Finance (No. 2) Bill 2024-26

31

Schedule 12, page 451, line 22, leave out “30 October 2024" and insert "6 April 2026"

32

Schedule 12, page 452, line 3, leave out “30 October 2024" and insert "6 April 2026"

33

Schedule 12, page 454, line 17, leave out "30 October 2024" and insert “6 April 2026"

34

Schedule 12, page 461, line 3, leave out sub-paragraphs (2) to (4)

35

Schedule 12, page 461, line 21, leave out from "paragraph" to end of paragraph 17(5)(b) and insert "comes into force on 6 April 2026"

36

Schedule 12, page 461, line 28, leave out “30 October 2024" and insert "6 April 2026"

30

Page 102, line 29, leave out Clause 86

None

Schedule 3, page 268, line 14, at end insert— "PART 1A AMENDMENT OF TRANSFER OF ASSETS ABROAD PROVISIONS In section 737 of ITA 2007 (exemption: all relevant post-4 December 2005 transactions), after subsection (4) insert— "(4A) In relation to income falling within subsection (4B) which arises to a person abroad on or after 6 April 2025, in determining whether Condition A or Condition B is satisfied, no regard is to be had to any purpose of avoiding liability to taxation for which the relevant transactions or any of them were effected if and to the extent the relevant transfer and any associated operation were effected before 6 April 2025 in a qualifying tax year. (4B) This subsection applies to income which would be relevant foreign income if it were the individual's or in relation to earlier tax years was income with a non-UK source in respect of which a non-UK domiciled individual would have been taxable only on a remittance basis (assuming any required claim and other steps had been made) if it had been the individual's. (4C) For the purposes of subsection (4A) a qualifying tax year is one for which the individual was not resident in the UK or (for tax years earlier than 2013/14) not ordinarily resident in the UK or, if resident or, as the case may be, ordinarily resident in the UK for that year, the individual was entitled to be taxed on the remittance basis for that year."

None

Schedule 3, page 275, line 20, at end insert— “Disregard of payments or transfers connected with designated qualifying overseas capital 15A After paragraph 13B (as inserted by paragraph 15 of this Schedule) insert— "Disregard of payments or transfers made in connection with the remittance of designated qualifying overseas capital 13C(1) This paragraph applies where an amount is remitted to the United Kingdom in a qualifying year in respect of the deemed income of an individual and— (a) the income is treated as income of the individual under section 721 or 728 of ITA 2007 by reference to income arising to a person abroad in the tax year 2024-25 or an earlier tax year, (b) the deemed income falls within section 721(1)(a) or section 728(1)(a) and is qualifying overseas capital by virtue of paragraph 2, and (c) the qualifying overseas capital is designated by the individual. (2) Subject to sub-paragraph (3), no payment or transfer of assets made in a qualifying year for the purpose of, or in connection with, the remittance of that designated qualifying overseas capital to the individual (whether by the person abroad, or any company or settlement), to the extent that the amount or value of such payments or transfers in that qualifying year does not exceed the aggregate amount of remittances within sub-paragraph (1) for that year, is capable of— (a) being or giving rise to income which is treated as income of the individual under section 721 or 728 of ITA 2007 or any provision of Chapter 5 of Part 5 of ITTOIA 2005; (b) satisfying the capital sum conditions in section 729 of ITA 2007; (c) being or giving rise to income which is taken into account for the purpose of increasing the total relevant income under section 733 of ITA 2007 in relation to that individual or any other individual; or (d) being or giving rise to income arising under a settlement for the purposes of section 648(1) of ITTOIA 2005. (3) When making a designation as qualifying overseas capital in relation to deemed income within sub-paragraph (1) for a qualifying year, the individual must specify the amount, the nature and the parties to the payments or transfers of assets within sub-paragraph (2) which have been or will be made during the qualifying year for the purpose of, or in connection with, the provision of the benefits within sub-paragraph (2). (4) Where a sequence of two or more payments or transfers is made in a qualifying year for the purpose of, or in connection with, the provision of the same amount or value of benefits falling within sub-paragraph (2) in that qualifying year, then for the purpose of determining whether the amount or value of such payments or transfers exceeds the amount or value of such benefits, that sequence is to be treated as a single payment or transfer with an amount or value equal to the payment or transfer within the sequence with the highest amount or value. (5) In this paragraph “qualifying year” means any of the tax years 2025-26, 2026-27 or 2027-28. Disregard of payments or transfers made in connection with the provision of certain benefits 13D(1) This paragraph applies where— (a) an amount of deemed income is qualifying overseas capital in relation to an individual by virtue of paragraph 6(1)(c), and (b) the individual designates that income as qualifying overseas capital. (2) Subject to sub-paragraph (3), no payment or transfer of assets made in a qualifying year for the purpose of, or in connection with, the provision of any benefit to the individual which gave rise to the deemed income within paragraph 6(1)(c) (whether by the person abroad, or any company or settlement), to the extent that the amount or value of such payments or transfers in that qualifying year does not exceed the aggregate amount or value of the benefits provided in that qualifying year, is capable of— (a) being or giving rise to income which is treated as income of the individual under section 721 or 728 of ITA 2007 or any provision of Chapter 5 of Part 5 of ITTOIA 2005; (b) satisfying the capital sum conditions in section 729 of ITA 2007; (c) being or giving rise to income which is taken into account for the purpose of increasing the total relevant income under section 733 of ITA 2007 in relation to that individual or any other individual; or (d) being or giving rise to income arising under a settlement for the purposes of section 648(1) of ITTOIA 2005. (3) When making a designation as qualifying overseas capital in relation to deemed income within sub-paragraph (1) for a qualifying year, the individual must specify the amount, the nature and the parties to the payments or transfers of assets within sub-paragraph (2) which have been or will be made during the qualifying year for the purpose of, or in connection with, the provision of the benefits within sub-paragraph (2). (4) Where a sequence of two or more payments or transfers is made in a qualifying year for the purpose of, or in connection with, the provision of the same amount or value of benefits falling within sub-paragraph (2) in that qualifying year, then for the purpose of determining whether the amount or value of such payments or transfers exceeds the amount or value of such benefits, that sequence is to be treated as a single payment or transfer with an amount or value equal to the payment or transfer within the sequence with the highest amount or value. (5) In this paragraph “qualifying year” means any of the tax years 2025-26, 2026-27 or 2027-28."

24

The Chancellor of the Exchequer

Schedule 12, page 445, line 14, leave out “£1 million” and insert “£2.5 million”

<p>This amendment increases the 100% relief allowance for agricultural property relief and business property relief to £2.5 million.</p>

25

The Chancellor of the Exchequer

Schedule 12, page 450, line 32, leave out “£1 million” and insert “£2.5 million”

<p>This amendment increases the standard maximum allowance for trusts settled by the same person to £2.5 million.</p>

26

The Chancellor of the Exchequer

Schedule 12, page 451, line 20, leave out “£1 million” and insert “£2.5 million”

<p>This amendment increases the maximum allowance for trusts settled before the announcement of the changes to agricultural property relief and business property relief to £2.5 million.</p>

27

The Chancellor of the Exchequer

Schedule 12, page 452, line 18, leave out “£1 million” and insert “£2.5 million”

<p>This amendment increases the maximum allowance for special trusts (e.g. temporary charitable trusts, accumulation and maintenance trusts or trusts for bereaved minors) to £2.5 million.</p>

28

The Chancellor of the Exchequer

Schedule 12, page 454, line 10, leave out “£1 million” and insert “£2.5 million”

<p>This amendment, together with amendment 29, increases the maximum allowance for 18-to-25 trusts to £2.5 million.</p>

29

The Chancellor of the Exchequer

Schedule 12, page 454, line 11, leave out “£1 million” and insert “£2.5 million”

<p>This amendment, together with amendment 28, increases the maximum allowance for 18-to-25 trusts to £2.5 million.</p>

NC1

To move the following Clause— "Section 62: application in Northern Ireland (1) The Chancellor of the Exchequer must, within six months of this Act coming into force, publish an assessment of the effects of the measures in section 62 as they apply in Northern Ireland. (2) The assessment must consider— (a) the number of estates in Northern Ireland expected to be subject to the reduction in agricultural property relief made under this Act, (b) the potential benefits to farmers in Northern Ireland of exempting land used for agricultural purposes from the changes to agricultural property relief made under this Act, (c) the potential costs to the Exchequer of exempting land used for agricultural purposes from the changes to agricultural property relief made under this Act, (d) the impact of the measures on farm succession, land retention, and the viability of agricultural businesses in Northern Ireland, including any potential implications for the resilience and security of the UK's food supply, and (e) any other matters that the Chancellor of Exchequer deems appropriate. (3) In subsection (2), “land used for agricultural purposes” does not include land that falls within the Financial Conduct Authority's definition of a land-banking investment scheme. (4) In carrying out the assessment, the Chancellor of the Exchequer must have regard to— (a) the average farm size and land valuation profile in Northern Ireland, (b) the prevalence of intergenerational family farming in Northern Ireland, (c) the interaction between agricultural property relief and devolved agricultural support schemes, and (d) any disproportionate impact on rural communities in Northern Ireland. (5) The assessment must be carried out following meaningful consultation with— (a) the Department of Agriculture, Environment and Rural Affairs in Northern Ireland, (b) representatives of farmers and land-based businesses in Northern Ireland, and (c) such other persons as the Chancellor of the Exchequer considers appropriate. (6) The Chancellor of the Exchequer must, within three months of publishing the assessment, lay before Parliament a statement setting out the steps the Government intends to take in response to the assessment’s findings. (7) The Chancellor of the Exchequer must keep the operation of the measures in section 62 under review in light of the assessment and publish a further assessment within 18 months of this Act coming into force."

1

Page 77, line 4, leave out Clause 62

3

Schedule 12, page 451, line 22, leave out “30 October 2024” and insert “1 March 2027"

4

Schedule 12, page 452, line 3, leave out “30 October 2024” and insert “1 March 2027"

5

Schedule 12, page 454, line 17, leave out "30 October 2024" and insert "1 March 2027"

6

Schedule 12, page 461, line 2, leave out "6 April 2026” and insert “1 March 2027"

7

Schedule 12, page 461, line 3, leave out sub-paragraphs (2) and (3)

8

Schedule 12, page 461, line 17, leave out "sub-paragraph (3) will not apply" and insert "the transfer will prove to be an exempt transfer”

9

Schedule 12, page 461, line 21, leave out from "paragraph" to end of paragraph 17(5)(b) and insert "comes into force on 1 March 2027"

10

Schedule 12, page 461, line 28, leave out "30 October 2024" and insert "1 March 2027"

11

Schedule 12, page 461, line 31, leave out "6 April 2026" and insert "1 March 2027"

12

Schedule 12, page 461, line 33, leave out "6 April 2026” and insert “1 March 2027"

13

Schedule 12, page 461, line 36, leave out “6 April 2026" and insert "1 March 2027"

14

Schedule 12, page 461, line 38, leave out “6 April 2026” and insert “1 March 2027"

15

Schedule 12, page 462, line 3, leave out "6 April 2026" and insert "1 March 2027"

16

Schedule 12, page 462, line 7, leave out "6 April 2026” and insert “1 March 2027"

17

Schedule 12, page 462, line 15, leave out "6 April 2026” and insert “1 March 2027"

18

Schedule 12, page 462, line 19, leave out "6 April 2026" and insert “1 March 2027"

19

Schedule 12, page 462, line 30, leave out "6 April 2026” and insert “1 March 2027"

20

Schedule 12, page 462, line 35, leave out “6 April 2026” and insert “1 March 2027"

21

Schedule 12, page 464, line 14, leave out “6 April 2026” and insert “1 March 2027"

22

Schedule 12, page 464, line 21, leave out "6 April 2026" and insert "1 March 2027"

23

Schedule 12, page 464, line 27, leave out "6 April 2026” and insert “1 March 2027"

2

Page 442, line 28, leave out Schedule 12