Finance Act 2026

None 140

Page 111, line 3, leave out Clause 88

Opposition Amendment NC1

To move the following Clause—
“Report on fairness and scope of the loan charge settlement opportunity
(1) HM Revenue and Customs must, within 12 months of the passing of this Act, lay before the House of Commons a report on the operation and impact of any loan charge settlement opportunity established under section 25 of this Act.
(2) The report under subsection (1) must in particular consider—
(a) whether the terms of the settlement opportunity are available to individuals who have previously settled or fully paid liabilities arising from disguised remuneration loan arrangements,
(b) whether the terms of the settlement opportunity are available to individuals with disguised remuneration loan arrangements falling outside the loan charge years specified in Part 7A of the Income Tax (Earnings and Pensions) Act 2003,
(c) the extent to which any differences in treatment between these groups and those eligible for the settlement opportunity affect perceptions of fairness, and
(d) the potential impact of such perceptions on future tax compliance and trust in the tax system.
(3) The report must include—
(a) an assessment of whether extending more favourable settlement terms to the groups described in subsection (2)(a) and (b) would improve fairness and consistency, and
(b) any recommendations HMRC consider appropriate in light of that assessment.”

This new clause would require HMRC to report on the operation and fairness of the new loan charge settlement opportunity. It would consider whether more favourable terms are, or should be, available to those who have a already settled or fully paid liabilities, and to those with arrangements outside the loan charge years.

Opposition Amendment NC2

To move the following Clause—
“Report on implementation customer service standards in relation to sections 253 to 258
(1) The Commissioners must, within six months of the commencement of sections 253 to 258, lay before the House of Commons a report setting out—
(a) customer service standards for persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970, including—
(i) maximum waiting times for telephone helpline calls,
(ii) minimum call answering rates,
(iii) maximum response times for written correspondence, and
(iv) availability of in-person support;
(b) measures taken to ensure adequate staffing and resources to meet those standards;
(c) data on actual performance against those standards in each quarter; and
(d) remedial action to be taken where standards are not met.
(2) The customer service standards published under subsection (1) must ensure that persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970 can access support through non-digital channels with service levels comparable to those historically provided before the introduction of Making Tax Digital.
(3) The Commissioners must publish an annual report on compliance with the customer service standards established under subsection (1), and lay a copy of the report before the House of Commons.”

This new clause would require HMRC to establish and publish customer service standards for tax payers exempted from Making Tax Digital requirements due to digital exclusion.

Opposition Amendment NC3

To move the following Clause—
“Report on winter fuel payment charge and related compliance and collection measures
(1) The Commissioners for HM Revenue and Customs must lay before the House of Commons a report on the operation and effects of the charge applied to winter fuel payments where an individual’s income exceeds the relevant threshold, including the compliance and collection arrangements introduced under section 55 and Schedule 10 in relation to that charge.
(2) The report under subsection (1) must in particular consider—
(a) the effect of the charge on people whose income exceeds the threshold by a small amount, and any resulting behavioural impacts,
(b) the administrative complexity and proportionality of introducing a tapered abatement for winter fuel payments,
(c) the potential effect of updating section 7 of the Taxes Management Act 1970 so that a winter fuel payment charge becomes a notifiable liability for tax assessment purposes, including the operation of penalties for failure to notify, and the interaction with existing exceptions for liabilities reflected in PAYE tax coding adjustments or where a taxpayer has already been issued a notice to file a self-assessment return, and
(d) the operation and effectiveness of any new PAYE regulation provisions that allow winter fuel payment charges to be collected via tax code adjustments in year, and which allow HMRC to repay any overpaid income tax related to the charge via the tax code within the same year.”

This new clause would require HMRC to report to Parliament on the operation of the winter fuel payment charge, including its effect on people whose income exceeds the threshold by a small amount. The report would also cover the implications of updating section 7 of the Taxes Management Act 1970 to make winter fuel payment charge liabilities notifiable for tax assessment purposes.

None NC4

To move the following Clause—
“Implementing the prohibition of the promotion of certain tax avoidance arrangements
(1) The Treasury must, within six months of the passing of this Act, consult and report on—
(a) how to ensure the regulations specified under section 156(2) of this Act can address the potential for harm to individuals and small businesses from the promotion online and via social media of tax avoidance arrangements by professionals and by social media tax influencers,
(b) the potential for detriment to individuals who are liable for tax arising from such promotions, and
(c) what steps HMRC should take to inform the public of the risks posed by online tax avoidance arrangements.
(2) The Chancellor of the Exchequer must lay before Parliament a report on the outcome of the consultation under subsection (1), including the steps they plan to take to address any issues identified.
(3) In this section, “tax influencer” means an individual who—
(a) is not a tax professional,
(b) promotes, markets or otherwise encourages participation in a tax avoidance arrangement, and
(c) does so by means of a social media service, where that promotion is carried out—
(i) in the course of a business or trade, or
(ii) in consideration of, or in expectation of, any payment or other benefit, whether from a promoter of the arrangement or from the social media service, or
(iii) with the intention of increasing engagement with, or the monetisation of, content relating to the arrangement.”

Opposition Amendment NC11

To move the following Clause—
“Uprating of allowance amounts for agricultural property
The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”

Opposition Amendment NC12

To move the following Clause—
“Review of anti-forestalling provisions relating to Agricultural Property Relief
(1) The Treasury must conduct a review of the effects of the anti-forestalling provisions relating to Agricultural Property Relief.
(2) The review must, in particular, consider the effects of those provisions on—
(a) succession planning and intergenerational transfer of agricultural land and businesses,
(b) the viability and continuity of family-run farms,
(c) food security and domestic agricultural production,
(d) land management, environmental stewardship, and the condition of the countryside, and
(e) the availability of agricultural land for active farming.
(3) In conducting the review, the Treasury must consult such persons as it considers appropriate, including representatives of the agricultural sector.
(4) The Treasury must lay before the House of Commons a copy of the report within 12 months of the coming into force of the anti-forestalling provisions under this Act.”

Opposition Amendment NC13

To move the following Clause—
“Review of impact of Act on complexity of the tax system and administrative burdens
(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 the complexity of the tax system and the costs of tax administration.
(2) The report under subsection (1) must identify the measures in this Act which—
(a) add to the complexity of the tax system;
(b) reduce the complexity of the tax system;
(c) increase the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(d) reduce the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(e) increase the resources required for HM Revenue and Customs to administer the tax system and ensure compliance; and
(f) reduce the resources required for HM Revenue and Customs to administer the tax system and ensure compliance.
(3) The report must include an assessment of the impact of this Act on the complexity of the tax system, and on the time and cost of tax administration and compliance, for each of the following groups—
(a) pensioners;
(b) taxpayers on low incomes;
(c) personal taxpayers as a whole;
(d) self-employed people;
(e) microbusinesses;
(f) small and medium-sized businesses;
(g) large businesses;
(h) personal representatives who administer a person’s estate after their death;
(i) professional tax advisers; and
(j) HM Revenue and Customs.”

This new clause would require the Chancellor to conduct an assessment of the impact of the Act on the complexity of the tax system and on the time and cost of tax administration for taxpayers and their representatives, and for HMRC.

Opposition Amendment NC14

To move the following Clause—
“Review of impact on unemployment and youth employment
(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report reviewing the impact of the provisions of this Act on levels of unemployment in the UK.
(2) The report under subsection (1) must, in particular, assess—
(a) the impact of the provisions of this Act on overall unemployment levels;
(b) the impact on employment levels for persons aged 16 to 24;
(c) the impact on rates of economic inactivity among young people;
(d) the effect on youth participation in apprenticeships, training, and entry-level employment;
(e) regional variations in youth unemployment arising from the provisions of this Act; and
(f) the impact on sectors with high levels of youth employment, including hospitality, retail, and the creative industries.
(3) The report must include an assessment of—
(a) the extent to which changes made by this Act have affected hiring decisions by small and medium-sized enterprises;
(b) any disproportionate impact on disadvantaged young people, including those from low-income households or with disabilities; and
(c) projected impacts over a three-year period following the passing of this Act.
(4) The Chancellor of the Exchequer must, following publication of the report under subsection (1), make a statement setting out what steps, if any, the Government proposes to take in response to its findings.”

This new clause requires the Chancellor to review and report on the impact of the Act on unemployment, with particular regard to young people aged 16 to 24.

Opposition Amendment NC15

To move the following Clause—
“Notification of taxpayers affected by frozen thresholds
(1) HM Revenue and Customs must take reasonable steps to identify individuals who, as a result of—
(a) the freezing of the starting rate limit for savings under section 9 of this Act, or
(b) the freezing of the personal allowance or the basic rate limit under section 10 of this Act, will—
(i) become liable to income tax for the first time, or
(ii) become liable to income tax at a higher rate than in the previous tax year.
(2) HM Revenue and Customs must ensure that each individual identified under subsection (1) is provided with a written notification before the start of the relevant tax year.
(3) A notification under subsection (2) must—
(a) explain that the individual’s tax liability is affected by the freezing of income tax thresholds,
(b) state whether the individual will pay income tax for the first time or move into a higher tax band, and
(c) provide information on where the individual can obtain further guidance about their tax position.
(4) HM Revenue and Customs must publish, no later than six months after the end of each affected tax year, a report setting out—
(a) the number of individuals notified under this section,
(b) the number of individuals who became income taxpayers for the first time as a result of sections 9 and 10, and
(c) the number of individuals who moved into a higher tax band as a result of those sections.
(5) In this section “written notification” includes electronic communication.”

This new clause would require HM Revenue and Customs to notify individuals who, as a result of the freezing of income tax thresholds in the Act, will pay income tax for the first time or move into a higher tax band.

Opposition Amendment NC16

To move the following Clause—
“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 changes introduced by sections 9,10 and 69 on household finances.
(2) The assessment must evaluate how households across different income levels are affected by these changes.”

This new clause requires the Chancellor of the Exchequer to assess and publish a report on how the freezing of tax thresholds to 2030-31 impacts households at various income levels.

Opposition Amendment NC17

To move the following Clause—
“Report on impact of sections 9, 10 and 69
Within three months of this Act being passed, the Chancellor of the Exchequer must lay before the House of Commons a report setting out—
(a) the number of taxpayers who will pay income tax at each rate during each tax year between 2026-27 and 2030-31 under sections 9, 10 and 69,
(b) the number of those taxpayers who are pensioners or are of State Pension Age,
(c) comparative figures for each tax year since 2020-21,
(d) comparative projected figures for each tax year to 2034-35, and
(e) comparative figures with a scenario under which normal uprating policy had been implemented for financial years 2020-21 through 2030-31.”

This new clause requires the Chancellor of the Exchequer to assess how many people will be in each income tax bracket from 2026-27 through to 2030-31, together with comparative figures before and after that period.

Opposition Amendment NC18

To move the following Clause—
“Review of the effect of sections 63 to 68
(1) HM Treasury must carry out a review of the effect of sections 63 to 68 of this Act (Pension interests).
(2) The review under subsection (1) must include an assessment of—
(a) the impact of those sections on individuals’ pension savings and beneficiaries, including on estate values and inheritance tax liabilities,
(b) the administrative effects on personal representatives, pension scheme administrators, and HM Revenue and Customs, and
(c) any behavioural effects on how pensions are used during life and on death.
(3) HM Treasury must lay before the House of Commons a report setting out the findings of the review under subsection (1) no later than six months after the date on which sections 63 to 68 come into force.”

This new clause would require HM Treasury to review and report on the effects of Clauses 63 to 68 of the Bill, which introduce inheritance tax charges on unused pension funds and death benefits, including their impacts on individuals, administrators, and behaviour, and to publish the findings to Parliament.

Opposition Amendment NC19

To move the following Clause—
“Administration of inherited pension pots
(1) HM Revenue and Customs must review the tax administration arrangements relating to inherited pension pots.
(2) The purpose of the review under subsection (1) is to ensure that—
(a) inheritance tax and related tax checks do not cause unreasonable delays in the payment of pension death benefits to beneficiaries, and
(b) bereaved families are able to receive pension benefits within a reasonable period following a member’s death.
(3) In carrying out the review, HM Revenue and Customs must have regard to—
(a) the cumulative administrative burden placed on personal representatives, pension scheme administrators, and beneficiaries,
(b) the interaction between inheritance tax reporting, clearance processes, and pension scheme payment rules, and
(c) any evidence of prolonged delays in the payment of inherited pension benefits.
(4) HM Revenue and Customs must publish the outcome of the review, including any proposed changes to its processes or guidance, within 12 months of the passing of this Act.”

This new clause would require the Government to address delays in the payment of inherited pension pots by reviewing HMRC’s tax administration processes, with the aim of preventing prolonged waiting periods for bereaved families.

Opposition Amendment NC20

To move the following Clause—
“Review of cumulative impact on the hospitality sector
(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before the House of Commons a report assessing the cumulative impact on the hospitality sector of—
(a) the measures contained in section 86 of this Act, and
(b) changes to taxation and business costs affecting that sector introduced outside this Act since 2020.
(2) For the purposes of subsection (1)(b), changes to taxation and business costs include, but are not limited to—
(a) changes to employer National Insurance contribution rates or thresholds,
(b) changes to business rates, including reliefs and revaluations, and
(c) any other fiscal measures which materially affect operating costs for hospitality businesses.
(3) A report under subsection (1) must include an assessment of the impact of the matters listed in that subsection on—
(a) levels of employment across the United Kingdom within the hospitality sector,
(b) the number of hospitality businesses ceasing to trade,
(c) the number of new hospitality businesses established, and
(d) the financial sustainability of hospitality businesses.
(4) In this section, “the hospitality sector” means persons or businesses operating in the provision of food, drink, accommodation, or related services.”

This new clause would require the Chancellor of the Exchequer to assess and report on the cumulative impact on the hospitality sector of alcohol duty measures in the Act alongside wider fiscal changes, including employer National Insurance contributions and business rates.

None 112

Clause 13, page 6, line 13, leave out from “means—” to “fifteenth” on line 16

None 113

Clause 13, page 6, line 20, leave out from “(1)” to end of line 23 and insert “for “£3 million” substitute “£6 million””

None 114

Clause 13, page 6, line 27, leave out subsection (3)(d)

None 115

Clause 13, page 7, line 1, leave out from “(1)” to end of line 4 and insert “for “£30 million” substitute “£120 million””

None 116

Clause 13, page 7, line 5, leave out from “(2)” to end of line 13 and insert “for “£30 million” substitute “£120 million””

None 117

Clause 13, page 7, line 10, leave out from “(1)” to end of line 13 and insert “for “250” substitute “500””

None 118

Clause 13, page 7, line 14, leave out from “(2)” to end of line 15 and insert “for “250” substitute “500””

None 119

Clause 13, page 7, line 25, leave out from “15 years” to end of line 27

None 120

Clause 13, page 7, line 28, leave out subsection (7)

None 121

Clause 13, page 8, line 28, leave out sub-paragraph (4)

None 122

Clause 14, page 8, line 36, leave out from “(5A))” to “, and” in line 38 and insert “, £20 million”

None 123

Clause 14, page 8, line 40, leave out from “company” to end of line 1 on page 9, and insert “, £10 million.”

None 124

Clause 14, page 9, line 5, leave out from “section 252A)” to “, and” in line 7, and insert “, £40 million”

None 125

Clause 14, page 9, line 10, leave out from “company” to end of line 11 and insert “, £24 million.”

None 126

Clause 14, page 9, line 15, leave out from “section 252A)” to “, and” in line 17 and insert “, £40 million”

None 127

Clause 14, page 9, line 19, leave out from “company” to end of line 21 and insert “, £24 million.”

None 128

Clause 14, page 9, line 24, leave out sub-paragraph (b)

None 129

Clause 14, page 9, line 38, leave out “that is not a specified Northern Ireland company”

None 130

Clause 14, page 10, line 4, leave out “that is not a specified Northern Ireland company”

None 131

Clause 14, page 10, line 10, leave out leave out subsections (6) and (7) and insert—
“(6) In section 186 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””

None 132

Clause 15, page 10, line 30, leave out from “(6A))” to “, and” in line 32 and insert “, £20 million”

None 133

Clause 15, page 10, line 34, leave out from “company” to end of line 36 and insert “, £10 million.”

None 134

Clause 15, page 11, line 4, leave out from “section 331A)” to “, and” in line 6 and insert “, £40 million”

None 135

Clause 15, page 11, line 8, leave out from “company” to end of line 10 and insert “, £24 million.”

None 136

Clause 15, page 11, line 14, leave out from “section 331A)” to “, and” in line 16 and insert “, £40 million;”

None 137

Clause 15, page 11, line 18, leave out from “company” to end of line 20 and insert “, £24 million.”

None 138

Clause 15, page 11, line 23, leave out subsection (6)(b)

None 139

Clause 15, page 11, line 34, leave out leave out subsections (7) and (8) and insert—
“(6) In section 297 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””

Opposition Amendment 9

Clause 74, page 91, line 25, at end insert—
“(7) The Treasury must make regulations under subsection (1) within 60 days of the passing of this Act.
(8) Before making regulations under subsection (1), the Treasury must consult—
(a) organisations representing infected and affected individuals,
(b) the Infected Blood Compensation Authority, and
(c) bereaved families of victims who have died awaiting compensation.
(9) The regulations made under subsection (1) must make provision for identifying and assisting the estates of deceased victims in claiming inheritance tax relief, including—
(a) outreach to known affected families,
(b) assistance with evidence gathering where medical records have been destroyed,
(c) clear and accessible guidance in plain language, and
(d) a dedicated helpline staffed by trained caseworkers familiar with the infected blood scandal.
(10) The Treasury must, within 6 months of regulations under this section coming into force, and every 6 months thereafter, lay before Parliament a report on—
(a) the number of victims who have died since the previous report while awaiting compensation,
(b) the number of estates that have received inheritance tax relief,
(c) the average time taken to process claims for relief,
(d) any identified barriers preventing families from accessing their entitlement, and
(e) steps taken to expedite outstanding infected blood compensation claims.”

This amendment requires the Chancellor of Exchequer to make regulations under this section within 60 days of Royal Assent. It requires mandatory consultation with those directly affected, and a support service to help bereaved families navigate the system. It also places a six-monthly reporting requirement on the Government.

Opposition Amendment 109

Schedule 12, page 442, line 20, leave out from “and” to end of line 23 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”

This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.

Opposition Amendment 110

Schedule 12, page 442, line 29, leave out from “and” to end of line 32 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),”

This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.

Opposition Amendment 111

Schedule 12, page 443, line 9, leave out from “and” to end of line 12 and insert—
“(b) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”

This amendment would apply 100% agricultural property trust relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.

Opposition Amendment 108

Schedule 12, page 454, line 40, at end insert “(But see subsection (2A).)
(2A) If the Treasury estimates that the value of agricultural land has increased by more than the percentage increase in the consumer prices index during the same period, then it must instead make an order by statutory instrument amending each relief allowance amount relating to agricultural property by the percentage increase in the value of agricultural land.”

Opposition Amendment 102

Schedule 12, page 444, line 16, after “£2.5 million” insert “plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”

This amendment, and Amendments 103 to 107, would allow landlords to access 100% relief from inheritance tax where they have let land or farms to tenant farmers on secure agreements under the Agricultural Holdings Act 1986 or on agreements under the Agricultural Tenancies Act 1995 for 10 years or more.

Opposition Amendment 103

Schedule 12, page 449, line 36, after “£2.5 million” insert “plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”

See Amendment 102.

Opposition Amendment 104

Schedule 12, page 450, line 25, after “£2.5 million” insert “plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”

See Amendment 102.

Opposition Amendment 105

Schedule 12, page 451, line 22, after “£2.5 million” insert “plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”

See Amendment 102.

Opposition Amendment 106

Schedule 12, page 453, line 15, after “£2.5 million” insert “plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”

See Amendment 102.

Opposition Amendment 107

Schedule 12, page 453, line 17, after “£2.5 million” insert “plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”

See Amendment 102.

Opposition Amendment 101

Page 103, line 29, leave out Clause 86

Opposition Amendment 95

Schedule 12, page 450, line 27, leave out “30 October 2024” and insert “6 April 2026”

This amendment, with Amendments 96 to 100, would remove the transition period in respect of the changes to agricultural property and business property relief so that the changes take effect for transfers made from 6 April 2026.

Opposition Amendment 96

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

See explanatory statement for Amendment 95.

Opposition Amendment 97

Schedule 12, page 453, line 23, leave out “30 October 2024” and insert “6 April 2026”

See explanatory statement for Amendment 95.

Opposition Amendment 98

Schedule 12, page 460, line 9, leave out sub-paragraphs (2) to (4)

See explanatory statement for Amendment 95.

Opposition Amendment 99

Schedule 12, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert “comes into force on 6 April 2026”

See explanatory statement for Amendment 95.

Opposition Amendment 100

Schedule 12, page 460, line 34, leave out “30 October 2024” and insert “6 April 2026”

See explanatory statement for Amendment 95.

None NC8

To move the following Clause—
“Impact of section 84 (General betting duty charge on remote bets)
The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of section 84 of this Act on the size of the illegal betting market.”

This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of section 84 on the illegal betting market.

None NC9

To move the following Clause—
“Impact of changes to gambling duties on the economy of Gibraltar
The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of sections 83 and 84 of this Act on the economy of Gibraltar.”

This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of sections 83 and 84 on the economy of Gibraltar.

Opposition Amendment NC10

To move the following Clause—
“Review of operation of the carbon border adjustment mechanism
(1) The Treasury must, each calendar year for five years following the passing of this Act, undertake a review of the operation of—
(a) Part 5, and
(b) Schedules 16 to 19.
(2) A review undertaken under subsection (1) must be conducted in accordance with sections 28 to 32 of the Small Business, Enterprise and Employment Act 2015.
(3) A review undertaken under subsection (1) must be completed as soon as reasonably practicable after the calendar year to which it relates.
(4) The Treasury must lay before Parliament a copy of each review carried out under this section as soon as reasonably practicable following the completion of the review.”

This new clause would place a duty on the Chancellor to conduct a post-implementation review of the operation of the carbon border adjustment mechanism one year after the implementation of the UK CBAM and every subsequent year.

Opposition Amendment 1

Page 2, line 7, leave out Clause 4

This amendment removes the increase in dividend rates from the Bill.

Opposition Amendment 2

Page 2, line 16, leave out Clause 5

This amendment removes the new savings rates of income tax from the Bill.

Opposition Amendment 3

Page 2, line 21, leave out Clause 6

This amendment removes the new rates of income tax on property income from the Bill.

Opposition Amendment 4

Page 4, line 31, leave out Clause 7

This amendment removes the property rates of income tax for 2027-28 from the Bill.

Opposition Amendment 5

Page 5, line 20, leave out Clause 10

This amendment removes the freeze in income tax thresholds from the Bill.

Opposition Amendment 6

Page 78, line 4, leave out Clause 62

This amendment removes the changes to the thresholds for Agricultural Property Relief and Business Property Relief from the Bill.

Opposition Amendment 7

Page 78, line 11, leave out Clause 63

This amendment removes the imposition of income tax on pension interest.

None 10

Page 94, line 4, leave out Clause 77

This amendment would maintain the existing zero-rating for the purposes of VAT on the full value of the lease of a vehicle to a disabled person supplied through the Motability Scheme.

None 11

Page 96, line 6, leave out Clause 78

This amendment would maintain insurance premium tax relief for all vehicles let to a disabled person and supplied through the Motability Scheme.

Opposition Amendment 8

Page 442, line 2, leave out Schedule 12

This amendment would remove the changes to Agricultural Property Relief and Business Property Relief from the Bill.

Opposition Amendment 89

Schedule 12, page 444, line 16, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 90

Schedule 12, page 449, line 36, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 91

Schedule 12, page 450, line 25, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 67

Schedule 12, page 450, line 27, leave out “30 October 2024” and insert “1 March 2027”

This amendment, along with Amendments 68 to 87 would remove the transition period in respect of the changes to agricultural property and business property relief and delay the implementation date so that the changes would take effect for transfers made after 1 March 2027.

Opposition Amendment 68

Schedule 12, page 451, line 6, leave out “30 October 2024” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 92

Schedule 12, page 451, line 22, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 93

Schedule 12, page 453, line 15, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 94

Schedule 12, page 453, line 17, after “£2.5 million” insert “excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”

Opposition Amendment 69

Schedule 12, page 453, line 23, leave out “30 October 2024” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 88

Schedule 12, page 458, line 31, at end insert—
(1A)In Section 227, leave out subsection (3)(a) and insert—
(a)if the chargeable transfer was made on death and to the extent that it qualified for relief under Chapters I or II of part V of this Act, eighteen months after the end of the month in which the death occurred, or
(b)if the chargeable transfer was made on death and to the extent that it did not qualify for relief under Chapters I or II of part V of this Act, six months after the end of the month in which the death occurred, and””

This amendment would defer the period for the payment of inheritance tax on assets qualifying for payment by instalments by 12 additional months.

Opposition Amendment 70

Schedule 12, page 460, line 8, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 71

Schedule 12, page 460, line 9, leave out sub-paragraphs (2) and (3)

See explanatory statement for Amendment 67.

Opposition Amendment 72

Schedule 12, page 460, line 23, leave out “sub-paragraph (3) will not apply” and insert “the transfer will prove to be an exempt transfer”

See explanatory statement for Amendment 67.

Opposition Amendment 73

Schedule 12, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert “comes into force on 1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 74

Schedule 12, page 460, line 34, leave out “30 October 2024” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 75

Schedule 12, page 460, line 37, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 76

Schedule 12, page 460, line 39, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 77

Schedule 12, page 460, line 41, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 78

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

See explanatory statement for Amendment 67.

Opposition Amendment 79

Schedule 12, page 461, line 9, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 80

Schedule 12, page 461, line 14, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 81

Schedule 12, page 461, line 22, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 82

Schedule 12, page 461, line 26, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 83

Schedule 12, page 461, line 37, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 84

Schedule 12, page 461, line 42, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 85

Schedule 12, page 463, line 19, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 86

Schedule 12, page 463, line 26, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Opposition Amendment 87

Schedule 12, page 463, line 32, leave out “6 April 2026” and insert “1 March 2027”

See explanatory statement for Amendment 67.

Government Amendment NC5

To move the following Clause—
“Offshore income gains
(1) In the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—
(a) in regulation 20 (application to gains of non-resident settlements), omit paragraphs (2) to (5);
(b) in regulation 21 (application of transfer of assets abroad provisions), omit paragraphs (4) to (6).
(2) In consequence of the amendments made by subsection (1)—
(a) in section 734 of ITA 2007 (reduction in amount charged: previous capital gains tax charge), in subsection (5), omit “20 and”;
(b) in Schedule 7 to FA 2008 (remittance basis), omit paragraphs 100 to 102;
(c) in the Offshore Funds (Tax) Regulations 2009—
(i) in regulation 18 (charge to tax on disposal of asset: further provisions), in paragraph (5), omit sub-paragraph (c);
(ii) in regulation 19 (income treated as arising under regulation 17: remittance basis), omit paragraph (5);
(iii) omit regulation 130 (amendments of FA 2008);
(iv) in Part 2 of Schedule 3 (index of defined expressions), omit the entry for “OIG amount”;
(d) in Schedule 10 to FA 2025 (temporary repatriation facility)—
(i) in paragraph 3(7), for “paragraphs 4 and 5” substitute “paragraph 5”;
(ii) in paragraph 3(9), for “paragraphs 4 and 5” substitute “paragraph 5”;
(iii) omit paragraph 4;
(iv) in paragraph 5(7), for “paragraphs 3 and 4” substitute “paragraph 3”;
(v) in paragraph 10, omit sub-paragraphs (7) and (8).
(3) Section (Offshore income gains: savings) makes provision preserving in certain cases the effect of the law as it applied before the amendments made by this section.
(4) This section—
(a) is to be treated as having come into force on 6 April 2025;
(b) has effect for the tax year 2025-26 and subsequent tax years.”

This new clause would make amendments in relation to certain offshore income gains so that certain provisions of the Taxation of Chargeable Gains Act 1992 that previously applied to them no longer apply.

Government Amendment NC6

To move the following Clause—
“Offshore income gains: savings
(1) This section applies in relation to an offshore income gain arising to the trustees of a settlement in a case where Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to that gain for the tax year 2025-26 or any subsequent tax year because of the amendments made by section (Offshore income gains).
(2) If the offshore income gain arose in a tax year before the tax year 2025-26 and, by reason of that offshore income gain or a part of it, an offshore income gain was treated as arising in a tax year before the tax year 2025-26 to an individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—
(a) Chapter 2 of Part 13 of ITA 2007 is to be treated as not applying in relation to the offshore income gain arising to the trustees or that part of that gain, and
(b) references in section 734 of ITA 2007 to chargeable gains treated as accruing to an individual are to be treated as including the offshore income gain treated as arising to the individual.
(3) An individual is not chargeable to income tax under Chapter 2 of Part 13 of ITA 2007 on income treated as arising to the individual under section 732 of ITA 2007 by reason of the offshore income gain to the extent that the income, without the amendments made by section (Offshore income gains)(1) and (2)(b)—
(a) would have been treated as arising to that individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and
(b) would have been non-chargeable income (see subsections (4), (5) and (6)).
(4) The income would have been non-chargeable income if, without the amendments made by section (Offshore income gains)(1) and (2)(b)—
(a) the income would have been treated as arising by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual before 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising before 6 April 2008, and
(b) paragraph 100 of Schedule 7 to FA 2008 would have applied to the income.
(5) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income—
(a) which would have been treated as arising to the individual by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, and
(b) to which paragraph 101 of Schedule 7 to FA 2008 would have applied,
and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (9) to (18) of paragraph 126 of that Schedule as they would have been modified by sub-paragraph (3) of paragraph 101 of that Schedule.
(6) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income—
(a) which would have been treated as arising to the individual by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008,
(b) to which paragraph 102 of Schedule 7 to FA 2008 would have applied, and
(c) to which paragraph 101 of that Schedule would not have applied,
and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (4) to (7) of paragraph 127 of that Schedule as they would have been modified by sub-paragraph (4) of paragraph 102 of that Schedule.
(7) Subsection (3) does not prevent Chapter 2 of Part 13 of ITA 2007 from having effect as though the income not chargeable to tax under that subsection had been charged to tax under section 731 of that Act.
(8) Accordingly—
(a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of that 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 that income will be deducted at paragraph (b) of Step 5.
(9) In section 733 of ITA 2007, after subsection (2D) insert—
“(2E) See subsections (7) and (8) of section (Offshore income gains: savings) of FA 2026 (offshore income gains: savings relating to amendments made by section (Offshore income gains) of that Act) for special provision about income that is treated as arising under section 732 but that is not chargeable to income tax under subsection (3) of that section.”
(10) This section—
(a) is to be treated as having come into force on 6 April 2025;
(b) has effect for the tax year 2025-26 and subsequent tax years.”

This new clause would make saving provision relating to the amendments made by NC5.

Government Amendment NC7

To move the following Clause—
“Pensions: abolition of the lifetime allowance charge
(1) Paragraph 134 of Schedule 9 to FA 2024 (power to make further provision in connection with the abolition of the lifetime allowance charge) is amended as follows.
(2) In sub-paragraph (2)—
(a) for paragraph (b) substitute—
“(b) have effect for the tax years 2024-25 and 2025-26 (as well as subsequent tax years);”;
(b) in paragraph (d), at the end insert
“(including any provision that could be made under paragraph 133)”
.
(3) In sub-paragraph (3) omit “that increase any person’s liability to tax”.
(4) In sub-paragraph (4), for
“5 April”
substitute
“30 June”
.”

The lifetime allowance charge was abolished for the tax year 2024-25 and subsequent tax years by the Finance (No. 2) Act 2023. This amendment updates the existing power in paragraph 134 of Schedule 9 to FA 2024 to make provision in relation to that abolition in four ways: it ensures that the power may be used to make provision taking effect from the time of the abolition; it clarifies that the power may be used to make any transitional etc provision that could also be made under paragraph 133; it ensures that all future exercises of the power are subject to the affirmative procedure in the House of Commons; and it postpones the date on which it expires.

Government Amendment 12

Clause 23, page 22, line 34, after “are” insert “, for the purposes of Chapter 4 or 5 of Part 2 of ITEPA 2003”

This amendment is consequential on Amendment 13.

Government Amendment 13

Clause 23, page 22, line 36, leave out “paid” and insert “treated as received”

This amendment ensures that the amendments made by clause 23 will only have effect in relation to general earnings treated as received on or after 6 April 2026.

Government Amendment 14

Clause 24, page 26, line 10, leave out from “of” to end of line 13 and insert “services having been provided to the individual in connection with finding the client with a view to the individual personally providing services to the client—
(i) by the purported umbrella company, or
(ii) where the provision of services to the client is as a result of a series of contracts, by one or more of the parties to those contracts.”

This amendment will prevent more complicated agency arrangements being deemed to include a purported umbrella company.

Government Amendment 15

Clause 63, page 79, line 25, at end insert—
“(4A) For the purposes of section 6 (excluded property), notional pension property in relation to a pension scheme is regarded as situated in the country or territory in which the scheme is established.”

This amendment ensures that the rules about excluded property apply to notional pension property. This will, in particular, exclude foreign pensions from the new charge to IHT where the deceased was, on death, not a long-term UK resident.

Government Amendment 16

Clause 63, page 79, line 42, leave out “is an active member of the scheme, and”

This amendment broadens the circumstances in which a pension used to provide death-in-service benefits is excluded from the new IHT charge, by removing the requirement that the deceased member must, at the time of death, have been accruing benefits under the scheme.

Government Amendment 17

Clause 63, page 80, leave out line 19

This amendment is consequential on Amendment 16.

Government Amendment 18

Clause 64, page 81, line 8, after “benefit” insert “, or an exempt benefit,”

This amendment ensures that inheritance tax payable on a deceased’s pension property cannot be recovered from the scheme administrator if it is required for benefits payable to spouses, civil partners, charities or other persons where transfers to them would be exempt from inheritance tax.

Government Amendment 19

Clause 64, page 81, line 10, leave out from “a benefit” to end of line 11 and insert “on the deceased’s death, other than an excluded benefit or an exempt benefit.”

This amendment ensures that the inheritance tax payable on a deceased’s pension property cannot be recovered from spouses, civil partners, charities or other persons where transfers to them would be exempt from inheritance tax.

Government Amendment 20

Clause 64, page 81, line 37, at end insert—
“(7) In this Act “exempt benefit”, in relation to a pension scheme and a deceased member of the scheme, means a benefit paid under the scheme if and so far as the payment renders the transfer of value made on the deceased’s death an exempt transfer.
(8) For provision under which a payment of a benefit renders the transfer of value on death an exempt transfer to the extent of the payment, see—
section 18 (transfers between spouses or civil partners);
section 23 (gifts to charities or registered clubs);
section 24 (gifts to political parties);
section 24A (gifts to housing associations);
section 25 (gifts for national purposes etc);
section 27 (maintenance funds for historic buildings etc).”

This amendment is consequential on Amendments 18 and 19.

Government Amendment 21

Clause 65, page 82, line 28, leave out “under this section (a “withholding notice”)”

This amendment is consequential on Amendment 22.

Government Amendment 22

Clause 65, page 82, line 31, at end insert—
“(1A) A prospective personal representative of a deceased person may give a notice to the scheme administrator of a registered pension scheme if they have reason to believe that, on becoming a personal representative, they would be, or might be, liable for tax attributable to notional pension property of the deceased in relation to the scheme.
(1B) In this section “withholding notice” means a notice under subsection (1) or (1A).”

This amendment ensures that a withholding notice can be given by a person who expects to be, but has not yet become, a personal representative of the deceased. This might occur, for example, where the deceased has died without a will but an application for a grant of letters of administration has not yet been made.

Government Amendment 23

Clause 65, page 82, line 33, leave out from “scheme” to end of line 35 and insert “to a person (“P”) if—
(a) the total amount of benefits previously paid under the scheme to P on the deceased’s death exceeds 50% of P’s benefit entitlement, or
(b) the payment of the benefit would result in the total amount of benefits paid under the scheme to P on the deceased’s death exceeding 50% of P’s benefit entitlement.”

This amendment clarifies that a withholding notice freezes payments to a beneficiary where the benefits paid to them already exceed 50% of their entitlement.

Government Amendment 24

Clause 65, page 83, line 1, leave out from “benefit” to end of line 3 and insert “or an exempt benefit”

This amendment ensures that a withholding notice does not prevent a scheme from paying benefits to spouses, civil partners, charities or other persons where transfers to them would be exempt from inheritance tax.

Government Amendment 25

Clause 65, page 83, line 6, leave out from “by” to end and insert “—
(i) the personal representatives, or
(ii) if the person who gave the notice was a prospective personal representative, that person;”

This amendment relates to Amendment 22 and ensures that, where a withholding notice is given by a prospective personal representative, it can be withdrawn by that person.

Government Amendment 26

Clause 65, page 83, line 21, leave out “In subsection (4)(b)” and insert “In this section—
“prospective personal representative” , in relation to a deceased person, means a person who has reason to believe that they will become a personal representative of that person;”

This amendment is consequential on Amendment 22.

Government Amendment 27

Clause 65, page 84, line 25, at end insert—
“(3A) The references in subsection (3)(e) to benefits do not include excluded benefits or exempt benefits.”

This amendment ensures that the personal representatives can only require the scheme to pay inheritance tax so far as the unpaid death benefits under the scheme are not exempt from inheritance tax.

Government Amendment 28

Clause 65, page 84, line 38, leave out “the benefits payable to that beneficiary” and insert “that beneficiary’s entitlement to benefits”

This amendment makes it clear that the consequential adjustments that can be made by a scheme administrator under section 226B(5)(a) of the Inheritance Tax Act 1984 include any adjustments to the beneficiary’s entitlement to benefits (and not only adjustments to benefits that have become payable).

Government Amendment 29

Clause 65, page 84, line 41, leave out “benefit payable” and insert “person’s entitlement to benefits”

This amendment ensures that the consequential adjustments that can be made by a scheme administrator under section 226B(5)(b) of the Inheritance Tax Act 1984 include any adjustments to a person’s entitlement to benefits under the scheme (and not only adjustments to benefits that have become payable).

Government Amendment 30

Clause 65, page 85, line 10, leave out “benefit payable” and insert “person’s entitlement to benefits”

This amendment is consequential on Amendments 28 and 29.

Government Amendment 31

Clause 66, page 86, line 15, at end insert—
“(4A) In section 24 (gifts to political parties), after subsection (4) insert—
“(5) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property—
(a) the value transferred is treated for the purposes of this section as also attributable to any property that on the death of the member is given under the scheme to a political party qualifying for exemption under this section, and
(b) section 23(2) does not (despite subsection (3)) apply in relation to subsection (1).”
(4B) In section 24A (gifts to housing associations), after subsection (3) insert—
“(4) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property—
(a) the value transferred is treated for the purposes of this section as also attributable to any land in the United Kingdom that on the death of the member is given under the scheme to a body falling within subsection (2), and
(b) section 23(2) does not (despite subsection (3)) apply in relation to subsection (1).”
(4C) In section 25 (gifts for national purposes etc), after subsection (3) insert—
“(4) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property—
(a) the value transferred is treated for the purposes of this section as also attributable to any property that on the death of the member is given under the scheme—
(i) to a body within Schedule 3, or
(ii) in the circumstances described in paragraph 1 of Schedule 14 to the Finance Act 2012 (gifts to nation), and
(b) section 23(2) does not (despite subsection (2)) apply in relation to subsection (1).”
(4D) In section 27 (maintenance funds for historic buildings etc), after subsection (2) insert—
“(3) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property—
(a) the value transferred is treated for the purposes of this section as also attributable to any property—
(i) that on the death of the member is given under the scheme to a person and becomes comprised in a settlement, and
(ii) in respect of which the condition in subsection (1)(a) or (b) is met, and
(b) section 23(2) does not (despite subsection (2)) apply in relation to subsection (1).””

This amendment ensures that, death benefits paid to a political party, a housing association, for national purposes, or for the maintenance of historic buildings, are exempt from inheritance tax (subject to the same conditions as would apply to a payment from the estate).

Government Amendment 32

Clause 66, page 86, line 26, at end insert—
“(6A) After section 218A insert—
“218B Pensions: information powers
(1) The powers conferred on the Board by section 251 of the Finance Act 2004 (powers relating to the provision and preservation of information in connection with pensions) are exercisable for the purposes of this Act.
(2) Subsection (1) is without prejudice to the generality of that section of that Act.””

This amendment clarifies that the powers enabling HMRC to require information to be provided or preserved in relation to pension schemes are available for the purposes of the new charge to inheritance tax.

Government Amendment 33

Clause 66, page 86, line 32, at end insert—
“““exempt benefit” , in relation to a pension scheme and a deceased member of the scheme, has the meaning given by section 210(7);””

This amendment is consequential on Amendments 18 and 19.

Government Amendment 34

Clause 67, page 87, line 24, at end insert “, or
(iii) the scheme administrator pays (under section 226B of IHTA 1984) an amount of inheritance tax that is so attributable, and the payment meets the condition in subsection (1A).”

This amendment (which needs to be read with Amendments 35, 36 and 37) is designed to ensure that the way the scheme administrator chooses to exercise the discretion under section 226B(5) of the Inheritance Tax Act 1984 where a lump sum death benefit is paid to a beneficiary does not affect the amount of the beneficiary’s taxable pension income that reflects the payment of that lump sum death benefit.

Government Amendment 35

Clause 67, page 87, line 24, at end insert—
“(1A) A payment of an amount of inheritance tax meets the condition in this subsection if (and so far as)—
(a) in consequence of the payment, the scheme administrator makes an adjustment (under section 226B(5) of IHTA 1984) as a result of which the beneficiary’s entitlement to a benefit other than that mentioned in subsection (1) (“the other benefit”) is reduced, and
(b) disregarding that reduction, the other benefit would not give rise to taxable pension income for any tax year.”

This amendment needs to be read with Amendment 34 (see the explanatory statement for that amendment).

Government Amendment 36

Clause 67, page 87, leave out lines 25 to 35 and insert—
“(2) A deduction is allowed from amount TPI equal to the lesser of—
(a) the amount of inheritance tax paid as mentioned in subsection (1)(d)(i) or (ii), less so much (if any) of that inheritance tax as has been deducted under this subsection in an earlier tax year, and
(b) so much of amount TPI as reflects the payment to the beneficiary of the benefit mentioned in subsection (1).
(3) Where the deceased was under 75 on death, and the benefit mentioned in subsection (1) is a relevant lump sum death benefit, a deduction is allowed from amount TPI equal to the lesser of—
(a) the amount of inheritance tax paid as mentioned in subsection (1)(d)(iii) so far as it meets the condition in subsection (1A), less so much (if any) of that inheritance tax as has been deducted under this subsection in an earlier tax year, and
(b) so much of amount TPI as reflects the payment to the beneficiary of the benefit mentioned in subsection (1).
(4) Where a deduction is allowed under both of subsections (2) and (3), the deduction under subsection (3) is to be made first.”

This amendment clarifies the operation of subsections (2) and (3) of the inserted section 567B of ITEPA 2003 in consequence of Amendment 34 and is otherwise in consequence of Amendment 37 (see the explanatory statement for that amendment).

Government Amendment 37

Clause 67, page 88, line 2, at end insert—
“(6) In this section—
“IHTA 1984” means the Inheritance Tax Act 1984;
“inheritance tax” includes interest on inheritance tax;
“excluded benefit” has the same meaning as in IHTA 1984;
“notional pension property” has the same meaning as in IHTA 1984;
“relevant lump sum death benefit” has the same meaning as in section 637S.”

The new definition of inheritance tax ensures that the income tax deduction available for inheritance tax paid given by the new section 567B includes any accrued interest paid with the inheritance tax. The other definitions inserted by this amendment are defining terms used in Amendments 34 and 36 or are relocated from subsection (4), which is removed by Amendment 36.

Government Amendment 38

Clause 67, page 88, leave out lines 6 to 9 and insert—
“(a) an amount of inheritance tax that is attributable to the value of notional pension property of a deceased member of a registered pension scheme is paid,”

This amendment (together with Amendments 39, 41, 42 and 43) ensures that, in all cases in which inheritance tax on a deceased member’s pension is overpaid, and the resulting repayment is received (directly or indirectly) by a beneficiary, and income tax has not previously been paid on income used to make the overpayment, the repayment is treated for income tax purposes as pension income in the hands of the beneficiary.

Government Amendment 39

Clause 67, page 88, line 10, leave out “by the scheme administrator”

This amendment needs to be read with Amendment 38 (see the explanatory statement for that amendment).

Government Amendment 40

Clause 67, page 88, line 12, at end insert “, other than a non-qualifying person,”

This amendment ensures that the new section 579B of ITEPA 2003 (under which a refund of inheritance tax is in certain circumstances treated as pension income) does not apply where the refund is made to a person in their capacity as a non-qualifying person. In such a case the refund may instead be subject to a charge under the new section 206B of FA 2004 (inserted by Amendment 47).

Government Amendment 41

Clause 67, page 88, line 17, leave out “and” and insert—
“(ba) in a case in which the payment of inheritance tax mentioned in paragraph (a) was made by the beneficiary or by the deceased’s personal representatives, a deduction is allowed under section 567B in respect of the payment, and”

This amendment needs to be read with Amendment 38 (see the explanatory statement for that amendment).

Government Amendment 42

Clause 67, page 88, leave out line 19 and insert “The relevant amount”

This amendment needs to be read with Amendment 38 (see the explanatory statement for that amendment).

Government Amendment 43

Clause 67, page 88, line 22, at end insert—
“(3) In subsection (2) “the relevant amount” means—
(a) in a case in which the payment of inheritance tax mentioned in subsection (1)(a) is made by the scheme administrator, the amount of the payment made to the beneficiary mentioned in subsection (1)(b)(i) or (ii);
(b) in a case in which the payment of inheritance tax mentioned in subsection (1)(a) is made by a beneficiary or by the deceased’s personal representatives, the lesser of—
(i) the amount of the payment made to the beneficiary mentioned in subsection (1)(b)(i) or (ii), and
(ii) the deduction allowed under section 567B in respect of the payment of inheritance tax mentioned in subsection (1)(a).”

This amendment needs to be read with Amendment 38 (see the explanatory statement for that amendment).

Government Amendment 44

Clause 67, page 88, line 22, at end insert—
“(4) In this section—
“inheritance tax” includes interest on inheritance tax;
“non-qualifying person” has the same meaning as in section 206 of FA 2004 (special lump sum death benefit charge).”

The new definition of “inheritance tax” ensures that, where a beneficiary of a pension death benefit receives (directly or indirectly) a repayment of overpaid inheritance tax from HMRC, any accrued interest that was included in the overpayment and is repaid is treated as pension income for income tax purposes (in the same way as the repaid tax). The new definition of “non-qualifying person” is consequential on Amendment 40.

Government Amendment 45

Clause 67, page 88, line 22, at end insert—
“(4A) In section 637T (availability of individual’s lump sum and death benefit allowance where multiple lump sum death benefits paid), after subsection (4) insert—
“(5) Where any inheritance tax is attributable to the value of the individual’s notional pension property, references in subsection (4) to the amount of a lump sum death benefit are to its IHT-adjusted amount.
(6) The “IHT-adjusted amount” of a lump sum death benefit paid to a person under a registered pension scheme is (subject to subsection (7)) the amount determined as follows —
Step 1 Take the amount of the lump sum death benefit paid to the person.
Step 2 Add the amount (if any) by which the person’s entitlement to the lump sum death benefit was reduced in consequence of an adjustment under section 226B(5) of IHTA 1984.
Step 3 Deduct the amount (if any) of inheritance tax—
(a) that is attributable to the value of the individual’s notional pension property in relation to the scheme, and
(b) for which the person—
(i) is, or at any time was, liable under section 200(1)(c) of IHTA 1984, or
(ii) would at any time have been liable under that provision if the tax had not previously been paid by another person.
If the result is a negative amount, the IHT-adjusted amount of the lump sum death benefit is nil.
(7) Where more than one lump sum death benefit is paid to the person under the scheme, the amount to be deducted under Step 3 is the following proportion of the amount of inheritance tax identified in that Step—
$C/D$
where—
“C” is the amount resulting from Step 2;
“D” is the aggregate of the amounts resulting from Step 2 in respect of each lump sum death benefit paid to the person under the scheme.
(8) In this section—
(a) “IHTA 1984” means the Inheritance Tax Act 1984;
(b) “notional pension property” has the same meaning as in IHTA 1984.””

This amendment is designed to ensure that, in a case in which a deceased member’s pension is subject to inheritance tax, and multiple lump sum death benefits are paid, the person by whom the inheritance tax is paid does not affect the way in which the available lump sum and death benefit allowance is apportioned between the different lump sum death benefits.

Government Amendment 46

Clause 67, page 88, line 26, leave out “and” and insert “to”

This amendment is consequential on Amendment 47.

Government Amendment 47

Clause 67, page 88, line 31, at end insert—
“(7A) After section 206 insert—
“206A Partial repayment of section 206 charge where IHT paid by recipient of benefit
(1) This section applies where—
(a) a registered pension scheme pays a lump sum death benefit in respect of a deceased member to a non-qualifying person,
(b) a liability to the lump sum death benefits charge arises in respect of the lump sum death benefit,
(c) at any time (whether before or after the payment of the lump sum death benefit)—
(i) the non-qualifying person pays an amount of inheritance tax that is attributable to the value of the deceased’s notional pension property, or
(ii) the deceased’s personal representatives pay an amount of inheritance tax that is so attributable and pass on the burden of that payment to the non-qualifying person, and
(d) the non-qualifying person makes an application under this section for a reduction in the lump sum death benefits charge.
(2) Section 206 applies in relation to the lump sum death benefit as if the amount of the benefit that was paid to the non-qualifying person were the amount in fact paid, reduced by the amount of inheritance tax paid as mentioned in subsection (1)(c).
(3) If and to the extent that the amount of the lump sum death benefits charge paid in respect of the lump sum death benefit exceeds the amount of the liability (as recalculated as a result of subsection (2)), the excess must be repaid to the non-qualifying person (and may not be repaid to the scheme administrator).
(4) An application under this section is of no effect unless it complies with such requirements as to timing, form and content as may be prescribed by the Commissioners.
(5) For the purposes of subsection (1)(c) the deceased’s personal representatives “pass on the burden” of a payment of inheritance tax to the non-qualifying person if—
(a) the personal representatives pay a sum to the non-qualifying person out of the deceased’s estate that has been reduced by the amount of inheritance tax, or
(b) the non-qualifying person reimburses the personal representatives that amount.
(6) In this section—
“the Commissioners” means the Commissioners for His Majesty’s Revenue and Customs;
“inheritance tax” includes interest on inheritance tax;
“non-qualifying person” has the same meaning as in section 206.
206B Supplementary charge on refund of overpaid IHT
(1) This section applies where—
(a) a registered pension scheme pays a lump sum death benefit in respect of a deceased member to a non-qualifying person,
(b) a liability to the lump sum death benefits charge arises in respect of the lump sum death benefit,
(c) an amount of inheritance tax that is attributable to the value of notional pension property of the deceased member is paid,
(d) some or all of the inheritance tax paid as mentioned in paragraph (c) is subsequently—
(i) repaid under section 241(1) of that Act to the non-qualifying person, or
(ii) repaid under that section to the deceased’s personal representatives and passed on by the personal representatives to the non-qualifying person, and
(e) in a case in which the payment mentioned in paragraph (c) was made by the non-qualifying person or by the deceased’s personal representatives, the non-qualifying person has made an application under section 206A in relation to the lump sum death benefit.
(2) A charge to income tax arises in respect of the relevant amount.
(3) In subsection (2) “the relevant amount” means—
(a) in a case in which the payment of inheritance tax mentioned in subsection (1)(c) is made by the scheme administrator, the amount of the payment made to the non-qualifying person mentioned in subsection (1)(d)(i) or (ii);
(b) in a case in which the payment of inheritance tax mentioned in subsection (1)(c) is made by the non-qualifying person, or by the deceased’s personal representatives, the lesser of—
(i) the amount of the payment made to the non-qualifying person mentioned in subsection (1)(d)(i) or (ii), and
(ii) the repayment made under section 206A to the non-qualifying person in relation to the lump sum death benefit.
(4) The person liable to the charge is the non-qualifying person.
(5) The rate of the charge is the same as the rate of the special lump sum death benefits charge (see section 206(4)).
(6) In this section—
“inheritance tax” includes interest on inheritance tax;
“non-qualifying person” has the same meaning as in section 206.””

This amendment relates to the interaction of the new charge to inheritance tax (“IHT”) on pensions created by the Bill, and the special lump sum death benefits charge (“the SLSDBC”) under section 206 of FA 2004. The new section 206A of FA 2004 is designed to ensure that the SLSDBC is not paid on that part of the lump sum death benefit that is used to pay IHT. The new section 206B of FA 2004 is designed to ensure that the SLSDBC is not reduced where an error is made and later corrected in calculating the IHT liability.

Government Amendment 48

Schedule 3, page 268, line 7, leave out sub-paragraphs (1) to (4)

This amendment is consequential on NC5.

Government Amendment 49

Schedule 3, page 270, line 22, after “87A” insert “of TCGA 1992”

This amendment would clarify the reference to section 87A of the Taxation of Chargeable Gains Act 1992.

Government Amendment 50

Schedule 3, page 270, line 29, leave out from “capital” to “.” in line 31

This amendment is consequential on NC5.

Government Amendment 51

Schedule 3, page 270, line 34, leave out sub-paragraphs (6) to (8)

This amendment is consequential on NC5.

Government Amendment 52

Schedule 3, page 273, line 6, leave out from “payments)” to end of line 8

This amendment is consequential on NC5.

Government Amendment 53

Schedule 7, page 352, line 4, after “company” insert “in the territory”

This amendment makes it explicit that a dependent agent of a company needs to act in a particular territory for there to be a permanent establishment of the company there.

Government Amendment 56

Schedule 11, page 400, line 28, after “individual” insert “or a person who is connected with the individual”

This amendment ensures that sums which arise to an individual that are co-investment repayments or returns are not treated as carried interest if the investment is made by a person who is connected with the individual.

Government Amendment 57

Schedule 11, page 400, line 32, at end insert—
(3)Section 993 of ITA 2007 (meaning of “connected”) applies for the purposes of this paragraph but as if—
(a)subsection (4) of that section were omitted, and
(b)partners in a partnership in which the individual is also a partner were not “associates” of the individual for the purposes of sections 450 and 451 of CTA 2010 (“control”).”

This amendment is consequential on Amendment 56.

Government Amendment 58

Schedule 11, page 401, leave out lines 37 to 3 on page 402

This amendment removes provision disapplying the rule that treats a sum as arising to a person (A) where it arises to a connected person (B), if it arises under arrangements under which B performs investment management services. That provision is unnecessary because such a sum would not arise under arrangements under which A performs investment management services, meaning that A would not be chargeable to income tax under section 23I in respect of the sum. It also removes provision in consequence of Amendment 56.

Government Amendment 59

Schedule 11, page 440, line 25, at end insert—
“(za) in subsection (1)(a) after “individual” insert “or a person who is connected with the individual”;
(zb) in subsection (1)(b) after “individual” insert “or a person who is connected with the individual”;”

This amendment is consequential on Amendment 56.

Government Amendment 60

Schedule 11, page 440, line 35, at end insert—
“(e) after subsection (4) insert—
“(5) Section 993 (meaning of “connected”) applies for the purposes of this section, but as if—
(a) subsection (4) of that section were omitted, and
(b) partners in a partnership in which the individual is also a partner were not “associates” of the individual for the purposes of sections 450 and 451 of CTA 2010 (“control”).””

This amendment is consequential on Amendment 59.

Government Amendment 61

Schedule 11, page 441, line 1, leave out paragraph (b)

This amendment is consequential on Amendment 58 and Amendment 59.

Government Amendment 54

Schedule 12, page 457, line 29, after “securities” insert “of a company”

This amendment is consequential on Amendment 55.

Government Amendment 55

Schedule 12, page 457, line 30, at end insert—
“(aa) in paragraph (ab) (as inserted by this sub-paragraph)—
(i) the words from “that” to the end become sub-paragraph (i), and
(ii) after that sub-paragraph insert
“, and
(ii) which (either by themselves or together with any unquoted shares in, or other unquoted securities of, the company that are owned by the transferor) gave the transferor control of the company immediately before the transfer;””

This amendment secures that the transfer of securities in a company traded on a recognised stock exchange will only benefit from 50% relief where the transferor had control of the company before the transfer.

Government Amendment 62

Schedule 12, page 457, line 32, leave out “or securities”

This amendment is consequential on Amendment 63.

Government Amendment 63

Schedule 12, page 457, line 34, at end insert—
“(ad) any unquoted securities of a company—
(i) that are traded on an exchange outside the United Kingdom that is not a recognised stock exchange, and
(ii) which (either by themselves or together with any unquoted shares in, or other unquoted securities of, the company that are owned by the transferor) gave the transferor control of the company immediately before the transfer;”

This amendment secures that the transfer of securities in a company traded on an overseas exchange that is not a recognised stock exchange will only benefit from 50% relief where the transferor had control of the company before the transfer.

Government Amendment 64

Schedule 12, page 457, line 36, at end insert—
(1A)In section 107, in subsection (4) for “105(1)(bb)” substitute “105(1)(aa) or (bb)”.
(1B)In that subsection (as amended by sub-paragraph (1A)) after “105(1)(aa)”, insert “, (ac)”.”

This amendment inserts some missing consequential changes.

Government Amendment 65

Schedule 12, page 460, line 15, leave out “amendment” and insert “amendments”

This amendment is consequential on Amendments 55 and 64.

Government Amendment 66

Schedule 12, page 460, line 15, leave out “paragraph 12(1)(b) (shares traded on overseas exchanges)” and insert “sub-paragraphs (1)(aa) and (b) and (1B) of paragraph 12”

This amendment is consequential on Amendments 55 and 64.

None NC4

To move the following Clause— “Implementing the prohibition of the promotion of certain tax avoidance arrangements (1) The Treasury must, within six months of the passing of this Act, consult and report on— (a) how to ensure the regulations specified under section 156(2) of this Act can address the potential for harm to individuals and small businesses from the promotion online and via social media of tax avoidance arrangements by professionals and by social media tax influencers, (b) the potential for detriment to individuals who are liable for tax arising from such promotions, and (c) what steps HMRC should take to inform the public of the risks posed by online tax avoidance arrangements. (2) The Chancellor of the Exchequer must lay before Parliament a report on the outcome of the consultation under subsection (1), including the steps they plan to take to address any issues identified. (3) In this section, “tax influencer” means an individual who— (a) is not a tax professional, (b) promotes, markets or otherwise encourages participation in a tax avoidance arrangement, and (c) does so by means of a social media service, where that promotion is carried out— (i) in the course of a business or trade, or (ii) in consideration of, or in expectation of, any payment or other benefit, whether from a promoter of the arrangement or from the social media service, or (iii) with the intention of increasing engagement with, or the monetisation of, content relating to the arrangement.”

None 10

Page 94, line 4, leave out Clause 77

None 11

Page 96, line 6, leave out Clause 78

Opposition Amendment NC1

To move the following Clause— “Report on fairness and scope of the loan charge settlement opportunity (1) HM Revenue and Customs must, within 12 months of the passing of this Act, lay before the House of Commons a report on the operation and impact of any loan charge settlement opportunity established under section 25 of this Act. (2) The report under subsection (1) must in particular consider— (a) whether the terms of the settlement opportunity are available to individuals who have previously settled or fully paid liabilities arising from disguised remuneration loan arrangements, (b) whether the terms of the settlement opportunity are available to individuals with disguised remuneration loan arrangements falling outside the loan charge years specified in Part 7A of the Income Tax (Earnings and Pensions) Act 2003, (c) the extent to which any differences in treatment between these groups and those eligible for the settlement opportunity affect perceptions of fairness, and (d) the potential impact of such perceptions on future tax compliance and trust in the tax system. (3) The report must include— (a) an assessment of whether extending more favourable settlement terms to the groups described in subsection (2)(a) and (b) would improve fairness and consistency, and (b) any recommendations HMRC consider appropriate in light of that assessment.”

Opposition Amendment NC2

To move the following Clause— “Report on implementation customer service standards in relation to sections 253 to 258 (1) The Commissioners must, within six months of the commencement of sections 253 to 258, lay before the House of Commons a report setting out— (a) customer service standards for persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970, including— (i) maximum waiting times for telephone helpline calls, (ii) minimum call answering rates, (iii) maximum response times for written correspondence, and (iv) availability of in-person support; (b) measures taken to ensure adequate staffing and resources to meet those standards; (c) data on actual performance against those standards in each quarter; and (d) remedial action to be taken where standards are not met. (2) The customer service standards published under subsection (1) must ensure that persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970 can access support through non-digital channels with service levels comparable to those historically provided before the introduction of Making Tax Digital. (3) The Commissioners must publish an annual report on compliance with the customer service standards established under subsection (1), and lay a copy of the report before the House of Commons.”

Opposition Amendment NC3

To move the following Clause— “Report on winter fuel payment charge and related compliance and collection measures (1) The Commissioners for HM Revenue and Customs must lay before the House of Commons a report on the operation and effects of the charge applied to winter fuel payments where an individual’s income exceeds the relevant threshold, including the compliance and collection arrangements introduced under section 55 and Schedule 10 in relation to that charge. (2) The report under subsection (1) must in particular consider— (a) the effect of the charge on people whose income exceeds the threshold by a small amount, and any resulting behavioural impacts, (b) the administrative complexity and proportionality of introducing a tapered abatement for winter fuel payments, (c) the potential effect of updating section 7 of the Taxes Management Act 1970 so that a winter fuel payment charge becomes a notifiable liability for tax assessment purposes, including the operation of penalties for failure to notify, and the interaction with existing exceptions for liabilities reflected in PAYE tax coding adjustments or where a taxpayer has already been issued a notice to file a self-assessment return, and (d) the operation and effectiveness of any new PAYE regulation provisions that allow winter fuel payment charges to be collected via tax code adjustments in year, and which allow HMRC to repay any overpaid income tax related to the charge via the tax code within the same year.”

Opposition Amendment 9

Clause 74, page 91, line 25, at end insert— “(7) The Treasury must make regulations under subsection (1) within 60 days of the passing of this Act. (8) Before making regulations under subsection (1), the Treasury must consult— (a) organisations representing infected and affected individuals, (b) the Infected Blood Compensation Authority, and (c) bereaved families of victims who have died awaiting compensation. (9) The regulations made under subsection (1) must make provision for identifying and assisting the estates of deceased victims in claiming inheritance tax relief, including— (a) outreach to known affected families, (b) assistance with evidence gathering where medical records have been destroyed, (c) clear and accessible guidance in plain language, and (d) a dedicated helpline staffed by trained caseworkers familiar with the infected blood scandal. (10) The Treasury must, within 6 months of regulations under this section coming into force, and every 6 months thereafter, lay before Parliament a report on— (a) the number of victims who have died since the previous report while awaiting compensation, (b) the number of estates that have received inheritance tax relief, (c) the average time taken to process claims for relief, (d) any identified barriers preventing families from accessing their entitlement, and (e) steps taken to expedite outstanding infected blood compensation claims.”

Opposition Amendment 1

Page 2, line 7, leave out Clause 4

Opposition Amendment 2

Page 2, line 16, leave out Clause 5

Opposition Amendment 3

Page 2, line 21, leave out Clause 6

Opposition Amendment 4

Page 4, line 31, leave out Clause 7

Opposition Amendment 5

Page 5, line 20, leave out Clause 10

Opposition Amendment 6

Page 78, line 4, leave out Clause 62

Opposition Amendment 7

Page 78, line 11, leave out Clause 63

Opposition Amendment 8

Page 442, line 2, leave out Schedule 12

Opposition Amendment 50

Clause 259, page 236, line 4, at end insert—
“(1A) After paragraph 5(8) insert—
(8A)A person is not liable to a penalty point as a result of the late filing of a return under this Schedule if they had no tax liability due in the relevant period.
(8B)For the purpose of this section, “no tax liability due” has the meaning that the total amount of tax owed, after credit for any tax deducted at source, tax credits, or other reliefs, is zero or results in a repayment to the taxpayer.””

This amendment would mean that a person would not be subject to a penalty point because of the late filing of a return where there is no tax liability due.

Opposition Amendment NC33

To move the following Clause—
“Review of effects of the Act on businesses
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, conduct a review of the aggregate effects on businesses of the measures contained in this Act.
(2) The Chancellor of the Exchequer must lay before the House of Commons a report setting out recommendations arising from the review under subsection (1).
(3) The review must make recommendations on—
(a) using business taxes to encourage and increase the investment of profits and revenue, and
(b) ensuring businesses have more certainty about the taxes to which they are subject.”

This new clause would require the Chancellor of the Exchequer to conduct a review of the aggregate effects on businesses of the measures contained in this Act, and to make recommendations on how to increase certainty and investment.

Opposition Amendment NC34

To move the following Clause—
“Review of impact of tax changes in this Act on households
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, publish an assessment of the aggregate impact of the measures in this Act on household finances.
(2) The assessment under subsection (1) must consider how households at a range of different income levels are affected by the measures in this Act.”

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

Opposition Amendment NC35

To move the following Clause—
“Review of effects of the Act on small businesses
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, lay before the House of Commons an assessment of the expected impact of the measures in this Act on small businesses.
(2) The report under subsection (1) must assess the effect on small businesses 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 effects of the Act on small businesses.

Opposition Amendment NC36

To move the following Clause—
“Review of the effects of this Act on the administrative burden on businesses
(1) The Chancellor of the Exchequer must, within 12 months of the passing of this Act, lay before the House of Commons a report on the effects of the provisions of this Act on administrative burdens faced by businesses.
(2) The report must in particular consider any—
(a) change in the time or resources required by businesses to comply with obligations arising under this Act,
(b) effects on small and medium-sized enterprises, and
(c) measures taken by HMRC to mitigate any increase in administrative burdens.
(3) The Chancellor of the Exchequer must make a statement to the House of Commons on the findings of the report within three months of its publication.”

This new clause would require the Chancellor of the Exchequer to review and report on the effects of the Act on the administrative burden on businesses, including the impact on SMEs and any mitigation measures.

Opposition Amendment NC32

To move the following Clause—
“Air passenger duty change on boarding passes
The Chancellor of the Exchequer must by regulations require travel operators who are liable to air passenger duty to ensure that in the case where a boarding pass is issued, the change in the level of air passenger duty made under section 96 and charged in respect of the passenger’s journey, is clearly stated on the boarding pass.”

Opposition Amendment NC31

To move the following Clause—
“Review of effects of sections 87 and 88 on illicit tobacco market
The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the provisions made under sections 87 and 88 on the illicit tobacco market.”

This new clause would require the Chancellor of the Exchequer to publish an assessment of the impact of sections 87 and 88 on the illicit tobacco market.

None 49

Schedule 3, page 268, line 14, at end insert—
“Part 1B
Transitional protection for pre-6 april 2025 transfer structures
7A After section 720 of ITA 2007 insert—
“720ZA Transitional preservation of deferral for pre-6 April 2025 transfer structures
(1) This section applies where—
(a) income arises to a person abroad on or after 6 April 2025,
(b) the income arises directly or indirectly from a transfer of assets, or an associated operation, made or effected on or before 5 April 2025 (“the legacy structure”), and
(c) immediately before 6 April 2025, the individual who would (apart from this section) be treated as liable under this Part was an individual who, for one or more tax years prior to 2025–26, was charged income tax on foreign income and gains only to the extent that such income or gains were remitted to the United Kingdom under the law then in force.
(2) For the purposes of this Part and any other provision of the Income Tax Acts which would otherwise treat income as arising to an individual by reason of a transfer of assets, income to which this section applies is not to be treated as arising to the individual in the tax year in which it arises to the person abroad.
(3) Income to which this section applies is to be treated as arising to the individual in the tax year in which—
(a) the income, or
(b) any benefit derived directly or indirectly from that income,
is remitted to, received in, or used in the United Kingdom.
(4) For the purposes of determining whether any liability arises under subsection (3), or under this Part or any other provision treating income as arising by reason of a transfer of assets—
(a) the continued existence, administration, refinancing, servicing, variation or discharge of obligations of the legacy structure,
(b) the retention, accumulation, investment, reinvestment or economic growth of income or assets within the legacy structure, and
(c) any associated operation undertaken wholly or mainly for the purpose of preserving, maintaining or unwinding the legacy structure or obligations incurred before 6 April 2025,
are not to be treated as conferring enjoyment, providing a benefit or giving rise to a charge solely by reason of the deferral of taxation until remittance.
(5) This section does not apply to income arising from capital or value added to the legacy structure on or after 6 April 2025.
(6) In this section—
“associated operation” has the meaning given by section 719;
“Income Tax Acts” has the meaning given by section 831.””

This amendment creates a transitional protection for legacy structures established before 6 April 2025 by former remittance basis users. It ensures that income within such structures is taxed only when remitted to the UK and prevents the maintenance, refinancing, or growth of the structure from being treated as tax avoidance or a taxable benefit.

Opposition Amendment NC30

To move the following Clause—
“Air passenger duty on boarding passes
The Chancellor of the Exchequer must by regulations made under section 96 require operators of aircraft who are liable to air passenger duty to ensure that in the case where a boarding pass is issued, the amount of air passenger duty charged in respect of the passenger’s journey is clearly stated on that boarding pass.”

Government Amendment 39

Clause 225, page 212, line 22, leave out paragraph (a)

This amendment omits penalties under the disclosure of tax avoidance schemes provisions from the definition of “relevant anti-avoidance penalty”.

Government Amendment 40

Clause 225, page 212, line 28, leave out paragraph (d)

This amendment omits penalties under the disclosure of tax avoidance schemes (VAT and other indirect taxes) provisions from the definition of “relevant anti-avoidance penalty”.

Opposition Amendment NC1

To move the following Clause—
“Report on the impact of section 15
(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 impact of implementation of the provisions of section 15 on—
(a) early-stage investment volume,
(b) investor participation, and
(c) international competitiveness.”

This new clause would require the Chancellor of the Exchequer to report to the House on the impact of section 15 on early-stage investment volumes, investor participation and the UK’s international competitiveness.

Opposition Amendment NC2

To move the following Clause—
“Report on the impact of section 28
(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 impact of implementation of the provisions of section 28 on—
(a) business investment levels,
(b) capital-intensive sector employment,
(c) the manufacturing sector,
(d) small and medium-sized enterprises, and
(e) the public finances.”

This new clause would require the Chancellor of the Exchequer to report to the House on the impact of section 28 on business investment, employment in capital-intensive sectors, the manufacturing sector, small and medium-sized enterprises and the public finances.

Opposition Amendment NC3

To move the following Clause—
“Review of the impact of section 30
(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 impact of the expiry in 2027 of the 100% allowance made under section 30.
(2) The report under subsection (1) must assess the case for long-term capital allowance support for zero-emission cars and electric vehicle charging points to maintain UK competitiveness in green technology.”

This new clause would require the Chancellor of the Exchequer to review and report on the impact of the expiry in 2027 of the 100% allowance made under section 30, including the case for ongoing capital allowance support for zero-emission cars and electric vehicle charging points.

Opposition Amendment NC4

To move the following Clause—
“Report on the impact of section 48 (international controlled transactions)
(1) The Chancellor of the Exchequer must, within 6 months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 48 on—
(a) cross-border trade, and
(b) administrative burdens on businesses.
(2) The report under subsection (1) must in particular set out the steps the Government intends to take to consult affected businesses and stakeholders on the operation of section 48.”

This new clause would require the Chancellor of the Exchequer to report to the House on the impact of section 48 on cross-border trade and business administrative burdens, and to set out how affected businesses and stakeholders will be consulted.

Opposition Amendment NC5

To move the following Clause—
“Pillar Two competitive safeguards and review
(1) The Chancellor of the Exchequer must, every six months beginning from the day on which this Act is passed, review the implementation of the provisions of section 50 and Schedule 8.
(2) Any review under subsection (1) must consider—
(a) whether other major economies are implementing Pillar Two on comparable timelines and with comparable scope,
(b) any competitive disadvantage to UK-based multinationals from implementation of section 50,
(c) any impact arising from differentiated treatment for the US, and
(d) proposals for remedial measures to address any competitive disadvantage to the UK that has been identified.
(3) The Chancellor of the Exchequer must lay before the House of Commons a copy of any review undertaken under subsection (1).”

This new clause would require regular reviews of the implementation of section 50 and Schedule 8, including consideration of international implementation of Pillar Two, any competitive disadvantage for UK-based multinationals and possible remedial measures.

Opposition Amendment NC6

To move the following Clause—
“Report on legacies to charities
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 52 on—
(a) charitable giving through estates, and
(b) charity sector income.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 52 on charitable giving through estates and on the income of the charity sector.

Opposition Amendment NC7

To move the following Clause—
“Report on charitable investments purpose test
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 53 on charity investment strategies.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 53 on charity investment strategies.

Opposition Amendment NC8

To move the following Clause—
“Report on tainted charity donations
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 54 and Schedule 9 on—
(a) legitimate charitable giving, and
(b) prevention of tax avoidance.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 54 and Schedule 9 on legitimate charitable giving and the prevention of tax avoidance.

Opposition Amendment NC9

To move the following Clause—
“Review of outcome test
(1) The Chancellor of the Exchequer must within two years of the passing of this Act, review implementation of the outcome test under section 54.
(2) The review must assess whether the outcome test is clearer and more effective than the purpose test.”

This new clause would require the Chancellor of the Exchequer to review the implementation of the outcome test in section 54 and to assess whether it is clearer and more effective than the existing purpose test.

Opposition Amendment NC10

To move the following Clause—
“Review of uprating of Winter Fuel Payment charge cap
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, lay before the House of Commons a report on the impact of uprating, by reference to the consumer prices index, the level of the winter fuel payment charge specified under Schedule 10.
(2) The report under subsection (1) must in particular assess the impact of such uprating on—
(a) households liable to the winter fuel payment charge, and
(b) Exchequer receipts.”

This new clause would require the Chancellor of the Exchequer to report on the impact of uprating the winter fuel payment charge cap in line with the consumer prices index on liable households and on Exchequer receipts.

Opposition Amendment NC11

To move the following Clause—
“Impact assessment on carried interest reforms
The Chancellor of the Exchequer must, within 2 years of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 56 on—
(a) the UK’s competitiveness in attracting and retaining fund managers,
(b) the level and composition of investment into the UK, and
(c) revenues collected compared to forecast revenues.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 56 on the UK’s ability to attract and retain fund managers, on investment into the UK and on realised revenues compared with forecasts.

Opposition Amendment NC12

To move the following Clause—
“Report on decommissioning relief agreements
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 61 on—
(a) North Sea decommissioning activity,
(b) employment levels in the UK oil and gas industry,
(c) capital expenditure in the UK oil and gas industry,
(d) UK oil and gas production,
(e) UK oil and gas demand, and
(f) the Scottish economy and economic growth in Scotland.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 61 on North Sea decommissioning, employment and capital expenditure in the UK oil and gas industry, UK production and demand, and the Scottish economy.

Opposition Amendment NC13

To move the following Clause—
“Report on gifts exemption
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 75 on—
(a) the volume and value of charitable donations,
(b) the financial position and funding mix of charities and registered clubs,
(c) donor behaviour, including any changes in the use of tax-relieved giving, and
(d) Exchequer revenues, including any distributional impacts across different types and sizes of charities.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 75 on charitable donations, the finances of charities and registered clubs, donor behaviour and Exchequer revenues.

Opposition Amendment NC14

To move the following Clause—
“Report on VAT for private hire and taxi vehicles
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 79 on—
(a) the taxi and private hire industry,
(b) driver earnings,
(c) vulnerable passengers,
(d) rural communities, and
(e) passenger fares.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 79 on the taxi and private hire industry, driver earnings, vulnerable passengers, rural communities and passenger fares.

Opposition Amendment NC15

To move the following Clause—
“Review of extension of three-year period for UK listing relief
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, publish and lay before Parliament a report on the potential benefits of extending beyond three years the period for which UK listing relief applies under section 82.
(2) The report under subsection (1) must assess the—
(a) impact that extending the period could have on the attractiveness of UK markets for new listings,
(b) potential effects on capital raising and investment in the UK, and
(c) implications for Exchequer revenues.”

This new clause would require the Chancellor of the Exchequer to report on the potential benefits of extending beyond three years the period for which UK listing relief applies under section 82, including effects on the attractiveness of UK markets, capital raising and Exchequer revenues.

Opposition Amendment NC17

To move the following Clause—
“Statement on increases to vehicle excise duty for cars and light goods vehicles
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, make a statement to the House of Commons, on the increase to vehicle excise duty made under section 89.
(2) The statement under subsection (1) must include details of the impact on—
(a) the automotive sector,
(b) household incomes, and
(c) the UK economy.”

This new clause would require the Chancellor of the Exchequer to make a statement to the House on the impact of the increase to vehicle excise duty under section 89 on the automotive sector, household incomes and the UK economy.

Opposition Amendment NC18

To move the following Clause—
“Statements on HGV Vehicle Excise Duty and HGV Road User Levy
(1) The Chancellor of the Exchequer must, within six months of this Act being passed, make a statement to the House of Commons on the increase to HGV vehicle excise duty made under sections 90 to 93 and the increase to the HGV Road User Levy made under section 95.
(2) The statement under subsection (1) must include details of the impact on the—
(a) haulage sector,
(b) decarbonisation of the logistics industry, and
(c) UK economy.”

This new clause would require the Chancellor of the Exchequer to make a statement to the House on the increases to HGV vehicle excise duty under sections 90 to 93 and to the HGV Road User Levy under section 95, including their impact on the haulage sector, decarbonisation of logistics and the UK economy.

Opposition Amendment NC19

To move the following Clause—
“Report on expensive car supplement
(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 impact of implementation of the provisions of section 94 on—
(a) the automotive sector,
(b) the sale of hybrid cars, and
(c) vehicle excise duty revenues from high-value vehicles.
(2) The review must consider whether the threshold set under section 94 remains appropriate.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 94 on the automotive sector, sales of hybrid cars and vehicle excise duty revenues from high-value vehicles, and to consider whether the threshold remains appropriate.

Opposition Amendment NC20

To move the following Clause—
“Review of bands and rates of air passenger duty
(1) The Chancellor of the Exchequer must, within 18 months of this Act being passed, publish an assessment of the impact of the changes to air passenger duty made under section 96 on—
(a) the aviation industry,
(b) passengers,
(c) household finances, and
(d) the public finances.
(2) The assessment under subsection (1)(c) must consider how households at a range of different income levels are affected by the changes under section 96.”

This new clause would require the Chancellor of the Exchequer to publish an assessment of the impact of changes to air passenger duty under section 96 on the aviation industry, passengers, household finances at different income levels, and the public finances.

Opposition Amendment NC21

To move the following Clause—
“Report on Climate Change Levy rates
The Chancellor of the Exchequer must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 97 on—
(a) energy-intensive industries, and
(b) the UK’s international competitiveness.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 97 on energy-intensive industries and the UK’s international competitiveness.

Opposition Amendment NC22

To move the following Clause—
“Review of landfill tax changes
(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 98.
(2) The report under subsection (1) must in particular assess any effects on—
(a) construction and infrastructure projects,
(b) investment in ports,
(c) levels of recycling and illegal dumping,
(d) progress towards the Government’s environmental objectives, and
(e) Exchequer revenues.”

This new clause would require the Chancellor of the Exchequer to report on the impact of section 98, including any effects on construction and infrastructure projects, port investment, recycling and illegal dumping, progress towards environmental objectives and Exchequer revenues.

Opposition Amendment NC23

To move the following Clause—
“Report on aggregates levy rate
The Treasury must, within six months of this Act being passed, lay before the House of Commons a report on the impact of implementation of the provisions of section 99 on—
(a) the construction industry, and
(b) infrastructure projects.”

This new clause would require the Treasury to report on the impact of section 99 on the construction industry and infrastructure projects.

Opposition Amendment NC24

To move the following Clause—
“Report on impact of section 13 (Enterprise management incentives: thresholds and period for exercise)
(1) The Chancellor of the Exchequer must, within two years of the coming into force of section 13, lay before the House of Commons a report on the impact of that section.
(2) The report under subsection (1) must, in particular, assess the impact on—
(a) the recruitment and retention of skilled employees in qualifying companies,
(b) high-growth and innovative companies, and
(c) the Exchequer finances.”

This new clause would require the Chancellor of the Exchequer to report to the House of Commons on the impact of section 13 on recruitment and retention in qualifying companies, on high-growth and innovative businesses, and on the Exchequer finances.

Opposition Amendment NC25

To move the following Clause—
“Report on fairness and scope of the loan charge settlement opportunity
(1) HM Revenue and Customs must, within 12 months of the passing of this Act, lay before the House of Commons a report on the operation and impact of any loan charge settlement opportunity established under section 25 of this Act.
(2) The report under subsection (1) must in particular consider—
(a) whether the terms of the settlement opportunity are available to individuals who have previously settled or fully paid liabilities arising from disguised remuneration loan arrangements,
(b) whether the terms of the settlement opportunity are available to individuals with disguised remuneration loan arrangements falling outside the loan charge years specified in Part 7A of the Income Tax (Earnings and Pensions) Act 2003,
(c) the extent to which any differences in treatment between these groups and those eligible for the settlement opportunity affect perceptions of fairness, and
(d) the potential impact of such perceptions on future tax compliance and trust in the tax system.
(3) The report must include—
(a) an assessment of whether extending more favourable settlement terms to the groups described in subsection (2)(a) and (b) would improve fairness and consistency, and
(b) any recommendations HMRC consider appropriate in light of that assessment.”

This new clause would require HMRC to report on the operation and fairness of the new loan charge settlement opportunity. It would consider whether more favourable terms are, or should be, available to those who have already settled or fully paid liabilities, and to those with arrangements outside the loan charge years.

Opposition Amendment NC26

To move the following Clause—
“Report on the treatment of disguised remuneration arrangements outside the loan charge years
(1) HM Revenue and Customs must lay before the House of Commons a report on the treatment, under any loan charge settlement opportunity established under section 25 of this Act, of disguised remuneration arrangements falling outside the 2010/11 to 2018/19 tax years.
(2) The report under subsection (1) must in particular consider—
(a) the extent to which disguised remuneration income from tax years outside the loan charge period is excluded from the settlement terms,
(b) the number of taxpayers with disguised remuneration arrangements which HMRC consider to fall outside the loan charge but within Part 7A of the Income Tax (Earnings and Pensions) Act 2003,
(c) the interaction between settlements pursued in respect of such arrangements and those relating to the loan charge, and
(d) whether excluding factually linked arrangements from the settlement opportunity may prevent taxpayers achieving a full and final resolution of their tax affairs.
(3) The report must include—
(a) an assessment of whether including disguised remuneration arrangements that are factually linked to the loan charge period (whether arising before, during or after that period) would improve the effectiveness, fairness and finality of the settlement process, and
(b) any recommendations HMRC considers appropriate.”

This new clause would require HMRC to report on the exclusion from the new loan charge settlement opportunity of disguised remuneration arrangements outside the loan charge years, including arrangements which HMRC considers to fall outside the loan charge but within the disguised remuneration rules.

Opposition Amendment NC27

To move the following Clause—
“Report on winter fuel payment charge and related compliance and collection measures
(1) The Commissioners for HM Revenue and Customs must lay before the House of Commons a report on the operation and effects of the charge applied to winter fuel payments where an individual’s income exceeds the relevant threshold, including the compliance and collection arrangements introduced under section 55 and Schedule 10 in relation to that charge.
(2) The report under subsection (1) must in particular consider—
(a) the effect of the charge on people whose income exceeds the threshold by a small amount, and any resulting behavioural impacts,
(b) the administrative complexity and proportionality of introducing a tapered abatement for winter fuel payments,
(c) the potential effect of updating section 7 of the Taxes Management Act 1970 so that a winter fuel payment charge becomes a notifiable liability for tax assessment purposes, including the operation of penalties for failure to notify, and the interaction with existing exceptions for liabilities reflected in PAYE tax coding adjustments or where a taxpayer has already been issued a notice to file a self-assessment return, and
(d) the operation and effectiveness of any new PAYE regulation provisions that allow winter fuel payment charges to be collected via tax code adjustments in year, and which allow HMRC to repay any overpaid income tax related to the charge via the tax code within the same year.”

This new clause would require HMRC to report to Parliament on the operation of the winter fuel payment charge, including its effect on people whose income exceeds the threshold by a small amount. The report would also cover the implications of updating section 7 of the Taxes Management Act 1970 to make winter fuel payment charge liabilities notifiable for tax assessment purposes.

Opposition Amendment NC28

To move the following Clause—
“Implementation of section 35 (Restriction of relief on disposals to employee-ownership trusts
(1) HM Revenue and Customs must, as part of the implementation of the provisions of section 35, make an assessment of the potential benefits of establishing a digital application process for taxpayers seeking to pay capital gains tax by instalments under section 280 of TCGA 1992 in respect of disposals to employee ownership trusts.
(2) The assessment made under subsection (1) must consider potential guidance on eligibility criteria and processing timescales.”

This new clause would require HMRC to assess the potential benefits of establishing a digital application process for taxpayers to pay capital gains tax by instalments in respect of disposal to employee ownership trusts as part of the implementation of section 35.

Opposition Amendment NC29

To move the following Clause—
“Report on the impact of section 35
The Chancellor of the Exchequer must, within 12 months of this section coming into force, lay before the House of Commons a report assessing the impact of the changes made under section 35 on small and medium-sized enterprises, including—
(a) the number of EOT transactions completed compared to the previous three-year average,
(b) any administrative costs and burdens reported by businesses and tax advisers,
(c) the incidence and value of dry tax charges arising, and
(d) recommendations for any modifications to the instalment payment regime under Section 280 of TCGA 1992.”

This new clause would require the Chancellor of the Exchequer to lay a report before the House of Commons on the impact of section 35 on small and medium-sized enterprises.

Government Amendment 37

Clause 13, page 7, line 37, at end insert—
“( ) In section 169I(7D)(b) of TCGA 1992 (material disposal of business assets)—
(a) for “tenth ” substitute “specified”;
(b) at the end insert “(with “specified anniversary” having the meaning given in section 529(2A) of that Act)”.”

This amendment to TCGA 1992 would reflect the changes made to section 529 of ITEPA 2003 by clause 13 of the Bill.

Government Amendment 38

Clause 13, page 7, line 38, for “(7)” substitute “(8)”

This amendment is consequential on the addition of a new subsection by Amendment 37.

Opposition Amendment 29

Clause 15, page 10, line 23, leave out subsection (2)

This amendment would maintain the rate of income tax relief for investments into venture capital trusts at 30 per cent.

Opposition Amendment 47

Clause 74, page 91, line 20, leave out from “(1)” to the end of line 25 and insert “may not be made unless a draft of the instrument has been laid before, and approved by resolution of, the House of Commons.”

This amendment would require that all regulations made under this section are subject to the affirmative procedure.

Opposition Amendment 48

Clause 74, page 91, line 25, at end insert—
“(6) Before laying regulations under subsection (1), the Treasury must make a statement setting out the extent to which the regulations made under this section meet the following objectives—
(a) that no infected or affected person, or their family, will be subject to inheritance tax in respect of infected blood compensation payments under the regulations,
(b) that the regulations provide fair and consistent treatment for all victims regardless of when their compensation was paid or when deaths occurred,
(c) that the relief provides compensation for physical harm and psychological trauma experienced by affected family members, and
(d) that administrative processes established for the purposes of implementation of this section will not create additional distress or burden for bereaved families.”

This amendment would require that, prior to making regulations under the section, the Chancellor should make a statement on the extent to which the regulations meet certain objectives in respect of the treatment of victims and their families.

Opposition Amendment 46

Clause 74, page 91, line 25, at end insert—
“(7) The Treasury must make regulations under subsection (1) within 60 days of the passing of this Act.
(8) Before making regulations under subsection (1), the Treasury must consult—
(a) organisations representing infected and affected individuals,
(b) the Infected Blood Compensation Authority, and
(c) bereaved families of victims who have died awaiting compensation.
(9) The regulations made under subsection (1) must make provision for identifying and assisting the estates of deceased victims in claiming inheritance tax relief, including—
(a) outreach to known affected families,
(b) assistance with evidence gathering where medical records have been destroyed,
(c) clear and accessible guidance in plain language, and
(d) a dedicated helpline staffed by trained caseworkers familiar with the infected blood scandal.
(10) The Treasury must, within 6 months of regulations under this section coming into force, and every 6 months thereafter, lay before Parliament a report on—
(a) the number of victims who have died since the previous report while awaiting compensation,
(b) the number of estates that have received inheritance tax relief,
(c) the average time taken to process claims for relief,
(d) any identified barriers preventing families from accessing their entitlement, and
(e) steps taken to expedite outstanding infected blood compensation claims.”

This amendment requires the Chancellor of Exchequer to make regulations under this section within 60 days of Royal Assent. It requires mandatory consultation with those directly affected, and a support service to help bereaved families navigate the system. It also places a six-monthly reporting requirement on the Government.

Opposition Amendment 36

Page 95, line 28, leave out Clause 79

Opposition Amendment 42

Clause 79, page 95, line 37, at end insert—
“(3B) Section (3A) does not apply to journeys by private hire vehicle or taxi in rural areas.”

This amendment would exempt journeys by taxi and private hire vehicle in rural areas from the provisions of subsection (3A) of section 79.

Opposition Amendment 43

Clause 80, page 96, line 28, at end insert—
(2A)The Treasury must, each year, amend by order the applicable limit set under section 5A(2)(a) by the change in the level of the consumer prices index in the previous tax year.”

This amendment would provide for the £200 applicable limit to be uprated annually in line with the consumer prices index.

Opposition Amendment 44

Clause 107, page 129, line 32, at end insert—
“(10) Before giving a direction under sub-paragraph (1), the Secretary of State must lay before Parliament an impact statement setting out—
(a) the evidence on which the Secretary of State has concluded that the conditions in sub-paragraph (1) have been met,
(b) an assessment of the potential impact on consumer prices and UK supply chains,
(c) the reasons why a direction is considered necessary in the circumstances, and
(d) whether coordination with other jurisdictions, including the European Union, has been considered.
(11) A direction under sub-paragraph (1) shall cease to have effect if, within the period of 21 sitting days beginning with the day on which the statement under sub-paragraph (10) is laid, either House of Parliament resolves that the direction should be annulled.”

This amendment would require the Secretary of State to provide Parliament with an impact statement before directing the TRA to initiate a dumping or subsidisation investigation, and would give Parliament the power to annul such directions within 21 sitting days.

Opposition Amendment 45

Clause 107, page 129, line 43, at end insert—
“(6A) In paragraph 17, at end insert—
(11)Before making a recommendation under paragraph 17, the TRA must prepare and publish an assessment of—
(a)the likely impact of the proposed anti-dumping amount or countervailing amount on consumer prices,
(b)the effect on UK businesses that use the goods subject to investigation as inputs in their production processes,
(c)the overall impact on the UK economy, including benefits to UK producers and costs to UK consumers and supply chains, and
(d)whether a lower duty than the margin of dumping or amount of subsidy would be sufficient to remedy any injury to UK industry.
(12)The Secretary of State must have regard to the assessment made under sub-paragraph (11) when making a decision on whether to accept the TRA's recommendation and at what level to set any anti-dumping or countervailing duties.””

This amendment would require the Trade Remedies Authority to assess and publish the consumer and wider economic impact of proposed anti-dumping or countervailing duties.

Opposition Amendment NC16

To move the following Clause—
“Review of effects of section 88 on illicit tobacco market
The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of the provisions made under section 88, on the illicit tobacco market.”

This new clause would require the Chancellor of the Exchequer to publish an assessment of the impact of section 88 on the illicit tobacco market.

Opposition Amendment 33

Schedule 3, page 268, line 19, at end insert—
“TRF available to non-residents
8A Omit sub-paragraph 1(7).”

This amendment provides that the Temporary Repatriation Facility is also available to non-residents.

Opposition Amendment 34

Schedule 3, page 268, line 19, at end insert—
“Removal of requirement that individual must have been subject to the remittance basis for a past year
8A Omit sub-paragraph 1(5).”

This amendment would enable offshore trust beneficiaries who have not themselves used the remittance basis to use the TRF.

Opposition Amendment 35

Schedule 3, page 268, line 19, at end insert—
“Trustee designation
8A After paragraph 1 insert—
“Trust cleansing facility charge
1A (1)The Trustees of a settlement may in the tax year 2025/26 or 2026/27 make a claim in relation to any or all of the following (“trust income or gains”)—
(a)a section 1(3) amount of the settlement for any tax year before 2025/26,
(b)an OIG amount of the settlement for any tax year before 2025/26,
(c)a section 1(3) amount in a schedule 4C pool of the settlement for any tax year before 2025/26,
(d)protected foreign source income or transitional trust income of the settlement for the purposes of section 643A of ITTOIA 2005,
(e)any relevant foreign income of the settlement for any tax year before 2025/26 that would, if remitted, be treated under section 648(3) of ITTOIA 2005 as arising only if and when remitted, and
(f)foreign relevant income of the settlement for the purposes of chapter 2 of part 13 of ITA 2007 (transfer of assets abroad) for any tax year before 2025/26.
(2)On the making of such a claim the Trustees shall be subject to the TRF charge and paragraph 1(8) shall apply to the Trustees as it applies to an individual.
(3)The amount of trust income or gains of the settlement for the category or categories in respect of which a claim is made shall be reduced accordingly.””

This amendment enables trustees to pay a TRF charge on the trust’s past FIG while retaining the funds within the trust.

Opposition Amendment 30

Schedule 3, page 271, line 26, leave out from “amount” to end and insert “is the lower of—
(a) the value of the amount when it first arose to the individual, or
(b) its value on 6 April 2025.”

This amendment provides that where an investment derived from foreign income has fallen in value, the temporary repatriation facility (TRF) charge is paid on the reduced value of the investment at the point the TRF opened.

Opposition Amendment 31

Schedule 3, page 275, line 38, leave out “paragraphs 9 to 16” and insert “paragraphs 9 to 12 and 14 to 16”

Opposition Amendment 32

Schedule 3, page 276, line 3, at end insert—
“(3) The amendments made by paragraph 13 of this Schedule have effect where the matched capital payment referred to in sub-paragraph 8(2C)(b) Finance Act 2025 (as inserted by paragraph 13 of this Schedule) is made on or after 26 November 2025.”

These amendments provide that a double tax charge created by paragraph 13 of Schedule 3 shall not apply retrospectively.