a) the effects of the provisions of sections 50 and 51 of this Act on the demand for houses in each region within England and Northern Ireland, and
(b) the implications for the housing market of the provisions of sections 50 and 51 of this Act.”

This new clause requires the Chancellor to review the impact increased rates of stamp duty for additional dwellings are having on the housing market in England and Northern Ireland.

1

Page 10, line 20, leave out Clause 18

This amendment, along with Amendment 2, seeks to scrap the proposed relief for carbon capture and storage installations.

NC1

To move the following Clause—
“Impact assessment: capital gains tax
The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a review of the impact of the measures contained in clauses 7 to 12 and schedules 1 and 2 of this Act, on—
(a) long-term investment;
(b) disposable income across different income deciles, and
(c) tax revenue.”

This new clause would require the Government to produce a report setting out the impact of changes to Capital Gains Tax made in this Act on investment and the disposable income of taxpayers across different income deciles.

NC2

To move the following Clause—
“Report on fiscal effects: relief for investment expenditure
The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained in clause 16 of this Act on tax revenue.”

This new clause would require the Government to produce a report setting out the fiscal impact of the Bill’s changes to the Energy Profits Levy investment expenditure relief.

NC3

To move the following Clause—
“Changes to energy (oil and gas) profits levy: review
The Chancellor of the Exchequer must, within three months of this Act coming into force, publish a review of the expected impact of the measures in sections 15 to 18 on—
(a) employment in the UK oil and gas industry;
(b) capital expenditure in the UK oil and gas industry;
(c) UK oil and gas production;
(d) UK oil and gas demand; and
(e) the Scottish economy and economic growth in Scotland.”

NC4

To move the following Clause—
“Section 12: review
The Chancellor of the Exchequer must, within three months of this Act coming into force, publish a review of the expected impact of the measures in section 12 of this Act on—
(a) the timing of asset disposals or transactions;
(b) shifting between different assets;
(c) shifting between gains and income;
(d) tax planning;
(e) migration; and
(f) non-compliance by non-payment, misreporting or underreporting of chargeable assets, gains or income.”

NC5

To move the following Clause—
“Business asset disposal relief: review of increase in rate
(1) The Chancellor of the Exchequer must commission and publish an assessment of the expected impact of the provisions of section 8 on the number of Business Asset Disposal Relief claims involving the sale of a business.
(2) The assessment must compare estimates for the number of claims involving the sale of a business in the tax year 2024-25 with the number of such claims in the tax year 2025-26.
(3) The assessment must compare the impact under the provisions of section 8 with what impact could have been expected had the rate remained unchanged”

2

Page 116, line 13, leave out Schedule 3

See explanatory statement for Amendment 1.