National Insurance Contributions (Reduction in Rates) (No.2) Bill

James Murray Excerpts

2nd reading
Wednesday 13th March 2024 Commons Chamber

[James Murray (Ealing North) (Lab/Co-op)]

Let me start by saying that the official Opposition will support the national insurance reductions before us. We have long said that the tax burden on working people is too high and should come down in a responsible way. In fact, when the now Prime Minster was pushing through a national insurance increase two years ago, we opposed it. Labour has consistently said that we want taxes on working people to be lower. Just as we supported the reductions in national insurance in January, we support the further measures announced in the Budget last week that are before us today.

The truth is, however, that neither the national insurance cuts nor anything else in the Budget changes the fact that people across Britain are worse off under the Conservatives. The Government are giving with one hand, but are taking far more with the other. Figures from the Office for Budget Responsibility show that for every £5 that working people will get back from the Government’s national insurance cuts, they will be losing a total of £10 thanks to the Conservatives’ tax plan. That tax plan will leave the average household £870 worse off and will drag 3.7 million more people into paying tax by 2028-29. Last week’s Budget confirms that, even after the changes we are considering today, the tax burden will continue to rise in each and every year of the forecast period, with the UK still set to have its highest tax burden in 70 years. That is the reality of Britain under the Conservatives, and that is why people across the country are saying it is time for change.

The national insurance reductions in the Bill were mentioned by the Chancellor toward the end of his Budget statement last Wednesday. The cuts had of course already been confirmed in the media by Government sources in the days before, so they came as no surprise. Many of us in the Chamber were wondering whether the Chancellor would follow the time-honoured tradition of ending his Budget by pulling an unexpected, and as yet unannounced, rabbit out of the hat. It turns out he did have a rabbit, but even after all the chaos of the Conservatives over the past few years, many of us could not quite believe what we were hearing: the Chancellor’s big pitch to the British people in the last Budget before the general election was a £46 billion unfunded tax plan.

As people across Britain continue to suffer the impact of the disastrous mini-Budget of 2022, the Conservative Chancellor announced that he would go into the general election with a plan to abolish national insurance, leave a £46 billion hole in the public finances, put family finances across the country at risk, and create huge uncertainty for pensioners. It is frankly the height of irresponsibility for the Chancellor to use the opportunity of last week’s Budget—an opportunity that should have been used to set out a long-term plan to grow the economy—to follow in the footsteps of his reckless predecessor with a £46 billion unfunded tax cut.

In fact, though, perhaps my comment is unfair to the Chancellor’s predecessor, because even he now seems to be critical of the current Chancellor’s approach. Yesterday, the right hon. Member for Spelthorne (Kwasi Kwarteng) told the BBC’s “Politics Live” that he thinks the Chancellor should indeed spell out how he will pay for the abolition of national insurance. It is quite something when the Chancellor who crashed the economy after his disastrous mini-Budget publicly calls on the current Government to be more responsible.

The truth is that promises of unfunded tax cuts have nothing to do with growing the economy, and everything to do with propping up a weak Prime Minister who is desperately trying to survive in a divided Conservative party. This reckless behaviour shows that the Conservatives are blindly putting party first and country second. For the good of the economy and of the millions of hard-working people who are still paying the price for the disastrous mini-Budget, I urge Treasury Ministers when they respond finally to come clean about how they will pay for their £46 billion unfunded tax plan.

Over the past week, we have seen Ministers struggle with that question. The day after the Budget, the Secretary of State for Work and Pensions implied that he did not feel the need to explain how the commitment would be funded as it was only “an aspiration”. On Sky News that day, the Exchequer Secretary to the Treasury seemed to think that the Conservatives do not need to explain how they will fund their promise as it may “take several Parliaments”.

The position of the Prime Minister and Chancellor is clear, however. In an email to his party members on Budget day, the Chancellor confirmed that abolishing national insurance would be a priority for the next Parliament, if the Conservatives win. The next day, he suggested that that could be achieved by merging national insurance into income tax, a move that raises the prospect of a huge tax hike for pensioners. On the Saturday after the Budget, the Prime Minister confirmed again that abolishing national insurance would be a priority for the Conservatives in the next Parliament, if they are still in Government.

Let us be clear: this is a £46 billion unfunded tax plan. It is a plan that comes from the top of the Conservative party about what they would do in the next Parliament. It comes straight out of the same playbook as the Conservatives’ disastrous mini-Budget that crashed the economy. This unfunded plan is yet more chaos and recklessness from the Conservatives. Only Labour will bring stability and security back to the British economy.

If Treasury Ministers disagree that their party is the reckless party, they can clear this up today by explaining how they will pay for their £46 billion tax cut. Will it be funded by higher income tax? Will it be funded by cuts to public services? Will they push up borrowing? The Conservatives’ unfunded tax plan blows a £46 billion hole in funding earmarked for the state pension and the NHS. They need to come clean today about what that means for people’s tax bills, pensions and public services.

To be fair, the Chancellor has at least hinted how he thinks that the Conservatives could pay for the abolition of national insurance: his proposal to merge national insurance with income tax. Of course, taking that route and replacing the revenue from employee and self-employed national insurance contributions with greater basic and higher rates of income tax would mean rates of income tax going up by 6.5%. That would hit all income tax payers and cause particular alarm for pensioners. Under the Chancellor’s planned merger, pensioners—who do not currently pay national insurance—could see an average tax hike of about £800 each. A retired pensioner with an income of £25,000 from a mix of private and state pension paying an extra 6.5% on their income above the personal allowance would see their income tax bill rise by more than £800.

Furthermore, national insurance contributions are what determine people’s entitlement to the basic state pension. The Conservatives’ plan to abolish national insurance in the next Parliament would sever the link between contributions and pension entitlement. Will the Minister explain, under their plan to abolish national insurance, how people will know what their future entitlement to the state pension will be? What would be the basis for state pension entitlement without employee national insurance contributions? Does their plan mean the end of the state pension as we know it? I hope that the Minister will take this opportunity to give clear answers to all those questions, or else confirm that the Conservatives have dropped their unfunded plan to abolish national insurance altogether.

[Alexander Stafford]

I have a lot of respect for the hon. Gentleman. He comes from a professional background, and, compared with most people on the Labour Benches, normally knows what he is talking about. However, I want to follow his logic when it comes to what he claims is a reckless potential abolition of national insurance. If abolishing all national insurance is reckless and will lead to the country going to hell in a handcart, as he so wants to portray it, why is Labour not opposing a reduction in national insurance? Surely, if he does not oppose a reduction in national insurance, his argument completely falls down, because that means that national insurance can be got rid of.

[James Murray]

I thank the hon. Member for his intervention—I think. He misses the point. The commitment by the Chancellor, the Prime Minister and, I think, the Treasury Ministers, although they seem to oscillate a little in their position, is to get rid of national insurance entirely—to abolish it at a cost of £46 billion—but they are refusing to say how that would be funded. We saw what happened in autumn 2022 when unfunded tax cuts were proposed by the Conservative Government: it crashed the economy and pushed up people’s mortgages and rents. That is the risk of the Conservatives to the British people, that is the risk to the economy, and that is why we need a general election.

If the Conservatives want to move on from this discussion, they should give assurances on the matter when they respond to the debate. If they do not give those assurances and are not able to distance themselves and rule out their plan to abolish national insurance, we will know that they have essentially given up on governing, are incapable of acting responsibly, and are putting their party before the country with their reckless plans.

As I said at the start of my speech, we will support the Bill because, after 14 years of the Conservatives and 25 tax rises in this Parliament alone, the tax burden on working people is too high. Labour wants the tax burden on working people to come down in an economically and fiscally responsible way. However, let us be clear about the context of this Bill and the changes it makes to national insurance. Even with the Bill’s national insurance cuts in place, households across Britain are set to be an average of £870 worse off as a result of the Conservatives’ tax plans, and the tax burden in the UK is still set to rise to its highest in 70 years.

To make people better off and support public services, we need a plan to get the economy growing. We needed last week a Budget with a long-term plan to bring about growth and help to rebuild our public services. That is what the country needs, and that is what Labour is offering with our plan to grow the economy through stability, investment and reform. That is not what we saw last week, however. According to the British Retail Consortium, the Chancellor did

“little to promote growth and investment”.

The British Chambers of Commerce said this morning:

“the UK stills lacks a clear industrial strategy to unlock long-term growth.”

Faced with a record tax burden, failing public services and no plan for growth, we see the Conservatives grasping desperately for positive headlines by announcing a reckless, irresponsible and unfunded £46 billion tax plan.

I wonder whether the former Prime Minister, the right hon. Member for South West Norfolk (Elizabeth Truss), approves of this plan. Maybe she feels outdone, with this unfunded tax plan coming in at £1 billion more than hers. Either way, the conclusion is clear: chaos and recklessness are the currency of the Conservatives. Only Labour will bring stability, security and responsibility back to the economy, and only a general election will give the British people the chance to vote for change.

Coastal Tourism and Hospitality: Fiscal Support

James Murray Excerpts

Thursday 22nd February 2024 Westminster Hall

[James Murray (Ealing North) (Lab/Co-op)]

It is a pleasure to see you in the Chair, Mrs Cummins. I congratulate the hon. Member for North Devon (Selaine Saxby) on securing this debate on fiscal support for the tourism and hospitality industries in coastal areas. I put it on the record that, like her, I have benefited greatly from my conversations with Kate Nicholls at UK Hospitality.

I am pleased to respond to the debate on behalf of the Opposition. Hon. Members have spoken passionately about the importance of hospitality and tourism, the jobs they bring to local economies, the vitality they bring to our local areas and the enjoyment they bring to all our lives. As we have heard, the tourism and hospitality industries have been hit by a series of challenges, from covid to the cost of living crisis. The Opposition are clear that hospitality and tourism are vital to the UK economy and need a Government who are ready and able to help them thrive.

In 2019, the economic output of tourism-related industries was estimated at £134 billion, of which £74 billion was estimated to be generated directly by tourism. Those figures are respectively equivalent to 6.6% and 3.6% of the whole economy. Additionally, as I mentioned in a Westminster Hall debate a few weeks ago, on fiscal support for the hospitality sector hospitality provides 3% of the UK’s economic output, and billions in tax revenues for the Treasury.

Hospitality and tourism are important industries for communities across the country. As we have heard from the hon. Member for North Devon and others, they are especially critical to coastal areas. Coastal communities are particularly reliant on tourism and hospitality for employment and income. When the economy is not working as it should, those communities are more likely to suffer deprivation and unemployment. VisitBritain data shows that 10% of inbound tourists in 2019 visited England’s coasts and beaches, and those most likely to journey to the coast were on visits lasting a week or longer. That figure is higher in Wales, Scotland and the south-west of England. Such trips are vital to people’s livelihoods right across the UK.

In my west London constituency, we have no coasts that I can praise in this debate. But may I put it on record that when I occasionally leave Ealing North, I enjoy visiting coastal areas across the country, including Oban on the west coast of Scotland and Saltburn, Whitby and Staithes in North Yorkshire, and visiting my family on the south coast of England from Brighton to Fareham and Littlehampton?

Many hospitality and tourism businesses in coastal communities are finding it harder and harder to succeed, with high inflation, rising rents and the burden of business rates. At the same time, their customers find that they have less money to spend on enjoying what seaside hotels, pubs, cafés, restaurants and so on have to offer, as people have seen their wages flatlining while taxes and the cost of living climb relentlessly. Today’s debate is rightly an opportunity to recognise the central role of hospitality and tourism in British life, but it is also an opportunity to make it clear that those industries need a Government who will support them to thrive.

Labour will revitalise the hospitality and tourism industries. We will help coastal communities to get back on their feet after 14 years under the Conservatives. It is clear that the antiquated system of business rates is doing the industries no favours. As I set out in the debate on fiscal support for the hospitality sector a few weeks ago, hospitality and tourism businesses in coastal areas may have had hope when they heard the Government’s promise of a fundamental review of the business rates system in their 2019 manifesto. However, that review never materialised, and trade groups representing consumer-facing businesses have expressed their dismay at the Government’s inaction on that promise. In March last year, the Federation of Small Businesses responded to what the Government were doing on business rates by saying that

“the 2019 Manifesto commitment to hold a fundamental downward review of business rates has not happened…these changes do not amount to the fundamental overhaul the system needs, to reduce the chilling impact of a regressive tax that you pay before even earning a penny in turnover, let alone profit.”

We will not stand by while businesses struggle from year to year, facing uncertainty. As the shadow Chancellor, my right hon. Friend the Member for Leeds West (Rachel Reeves), has set out, if Labour were in Government we would scrap and replace business rates, shifting the burden away from hospitality and retail businesses, which continue to shoulder a heavy burden compared with those operating primarily in the digital economy.

Our new system would incentivise investment, promote entrepreneurship and reward businesses that move into empty premises. It would help the hospitality and tourism industries once again to thrive. Our plan to revitalise Britain’s tourism and hospitality industries is clear, so in advance of the spring Budget, I would be grateful if the Minister explained what representations he or the Government have taken from businesses in coastal communities, and what measures they are considering offering to address the points that hon. Members have set out today.

I am sure that many people across coastal towns will be interested to hear the Minister’s response, but whatever he says, we know that last week’s news about the economy being in recession will further have added to the sense of gloom facing hospitality and tourism in coastal areas, and indeed businesses in every sector in every region and nation of the UK. That is why our plan to get the economy growing is so important, to make sure that the tourism and hospitality industries in our coastal communities can thrive once again.

Draft Social Security (Contributions) (Limits and Thresholds, National Insurance Funds Payments and Extension of Veterans Relief) Regulations 2024 Draft Tax Credits, Child Benefit and Guardian's Allowance Up-rating Regulations 2024

James Murray Excerpts

Wednesday 7th February 2024 General Committees

[James Murray (Ealing North) (Lab/Co-op)]

It is a pleasure to serve on the Committee with you, Sir Charles. I welcome the opportunity to address, on behalf of the Opposition, the measures laid out in the two statutory instruments.

First, as we heard from the Minister, the draft Social Security (Contributions) (Limits and Thresholds, National Insurance Funds Payments and Extension of Veterans Relief) Regulations 2024 give effect to the annual re-rating of national insurance contributions limits and thresholds for the purposes of calculating class 1 NICs liability for the coming tax year. As we also heard, the regulations allow for payments of a Treasury grant not exceeding 5% of the estimated benefit expenditure for 2024-25 to be made into the national insurance fund, while also making provision for Northern Ireland. Finally, the regulations extend the availability of the zero-rate relief on secondary class 1 contributions for employers of veterans for the tax year 2024-25.

Members will recall that at the autumn statement 2022 the Chancellor announced, as the Minister said, that national insurance contribution thresholds that are in line with income tax will be fixed at their 2023-24 levels until 2027-28. As the Office for Budget Responsibility pointed out at the time, the freeze to national insurance thresholds and limits meant that

“all the main personal tax thresholds are now frozen in cash terms across our entire forecast period”

through to 2027-28.

The freezes to allowances, limits and thresholds provide the context for why the Chancellor’s boasting about the cut in the rate of national insurance at the autumn statement 2023 rings so hollow. As Paul Johnson from the Institute for Fiscal Studies said, the changes made at the statement

“won’t be enough to prevent this from being the biggest tax-raising parliament in modern times.”

The truth is that after 25 tax rises in this Parliament alone, the tax burden remains on course to be at its highest since the second world war.

One of the central reasons for that is the freeze to income tax and national insurance thresholds through to 2027-28. That fiscal drag means that, on average, personal taxes will go up by £1,200 per household even after the 2% cut to national insurance in January. The Government are, in effect, giving with one hand while taking with the other. Indeed, after the autumn statement the IFS noted that tax reductions announced in November would give back

“less than £1 of every £4 that is being taken away”.

I have heard the Minister say several times in previous debates that Members should compare our December and January pay slips; frankly, I am more concerned about the post-tax income for low and middle earners than I am for MPs. The truth is that even people in this place on very good salaries will see their tax burden rise as a result of the Government’s freezes to thresholds, but the impact on low and middle earners is stark. Does the Minister agree with consumer finance expert Martin Lewis on this? Mr Lewis recently said that even with the reduction in national insurance, people on incomes of between £12,500 to £26,000 will be worse off, looking at this year in isolation, as a result of threshold freezes and fiscal drag. Does the Minister agree with that or does he think Mr Lewis is mistaken?

On a point of clarification, I understand that last year, through the Social Security (Contributions) (Rates, Limits and Thresholds Amendments and National Insurance Funds Payments) Regulations 2023, the Government made provisions for classes 2, 3 and 4 national insurance contributions. Will the Minister explain the procedural reasoning for why such provision has been omitted from this year’s regulations?

Secondly, the draft Tax Credits, Child Benefit and Guardian’s Allowance Up-rating Regulations 2024 set the annual rates of working tax credit and child tax credit and the weekly rates of child benefit and guardian’s allowance for the coming financial year. Amid a damaging cost of living crisis, we support the increases, as any help for people who are struggling in the face of persistently high energy, food and housing costs is particularly needed at this time. We know that 8 million households received their final means-tested cost of living payment this week. That support has been critical for millions across this country, including many children. I know from my constituency that many people continue to struggle to provide for themselves and their families. I would therefore be grateful if the Minister could share with us his assessment of the impact of the end of the cost of living payment on levels of child poverty.

Oral Answers to Questions

James Murray Excerpts

Tuesday 6th February 2024 Commons Chamber

[Nigel Huddleston]

I hear the House’s concern about this issue, on which we had a debate not so long ago. Of course, the suicides the hon. Gentleman mentions concern us, and independent reviews have taken place. However, I want to provide the House and anybody listening with reassurance that the best thing to do if people have concerns is to engage with HMRC, because very generous and long-term plans can be put in place to help people to repay. As I said, there are fears out there—there is a bit of scaremongering—that homes are being taken over or people are having to give up pensions. That is not the case. Engagement with HMRC to establish reasonable time to pay would therefore be reassuring for many of the people who fear much worse consequences. My appeal is to engage with HMRC.

[James Murray (Ealing North) (Lab/Co-op)]

The Government’s approach to the loan charge has become a nightmare for ordinary people across the country who are the victims of mis-selling and facing financial ruin. The torment and devastating reality is the clearest possible proof that the Government need to think again. Those facing the loan charge ordeal cannot bear to hear yet again that the Morse review is the final word on this matter. Will the Minister finally agree today to commission a new, truly independent review?

[Nigel Huddleston]

We had an independent review in 2019 under Lord Morse. The Government accepted 19 of its 20 recommendations. The review has taken place, but as I have said repeatedly, I am challenging HMRC and listening to colleagues. If action needs to be taken, I will take it, but I do not believe that there is a case for another review, because we have already had one, and the Government have already taken action.

Finance Bill

James Murray Excerpts

Report stage
Monday 5th February 2024 Commons Chamber

I have outlined the case for each of the Government amendments, and I therefore urge the House to accept them.

[James Murray (Ealing North) (Lab/Co-op)]

In speaking to new clause 6, which relates to permanent full expensing, I remind the House of the context in which this Finance Bill was published. It followed the Chancellor’s statement on 22 November last year, in which he claimed that he was delivering an “autumn statement for growth”. Members will remember, however, that the same day, the Office for Budget Responsibility confirmed that growth forecasts had been cut by more than half for the coming year, cut again for the year after that, and cut yet again for the year after that. Independent analysts confirmed that even after all the changes that the Government had announced, personal taxes would still rise. They are set to rise by £1,200 per household by 2028-29, with the tax burden on track to be the highest since the second world war.

That was the context in which this Bill was published: flatlining wages, higher taxes, higher mortgage payments and worsening public services—all the product of 14 years of Conservative economic failure. Our country needs change. A critical part of making that change will be to get our country’s growth rate up. We need a plan for growth, to make people across Britain better off, and to ensure sustainable funding for our public services. Labour has been developing our plan for growth by working hand in hand with businesses across the country and across the economy.

We know how highly businesses that are considering investing in the UK rate stability, predictability and a long-term plan. For that reason, we welcome the fact that, as our new clause 6 highlights, the Bill makes full expensing permanent. Permanent full expensing is something we have long called for, as a policy that can support greater business investment and economic growth. Because Labour knows how important stability and predictability are to businesses, the shadow Chancellor, my right hon. Friend the Member for Leeds West (Rachel Reeves), announced last week that Labour is committed to maintaining permanent full expensing in the UK tax system, as well as the annual investment allowance, if we win the next general election. The shadow Chancellor has made this commitment to offer businesses certainty for the years ahead. Businesses considering plant and machinery investment across Britain can be confident that the tax treatment of that investment would not change with a Labour Government.

Of course, there is still a general election to face, so I use this opportunity to invite the Minister to put on the record whether the Conservatives will follow our lead by confirming that should they win the general election, they will maintain permanent full expensing. I am sure many businesses would welcome the certainty that would come from knowing both the main parties are going into the election fully committed to keeping permanent full expensing. I urge the Minister, when he responds, to confirm whether that will be his party’s policy going into the general election.

After all the chopping and changing we have seen in capital allowances in recent years, the Minister needs to make the commitment explicit. As I mentioned during earlier stages of the Bill, the annual investment allowance had been temporarily raised to £1 million when this Parliament began; that temporary basis was extended by the Finance Act 2021, again by the Finance Act 2022, and then made permanent by the Finance (No. 2) Act 2023. Meanwhile, over the course of this Parliament, the super-deduction came and went. Last year, full expensing for expenditure on plant and machinery was introduced on a temporary basis for three years. In this Bill, the Government are finally making it permanent. After so much instability, a commitment from Treasury Ministers at the Dispatch Box that the Conservatives, like Labour, will commit to maintaining permanent full expensing feels like the least they can do.

Our new clause 6 would require the Chancellor to publish not only an assessment of the impact of permanent full expensing, but a consideration of what other policies would support its effectiveness. We believe this is important to ensure that business investment is supported as much as possible. The Opposition have begun to set out what some of our policies would be if we won the next general election. As the shadow Chancellor has set out, if we were in government, we would consider the outcome of technical consultations on whether leased assets can be included in full expensing and on simplifying the UK’s capital allowance regime. I would be grateful if the Minister updated us on the progress of those consultations.

Last week, the shadow Chancellor also made clear the commitment that if Labour wins the next general election, we will ask HMRC to produce simple and comprehensive guidance making clear which assets are eligible for each type of capital allowance. That guidance would give businesses clarity over how their investments will be treated, and businesses will be able to use it as a single point of reference when making investment decisions. Will the Minister confirm whether the Government have considered taking such steps, or making such a commitment?

To give further certainty, the Shadow Chancellor has also said that in government, Labour would explore the greater use of rulings and clearances. Under such an approach, businesses would be able to get a written ruling from HMRC about the tax treatment of potential investments, making clear, for instance, whether they qualify for full expensing or other capital allowances. We know that businesses benefit from other countries’ tax administrators being able to provide such rulings and clearances. As certainty is crucial to encourage investment in Britain, I would be grateful if the Minister confirmed whether the Treasury has asked HMRC to consider the greater use of rulings and clearances for investment, and, if so, what its conclusion has been.

Of course, any policies on expensing or other capital allowances sit under the headline rate of corporation tax. It is hard to conclude anything other than that the Conservative party is rather unclear and confused about its approach to corporation tax rates in the UK. For evidence of that, we need look no further than the current Chancellor: in July 2022, during his leadership bid, he pledged to cut the headline rate of corporation tax from 19% to 15%, yet when he became Chancellor just three months later, one of his first acts was to promise to raise the tax instead from 19% to 25%. It is no wonder that businesses, and indeed Conservative Back Benchers, find it so hard to understand the Conservatives’ policy on corporation tax rates.

Let me be clear about the certainty we would offer if we won the next general election. As the shadow Chancellor has set out, we believe the current rate of 25% strikes the right balance between what our public finances need and, as the lowest rate in the G7, keeping our corporation tax competitive in the global economy. That is why we are pledging to cap the headline rate of corporation tax at its current rate of 25% for the whole of the next Parliament. We would take action if tax changes in other advanced economies threaten to undermine UK competitiveness. That choice provides predictability and has a clear rationale. That is the pro-business choice and the pro-growth choice. The promise to cap corporation tax at 25% is clear from us. Again, to offer businesses as much certainty as possible, will the Conservatives follow our lead and also pledge, today, to cap corporation tax at 25% for the next Parliament?

These commitments—to cap corporation tax, to maintain permanent full expensing and to keep the annual investment allowance—will all form part of the road map that we would publish in the first six months of a Labour Government, setting out our tax plans for businesses for the whole of that Parliament. That would put stability, predictability and a long-term plan at the heart of our approach. To give businesses as much certainty as possible, I would be grateful if the Minister confirmed whether a corporation tax cap at 25% and keeping full expensing in place will be in the Conservative party manifesto too.

[Richard Fuller (North East Bedfordshire) (Con)]

I was interested in what the shadow Minister was saying about what would happen if other countries changed their corporation tax. As he will know, Mr Trump, the former President, has said that he would cut US corporation tax, potentially from 21% to 15%. Given such examples, does the hon. Gentleman anticipate that a Labour Government would look to cut the headline rate of corporation tax, as we would be looking at a significant tax cut by the world’s largest economy?

[James Murray]

I thank the hon. Gentleman for his intervention. As we have made clear, we would take action if tax changes in other advanced economies threatened to undermine UK competitiveness, but the headline commitment from us is to cap corporation tax at 25% for the duration of the next Parliament. I recall that in earlier consideration in this debate, he and I had an exchange about permanent full expensing, so I hope he will welcome our commitment to maintaining permanent full expensing if we are in government. Perhaps he will put pressure on his Front-Bench colleagues to join us today in making that a cross-party commitment from the House.

New clause 7 focuses on the multipliers used to calculate higher rates of air passenger duty. As we have discussed at earlier stages of the consideration of this Bill, clause 24 makes no changes to band A rates, while in band B, the reduced, standard and higher rates will increase by £1, £3 and £7 respectively. In band C, the reduced, standard and higher rates will rise by £1, £2 and £6 respectively. In each of those three bands, which cover international travel to a range of destinations, a simple principle is followed: if the duty for passengers on economy flights goes up, the duty for those flying business class and by private jet goes up too. In the domestic band, however, which covers flights within the UK, that simple principle of fairness does not apply. Instead, under the Bill, for domestic UK flights, the reduced rate of APD rises by 50p and the standard rate rises by £1, yet the higher rate is unchanged. Let me be clear what this means in plain English: from 1 April, passengers flying economy and business class within the UK will see their taxes rise, whereas passengers taking exactly the same flights by private jet will enjoy a tax freeze. Although the changes kick in on 1 April, this is no April fools’ day joke, although the Prime Minister may be laughing; it is the result of a hidden loophole that that the Conservatives have introduced. We discussed this matter in Committee, when the Exchequer Secretary tried to provide an explanation for this unfairness. He said that APD rates are

“uprated by a forecast of RPI and those rates are then rounded to the nearest pound.”

As for the different rates I highlighted in Committee, he said:

“It largely depends on how they”—

the rates—

are rounded to the nearest pound; the actual rate is determined by whether the figure is rounded down or up.”––[Official Report, Finance Public Bill Committee, 16 January 2024; c. 34-35.]

I know that the Exchequer Secretary always tries to give me a straight answer—let me put it on the record that I genuinely appreciate his efforts to do so—but I fear that his explanation in Committee may have been unintentionally misleading or, at the very least, only partial. Since that Committee stage, the House of Commons Library has given me information confirming that it does not tell the full picture to say that the duty rates are, as the Minister claimed,

“uprated by a forecast of RPI and those rates are then rounded to the nearest pound.”––[Official Report, Finance Public Bill Committee, 16 January 2024; c. 34.]

In fact, my understanding is that the Minister’s statement applied only to the reduced rates of air passenger duty. Those are indeed adjusted each year in line with forecast RPI and rounded to the nearest pound. However, the standard and higher rates are not calculated by separate reference to RPI; rather, they are generally set as multipliers of their respective reduced rates. For instance, the standard and higher rates in band B are set as 2.2 and 6.6 times the band B reduced rate respectively, rounded in both cases to the nearest pound.

--- Later in debate ---

[James Murray]

I begin by wishing His Majesty the King the very best for a speedy recovery. My colleagues and I are thinking of him and the royal family at this time, and we wish him a swift return to full health.

Throughout consideration of the Bill, the Opposition have made it clear that it contains a number of measures for which we have been calling for some time. For instance, we welcome the Government finally making full expensing permanent after so many years of chopping and changing capital allowances; we have made it clear that we will maintain that policy if we win power this year. We have also made it clear that we will maintain the system of R&D tax credits introduced by the Bill—again, after so many years of this Government chopping and changing the design of the scheme. In both cases, that is because we prize stability and predictability for businesses; they have made it clear to us that they value that greatly.

We know that providing certainty is a critical factor in boosting business investment and economic growth. If Labour won the next general election, we would put that certainty and stability at the heart of our approach in government by publishing a road map in the first six months, setting out our business tax plans for the whole Parliament. We have set out our approach to full expensing and to corporation tax, so I am disappointed that the Minister was not able to give us a clear guarantee that the Conservatives will maintain full permanent expensing and cap corporation tax at 25% for the whole of the next Parliament. Businesses can have confidence, however, that both of those commitments are locked in with Labour.

Of course, there are provisions in the Bill of which we have been critical, not least the fact that it freezes tax for passengers flying around the UK on private jets, while hiking taxes for everyone else who is flying economy or business class. Also, the Government admit that some provisions will need to be returned to and corrected. That is a far from ideal position to be in before a Bill has even become law. We know this is the case because, towards the end of last month, HMRC admitted that the way in which the Government have legislated to remove the lifetime allowance has

“created unintended consequences for members with multiple pension schemes”.

HMRC says that further legislation will be necessary to fix three areas in schedule 9 relating to the abolition of the lifetime allowance. That clearly indicates rushed legislation that runs the risk of creating problems for all involved. The legal firm Wedlake Bell, for instance, has said:

“The proposed new tax regime replacing the LTA at breakneck speed from 6 April 2024 is very risky for all parties including trustees, administrators, members and indeed HMRC itself.”

More widely, our concern with this Bill, as with the autumn statement it followed, is that the Conservatives cannot hide or move on from their 14 years of economic failure. Those 14 years of failure have left economic growth languishing and people across Britain worse off. Last November’s autumn statement for growth was the 11th attempt at an economic growth plan from the Conservatives. The truth is that the Conservatives are incapable of getting our country back on track. We need a general election so that Labour can offer the change and the plan that families and businesses across Britain need.

[Mr Deputy Speaker (Mr Nigel Evans)]

I call the Chair of the Treasury Committee.

Hospitality Sector: Fiscal Support

James Murray Excerpts

Wednesday 31st January 2024 Westminster Hall

[James Murray (Ealing North) (Lab/Co-op)]

It is a pleasure to speak in this debate with you in Chair, Ms Bardell. I begin by congratulating the hon. Member for Stirling (Alyn Smith) on securing this debate on fiscal support for the hospitality sector. I am pleased to be able to respond on behalf of the Opposition. We have heard Members from across the House speaking passionately about the importance of the hospitality sector, in the jobs it brings to local economies, the vitality it brings to our high streets and the enjoyment it brings to all our lives. My hon. Friend the Member for York Central (Rachael Maskell) in particular spoke about the importance of Government policy to the many hospitality venues in her constituency. Not only does the sector provide 3% of the UK’s economic output and billions in tax revenues for the Treasury; it is a central part of our social lives. That is why our constituents value the hospitality sector so greatly and are so keen to support it.

This debate has been an opportunity not only to speak about the policy but to recognise the sector’s central role in British life, including the way that it underpins high streets as places that communities take pride in. Because of time constraints, I will resist the temptation to mention all the cafés, pubs and other venues in my constituency, although I congratulate other Members on their valiant efforts to do so— I particularly commend the hon. Member for Totnes (Anthony Mangnall) for getting so many references into his speech.

In my constituency of Ealing North, it is hard to imagine Pitshanger Lane without Cinnamon café, where I first went with my grandparents many years ago. I thank the café for its excellent coffee and sandwiches, which keep me sustained and happy whenever I pop in as a customer. A few hundred yards away is the Duke of Kent, which is a gem of a pub that I am glad to be able to enjoy, but a couple of miles away is one of my favourite pubs, the Black Horse, which sadly closed just over a year ago. It is such a deep shame to see it boarded up whenever I walk or drive past. It is a sad reminder of the struggle that many hospitality venues face and of the real loss that local communities can feel when they close.

Our analysis shows that we have lost over 6,000 pubs from our high streets since 2010. Many hospitality venues are finding it harder and harder to succeed, because of high inflation, staff shortages, rising rents and the burden of business rates. At the same time, their customers have less money to spend on enjoying what pubs, cafés and restaurants have to offer, because their wages have flatlined, while taxes and the cost of living climb relentlessly.

Many hospitality businesses may have been hopeful when they heard about the Government’s 2019 manifesto promise of a fundamental review of the business rates system. However, the fundamental review never materialised, and trade groups representing businesses on the high street have expressed their disappointment. In March last year, the Federation of Small Businesses stated that

“the 2019 Manifesto commitment to hold a fundamental downward review of business rates has not happened…these changes do not amount to the fundamental overhaul the system needs”.

Meanwhile, the British Retail Consortium said that the Government’s rates review report

“falls far short of the truly fundamental reform that is needed and was promised in the government’s 2019 manifesto.”

In the absence of fundamental action from this Government, Labour is committed to scrapping the current system of business rates and replacing it with a new approach that is fit for the current economy. As the shadow Chancellor, my right hon. Friend the Member for Leeds West (Rachel Reeves), has set out, if Labour were in government, we would scrap and replace business rates, and shift the burden away from hospitality and retail businesses on the high street, which continue to shoulder a heavy burden compared with those that operate primarily in the digital economy. Our new system would incentivise investment, promote entrepreneurship and reward businesses that move into empty premises. It would help the hospitality sector to thrive once again. Our plans for business rates form just one part of our five-point plan to reverse years of decline and revitalise local high streets, alongside our commitments to stem rampant energy bills, stamp out late payments, revamp empty shops and tackle antisocial behaviour.

Before the next general election, we expect another Budget, so I would be grateful if the Minister explained what representations he has had from the hospitality sector ahead of the Budget in March and what proposals he is considering to support hospitality this year. I am sure that many businesses will be interested in the Minister’s response. In this year’s general election, the Opposition will offer the change that businesses need: a Government that are ready to work hand in hand with businesses, get the economy growing and do everything we can to support the hospitality sector to thrive.

Draft Local Government Finance Act 1988 (Prescription of Non-Domestic Rating Multipliers) (England) Regulations 2023

James Murray Excerpts

Wednesday 24th January 2024 General Committees

[James Murray (Ealing North) (Lab/Co-op)]

It is a pleasure to serve on this Committee with you in the Chair, Mrs Murray. I welcome the opportunity to address the draft regulations on behalf of the Opposition.

As we know, business rates are determined according to the formulas defined in the Local Government Finance Act 1988. The rates are calculated as the product of the property’s rateable value, as determined by the independent Valuation Office Agency, and the relevant multiplier. As we heard from the Minister, this statutory instrument continues the existing policy under which the majority of occupied properties with a rateable value below £51,000 pay rates calculated by reference to the small business multiplier, and extends it by making charities and unoccupied properties eligible for the small business multiplier too.

Specifically, as the Minister set out, the statutory instrument seeks to do three things: first, to maintain the threshold for the small business multiplier to be applied at below £51,000 of rateable value, which, as the Minister notes, has been Government policy since 2017; secondly, to give effect to the announcement that charities and unoccupied properties will be eligible for the small business multiplier; and thirdly, to implement the Government’s decision to extend the small business multiplier to central list properties below the £51,000 rateable value threshold, of which we understand there are seven.

We will not oppose this statutory instrument. However, I would be grateful if, when the Minister responds, he could provide further detail about his and the Government’s understanding of what constitutes an unoccupied property. As he will know, the Government consulted on business rates avoidance and evasion in July last year. In the consultation document, the Government made it clear that Ministers were concerned about potential abuse of empty property relief by owners who use a brief period of apparent occupation to reset their property’s eligibility for that relief. The consultation document that I am referring to made clear that,

“There is no statutory definition of what constitutes ‘occupation’ of a property, and minimal occupation possibly of no material benefit to the occupier, except as a method to avoid paying rates, may be sufficient to allow ratepayers access to a further rate-free period.”

As there is no statutory definition of what constitutes occupation of a property, I would be grateful if the Minister could explain to the Committee what definition the Government are using to identify unoccupied properties for the purposes of this SI.

I would also be grateful if the Minister would confirm when the Government intend to set out their response to the business rates avoidance and evasion consultation, and when they plan to bring forward any actions they intend to take to combat avoidance and evasion in the business rates system.

Inheritance Tax

James Murray Excerpts

Wednesday 17th January 2024 Westminster Hall

[James Murray (Ealing North) (Lab/Co-op)]

It is a pleasure to speak in this debate with you as the Chair, Sir Robert.

I begin by congratulating my hon. Friend the Member for Hemsworth (Jon Trickett) on securing this debate. I am pleased to respond to it on behalf of the Opposition, following the contributions of Members from right across the House, including those of my hon. Friends the Members for Easington (Grahame Morris), for Wansbeck (Ian Lavery) and for Coventry South (Zarah Sultana).

Any debate about tax in this country must begin by recognising that under the Conservatives the tax burden is set to be the highest since the second world war. We have seen 25 tax rises in this Parliament alone and the decisions taken by this Government will leave the average family £1,200 worse off. No wonder the Prime Minister and the Chancellor are feeling pressure to cut taxes. However, the problem for them is that the average family will still be £1,200 worse off even after the recent national insurance cuts. Indeed, the Conservatives have put up taxes so much that there is now nothing they can do to repair the damage they have done to the economy and to family finances.

The truth is that the personal tax rises introduced by this Government will far outweigh any relief arising from their recent change to national insurance. Even taking this year in isolation, many of those on lower incomes will see their taxes rise. Consequently, with a general election approaching, we can expect the Conservatives to get more and more desperate, and—frankly—more and more reckless, in what they are prepared to throw at holding on to power. The Opposition will always stand with working people; that is why we have made it clear that we want the tax burden on working people to come down. We are also always clear that, unlike what we have seen from the Conservatives during this Parliament, we will always set out exactly how we would pay for any tax cuts.

As the 6 March Budget approaches, we are again beginning to hear rumours that the Prime Minister and Chancellor are considering abolishing inheritance tax, as they feel growing pressure to assuage their Back Benchers and members. All parents have a natural desire to pass on to their children what they have worked hard for in life, but the truth is that an inheritance tax cut would benefit only the top few per cent. of estates. In the middle of a cost of living crisis, when families across Britain are struggling and our public services are on their knees, that cannot be the right priority.

According to figures from HMRC, in 2020-21 only 3.7% of estates paid inheritance tax, while the Institute for Fiscal Studies suggests that the cost of abolishing the tax would be £7 billion. The IFS also notes that about half the benefit of abolishing inheritance tax would go to those with estates of £2.1 million or more, who make up the top 1% of estates and would benefit by £1.1 million on average. Given the state of public finances and services, that simply cannot be justified as a priority when taxes for working people are already so high and set to keep rising.

[Peter Gibson]

I am very interested to hear what the hon. Gentleman has to say about hard-working families. Will he outline how much those hard-working families would be hit by his party’s plans to borrow an extra £28 billion each and every year?

[James Murray]

I thank the hon. Member for his intervention, but, as we have set out, all our plans are within our fiscal rules. Frankly, that was the hon. Member’s attempt to distract from the fact that he is a member of a party presiding over a Parliament that has put up taxes 25 times and is on track to have the highest tax burden since the second world war. There is simply no getting away from that record and from the burden that his party has increased on working people during this Parliament.

[Peter Gibson]

I am grateful to the hon. Gentleman for giving way again; he is being incredibly generous with his time. I am incredibly proud of my party and the track record of what it has delivered for our country over the past few years: the incredible support given throughout covid and to working families up and down the country through the cost of living crisis.

[James Murray]

Frankly, I think that an increasing number of people across Britain would disagree. The one question that they are going to be asking themselves as we approach the next general election is: am I and my family any better off than we were 14 years ago? Is anything working better or in a better state in this country than it was 14 years ago? The answer to that question is a resounding no.

[Peter Gibson]

rose—

[James Murray]

I see the hon. Gentleman gesturing, but I have given way twice; I am going to make a bit of progress before taking any more interventions.

We are not concerned just that inheritance tax would be the wrong priority; we are also concerned about the damage that the Government might do to our economy if the tax cut were unfunded. People across Britain will remember the chaos unleashed by the disastrous mini Budget, when the previous Prime Minister and Chancellor promised irresponsible unfunded tax cuts for the wealthiest. I ask the Minister: how would the Government pay for the £7 billion abolition of inheritance tax that it appears they are briefing the media about?

Which of our public services would see their funding reduced? What other taxes would the Government expect to increase? What investment in our future would they plan to cut and how much more do they want to push up debt? I would welcome it if the Minister were upfront about what the Government are considering. If they are not considering abolishing inheritance tax, they should say so now.

Perhaps, though, it is unfair to ask the Minister to be clear about what the Government are thinking, as the Prime Minister and Chancellor may, in all honesty, not know what to do. The Conservatives need to call an election in the next 12 months and they know that they are out of options when it comes to what to say. After 14 years of Conservative government, public services have been run into the ground, the economy has stagnated and the tax burden is set to be at its highest in generations. Yet what we hear from their briefings to the media is speculation that they want to cut inheritance tax—something that would benefit the top 4%, while taxes on working people keep rising. That is the wrong priority when both public and household finances are so stretched.

What the country needs is a Labour Government with fiscal responsibility at their heart and a plan to reform public services while growing the economy. That is the way to make people across Britain better off.

Finance Bill

James Murray Excerpts

Committee of the whole House
Wednesday 10th January 2024 Commons Chamber

[Nigel Huddleston]

I agree that certainty for business is pivotal, but with both full expensing and R&D the Government, the Chancellor and others have been indicating the direction of travel for some time and therefore giving increased certainty. As I have said, it was mentioned a while ago that we intended to pursue the policy of full expensing when the economic circumstances allowed, and now they do. R&D, which I will come to in a minute, has been discussed for quite a long time and is the result of extensive co-operation with industry.

It is also the reality, though, that Government policy needs to change in response to the nature of a changing economy and to things such as digital, the cloud and so on. When it comes to other investments, we need to make sure that new and emerging policy areas are covered as well. We have seen today, as we saw in the autumn statement, a very clear direction of travel from the Conservative side of the Chamber, which is about incentivising businesses and cutting taxes. Permanent full expensing also simplifies the capital allowances regime overall, as companies can claim the full cost in year one, reducing the need to claim writing-down allowances year on year.

Turning to clause 2 and schedule 1, the Government have also announced the closure of the R&D tax relief review launched in 2021—the point I was just making to the hon. Member for Reading East (Matt Rodda)—alongside a set of changes to simplify and improve the system. Clause 2 makes changes to merge the current R&D expenditure credit and SME schemes for expenditure in accounting periods beginning on or after 1 April 2024, simplifying the system and providing greater support for UK companies to drive innovation.

The merged scheme will have an above-the-line mechanism similar to the R&D expenditure credit, with a rate of 20%. That will make the benefit more visible and easier for companies to factor into their investment decisions. Additionally, small and medium enterprise lossmakers will now be able to carry forward their losses rather than having to surrender them, which will give a total benefit of up to £45 per £100 of R&D expenditure.

There will also be a reduction in the rate at which the merged scheme credit is taxed for lossmakers, from 25% to 19%. That is worth around £120 million per annum to non-intensive lossmakers and will increase the up-front cash benefit for lossmakers. Subcontracting rules in the merged scheme will allow the company taking the decision to do R&D to claim relief on contracted-out R&D. That approach is based on the current SME scheme, which was identified as the best option in the consultation we delivered, and has been refined further following engagement with industry last summer.

Subsidy rules will also be removed, allowing SMEs to claim relief for work for which they receive a grant of a subsidy. This represents an increase in generosity for SMEs as well as being a major tax simplification.

The Government are also legislating for enhanced support for loss-making R&D-intensive SMEs. That was announced at spring Budget 2023 and will benefit 23,000 SMEs a year by providing further support to the most R&D-intensive SMEs while merging the current schemes. The Government are promoting the conditions for enterprise to succeed. Companies claiming the existing SME tax relief will be eligible for a higher payable credit rate of 14.5% if they meet the definition for R&D intensity.

At the summer statement, the Government announced several improvements being made to that enhanced support. The R&D intensity threshold is being lowered to 30% from 40% from April 2024, meaning that around 5,000 more companies will benefit from the support. A one-year grace period is being introduced, providing greater certainty by ensuring that companies that dip under the 30% threshold will continue receiving relief for one year. The same subcontracting rules as the merged scheme will apply to this enhanced support, further helping to simplify the system with one set of rules that both SMEs and larger companies will follow.

Overall, R&D reliefs will support an estimated £55 billion of business R&D expenditure in 2028-29—a 25% increase from £44 billion in 2021-22. Expenditure on R&D reliefs is forecast to increase in every year of the scorecard period. We will also restrict nominations and assignments for R&D relief payment. That measure ensures that genuine businesses get the payment for their R&D claim directly, rather than receiving it through an agent, and is designed to benefit genuine claimants and reduce non-compliance.

Subject to limited exceptions, no R&D tax credit payments will be made to nominee bank accounts, and any R&D tax credit payments must be paid directly to the company that claims for the R&D, so claimants will now receive their payments directly, giving them more control. That will ensure that the person claiming the relief has better oversight of the claim and receives the money into their account quicker. Claimants will also be clearer on exactly how much money is being charged by their agents, rather than just receiving a net amount after fees have been deducted. That builds on previously announced measures and policy changes to help to ensure greater company control over R&D claims.

The Government are committed to making the UK the best place in the world to do business. Full expensing and R&D tax relief support businesses to grow and invest, which will boost productivity and economic growth. That remains the key way to raise everybody’s living standards and to fund high-quality public services throughout the UK. I commend clauses 1 and 2 and schedule 1 to the Committee.

[James Murray (Ealing North) (Lab/Co-op)]

Let me start by briefly considering the context in which we are debating clauses 1 and 2. As we know, the Bill follows the Chancellor’s statement on 22 November last year, in which he claimed that he was delivering an “autumn statement for growth”. As the Committee may remember, the Office for Budget Responsibility confirmed on the same day that growth forecasts had been cut by more than half for the coming year, cut again for the year after that, and cut yet again for the year after that. Independent analysts confirmed that, even after all the changes the Government had announced, personal taxes would still rise. In fact, personal taxes are now set to rise by £1,200 per household by 2028-29, with the tax burden on track to be the highest since the second world war. Despite people across the country paying so much in tax, public services are collapsing, the NHS is on its knees, and more and more families are struggling to make ends meet.

That was the context in which we considered the Bill on Second Reading just before Christmas: 13 years of Conservative economic failure had left people across Britain worse off. The only thing to have changed since then is that we now face 14 years of Conservative economic failure. It may be a new year, but those in the governing party face the same cold truth: nothing they can say or do now can repair the damage that they have done to our economy.

People in businesses across Britain deserve so much better. As a foundation of better management of the economy, our country needs and deserves stability, certainty and a long-term plan. It is for that reason that, although we welcome the fact that clause 1 makes full expensing permanent, which we have long called for, it simply cannot make up for the years of uncertainty that businesses have faced. Businesses need stability and predictability to help them plan for growth, and their long-term planning has been held back because the Government have been chopping and changing business taxes and reliefs year after year, with no evidence of anything resembling a long-term strategy.

[Richard Fuller]

I was very pleased to hear the shadow Minister say that the Opposition welcome the full expensing. That helps, but maybe he can go further to clarify. In new clause 6, tabled in his name, the Opposition are calling for a review of all business taxes and reliefs, which would include full expensing. He will know, as will the hon. Member for Mid Bedfordshire (Alistair Strathern) who is sitting behind him, that there is a particular potential investment decision in our county. Will the shadow Minister make it explicit that the Labour party’s intention is to include in its manifesto for the next election a commitment to maintaining full expensing?

[James Murray]

As I have said, we have long been calling for full expensing, and we welcome the fact that it is being made permanent. I do not mean to sound jokey in my response—I am deadly serious when I say this—but if the hon. Gentleman wants to know what a Labour Government would do if we got into office, there is one way to see that eventuality come about: we could have a general election sooner rather than later, instead of dragging things on throughout the course of 2024.

Frankly, the country needs to move on from the current Government. Just look at their record on capital allowances since the last general election. The hon. Member for North East Bedfordshire (Richard Fuller) spoke about certainty and the need for stability, but let us look at the changes that have happened to capital allowances over the past four or five years. As I mentioned on Second Reading, back at the beginning of this Parliament, the annual investment had been raised to £1 million on a temporary basis. That temporary basis was extended by the Finance Act 2021, extended again by the Finance Act 2022, and then made permanent by the Finance (No. 2) Act 2023. Meanwhile, over the course of this Parliament, the super-deduction came and went entirely. Last year, full expensing for expenditure on plant or machinery was introduced but only on a temporary basis for three years.

Now, of course, Treasury Ministers are amending what their predecessors announced last year by making full expensing permanent. Although we welcome that policy, I wonder how long it will last. Frankly, I wonder how long any policy can be expected to last under this Government, when they are led—in the loosest possible sense of that word—by such a weak Prime Minister. If we accept clause 1 at face value, we welcome its principle of making full expensing permanent, as that is something that we have long called for. I will focus the rest of my questions on some of the specifics of the Government’s approach.

As ever, I am grateful to the excellent team at the Chartered Institute of Taxation for all their thoughts on the detail of what the Government have proposed in this clause and others. I know that one matter of interest to the chartered institute was the fact that, at the autumn statement, the Government said that they would publish a technical consultation on leased assets. I would be grateful if the Minister told us when that will be published.

Furthermore, both the Chartered Institute of Taxation and the Association of Taxation Technicians—to which I am also grateful for its thoughts on the detail of the Bill—have queried which companies and assets are eligible for full expensing. I would be grateful if the Minister clarified which assets are outside the scope of full expensing, and whether the Treasury will publish a detailed list of what does and does not count as plant and machinery. I would also be grateful if he told us how many firms will not be eligible for full expensing because they are partnerships. I know that many who take an interest in this matter would welcome clarity on that.

In clause 2, the Government propose changes to the system of tax credits for research and development. As with their approach to business taxation and capital allowances, the Government have failed to deliver any sense of stability when it comes to R&D tax credits, despite certainty and predictability being so crucial to businesses that are making investment decisions. That much is clear when looking at the list of changes that we have debated in Finance Bills over the course of the current Parliament alone: the Finance Act 2020 changed the rate of R&D expenditure credit; the Finance Act 2021 changed how much R&D tax relief small and medium-sized enterprises could claim; the Finance Act 2023 again changed the rates of R&D tax relief; the Finance (No. 2) Act 2023 changed further how the relief operates; and now, the Finance Bill before us changes the system of reliefs yet again. We accept, of course, that some change is necessary and important to enable legislation to function well, but that does not seem to be what we have seen. What we have seen is a Government incapable of providing stability, predictability, and the long-term plan that businesses need to invest and grow. It is clear that after 14 years in office, the Conservatives are incapable of providing that crucial foundation for our economic success.

[Matt Rodda]

My hon. Friend is making an excellent point, which comes to the nub of the argument: the Government are not capable of providing business with the certainty it needs. That is such a tragedy, because so many wonderful emerging industries in the UK which have incredible potential need that certainty, as indeed do other businesses.

[James Murray]

My hon. Friend is absolutely right. So many businesses in the UK that are keen to invest, grow, and make people across Britain better off are being held back by the lack of stability and certainty from this Government. I cannot help but notice that the Government recognise the symptoms of the problem—that a lack of stability and certainty is indeed a problem for economic growth—but they are simply unable to provide a response to that problem, and provide the long-term plan that Britain so desperately needs.

We know that so much chopping and changing without any clear long-term plan has had a cost for our economy, by undermining prospects for investment, innovation and growth. Indeed, the Institute of Chartered Accountants in England and Wales has shared with us the view of its members that there is a lack of confidence when claiming R&D tax relief within the UK, and their belief that

“this has arisen due to the various changes made to the rules in quick succession over the past few years.”

We also know, of course, that having so many changes one after the other has a direct impact on taxpayers as well as businesses, as the public finances bear the costs for all the impacts on His Majesty’s Revenue and Customs in terms of IT systems and staffing. Our analysis of HMRC policy papers suggests that the changes made and proposed within the current Parliament have had a cumulative impact on operational costs for HMRC of more than £60 million. That sum is likely to include a substantial waste of taxpayer money as a result of so many piecemeal changes rather than coherent and lasting reform.

In order to be clear and transparent on the costs of all the Government changes to R&D tax credits, we have tabled new clause 1. The new clause would require the Chancellor to publish a review setting out the total implementation costs of all changes to research and development reliefs in the current Parliament. I hope Ministers will accept that straightforward new clause, but if not, I look forward to Government Members who would be interested in such transparency joining us in supporting it. Furthermore, if Ministers are not prepared to vote for the new clause or accept it, I would be grateful if they could at least commit to writing to me with the figures that our new clause requests.

Turning to the substantive impacts of clause 2, we should be clear about what the clause does. In the autumn statement, the Chancellor said that the Government were

“creating a new, simplified R&D tax relief that combines the existing R&D expenditure credit and small and medium-sized enterprise schemes.”—[Official Report, 22 November 2023; Vol. 741, c. 325.]

We have heard similar words from the Minister in this debate. In reality, though, the Government’s plans still effectively maintain two separate schemes: although they seek to merge the two existing schemes, they continue to provide additional support for R&D-intensive SMEs through the existing SME scheme, rather than its forming part of the new merged scheme. Although we recognise that R&D-intensive SMEs may need extra support, the Chartered Institute of Taxation has pointed out that the Government’s plans are

“less a merger than the shifting of most SMEs into a revised scheme based on an ‘RDEC’ approach, with the SME scheme remaining for a smaller group of R&D intensive SMEs.”

The Association of Taxation Technicians has pointed out the impact this may have, saying that

“the introduction of new rules to define R&D intensive SMEs and the possibility of companies moving in and out of the two regimes as their expenditure profile changes will arguably result in an overall increase in the complexity of the R&D relief regime, rather than simplification.”

As I said, we recognise that R&D-intensive SMEs may need additional support, but I would be grateful if the Minister could explain why the Government have chosen to continue operating a separate scheme to provide that support, rather than delivering it as part of the new merged scheme.

Alongside understanding the Government’s intention regarding the design of the new regime, I would also like to question the Minister about the timescales for implementing the measures in clause 2. In the policy documents associated with the autumn statement, it was clear that the new regime would apply from April 2024 onward. In the Bill, however, schedule 1, which clause 2 introduces, makes clear that the changes will apply from an “appointed day”—a day to be appointed by the Treasury in regulations. I would be grateful if the Minister could confirm in his reply what that appointed day will be. Is it 1 April 2024, or will it be a later date?

As April is less than three months away, if the appointed day does indeed fall within that month, is the Minister confident that that leaves enough time for proper consultation, and for any new systems and processes to be put in place by businesses, agents, software providers and HMRC? If, instead, the appointed day is later than April 2024, those affected need to know what is happening. I hope the Minister will be able to provide clarity on that question today; otherwise, sadly, this seems to be yet another example of continued uncertainty for businesses from this Government.

Finally, we know that the Government are concerned about the level of non-compliance with the R&D tax credit schemes. In their policy paper published in November about the merging of the current schemes, they wrote:

“Further action may be needed to reduce the unacceptably high levels of non-compliance in the R&D reliefs, and HMRC will be publishing a compliance action plan in due course.”

Tackling non-compliance is of course very important, so I would be grateful if the Minister could confirm in his reply when HMRC will be publishing the promised compliance action plan.

I am also very aware from meetings I have had with smaller businesses that they often face a great deal of confusion over the guidelines associated with R&D tax credits. Whereas larger businesses will typically have the resources and institutional capacity to navigate those rules, I am concerned that smaller businesses often do not, and may find themselves having to pay for expensive consultants to help them understand them.

HMRC could have a role to play in supporting small firms with clarity about the guidelines on R&D tax credits, as well as, of course, in its role in tackling genuine fraud. Indeed, the Startup Coalition—an organisation that advocates for policies to support innovative firms in the UK—has highlighted the need for HMRC to improve, and has called for improved

“transparency around adjudicating whether activity is R&D to provide certainty for firms.”

The ICAEW has made similar points, stressing the need for guidance and education and making clear that

“the new rules will significantly affect all sizes of companies including those smaller entities with limited professional tax resource.”

I therefore urge the Minister to make sure that any plan for improving compliance with the rules also focuses on making the rules easier to comply with wherever possible, and on working with small, innovative firms to help give them the certainty they need to thrive.

To conclude, Labour will not be opposing either of the clauses, but I urge Treasury Ministers to accept our new clause 1 and, when they reply, to respond to the specific points that I have raised. More widely, it is clear from their approach to capital allowances and R&D tax reliefs that the Conservatives are incapable of providing stability and a long-term approach. Their failure is letting down businesses across our country who stand ready to play their part in growing the economy and making people across Britain better off.

[Maggie Throup (Erewash) (Con)]

I am delighted to be able to speak in Committee on the Finance Bill, which I believe emphasises the Conservative principles of encouraging entrepreneurs, free enterprise and innovation. Many in this Chamber will know that I do not have a traditional finance background, but I did run my own business for 19 years, which I think qualifies me to identify when fiscal measures are really going to help business. That is what I see in the Bill, especially clauses 1 and 2, which I will speak to today.

First, I will take the opportunity to speak in favour of clause 1, which will support UK business by making full expensing permanent. In the spring Budget 2023, the Chancellor introduced major reforms to the system of capital allowance by replacing the super-deduction system with three years of full expensing. The new measure, which was initially put in place until 1 April 2026, allows companies to claim the full cost of their expenditure on plant or machinery against tax when the business investment is made. That measure was well received by businesses across the UK, as my hon. Friend the Minister has already stated; he quoted a number of large plcs, but the measure has also allowed a number of Erewash-based businesses to benefit and prosper.

Dales Fabrications Ltd previously claimed a super-deduction, the predecessor of full expensing, on a very significant piece of machinery. It sounds quite complicated to me, but it is a 4-metre press break with lots of bespoke options. The benefits of the super-deduction were of such significance that the business purchased additional and highly beneficial tooling concurrently with the machine. The now chairman of the business said to me:

“In reality, we would have inevitably deferred that additional tooling purchase without the super deduction, thus meaning we wouldn’t have had 100 per cent of the benefits of our new machinery from day one and would have been effectively denied access to some types of work that went beyond typical industry-standard sizes.”

The owner of another business, Millitec, said:

“Super deductions are really good and a real incentive for us to invest.”

The successor of the super-deduction, which means being able to expense fully the cost of plant and machinery on a permanent basis, as proposed in clause 1, will undoubtedly continue to be a huge incentive for businesses across the UK to invest in their futures and in UK plc. I know from speaking to my local businesses that they really welcome this, and see it as one way to be able to expand and grow their business. However, I have a question for my hon. Friend the Minister. The terminology of plant and machinery is very broad, so when he responds could he provide some clarity for my Erewash businesses about what is defined as plant and machinery, to help them understand what is in scope? For example, does it extend to IT equipment? I think that having a better understanding of the terminology will really help businesses of all sizes to take full advantage of what is on offer.

The contents of clause 1 shows that the Government are on the side of business. Ahead of the autumn statement last year, 200 businesses—including AstraZeneca, which was so instrumental in the covid vaccine roll- out, and Toyota, a major employer of many of my constituents—wrote a joint letter to my right hon. Friend the Chancellor asking for the 1 April 2026 expiry date to be removed, so making full expensing permanent. Today, by supporting clause 1 and making full expensing permanent, we are backing businesses and helping them to succeed. It also shows that the Government are listening to businesses and making sure they are putting in place measures that will really help them grow their business.

Clause 1 will provide businesses with the biggest tax cut in modern history, worth over £10 billion a year, making the UK capital allowances regime one of the most generous in the world. Since the introduction of temporary full expensing in April 2023, the UK has become an appealing place to invest. The UK has had the second highest investment growth in the G7 and three times that of the US. Making full expensing permanent can only perpetuate that growth. Will my hon. Friend say when he winds up whether plans are in place to extend full expensing to plant and machinery that is either leased or hired? Those two options are often the only affordable ones for businesses with big ambition, but limited capital.

Let me turn to clause 2 and schedule 1. The Bill will simplify research and development rules by merging the small and medium-sized enterprises and the R&D expenditure credit schemes. Whether it is trialling and distributing the successful covid vaccines, which helped us defeat covid-19, or testing and developing new innovations that will enable us to meet our net zero targets, R&D businesses play a vital role in growing our economy. At the spring Budget 2023, my right hon. Friend the Chancellor announced enhanced support for R&D-intensive SMEs worth around £500 million per year, a consultation on the potential merged R&D tax relief scheme and support for those loss-making R&D businesses. As a result, the measures in this Bill show the Government’s unwavering support for R&D businesses.

Specifically, clause 2 and schedule 1 will help reduce bureaucracy and ensure that taxpayers’ money is spent as effectively as possible by simplifying the R&D tax system. That will stop many businesses having to navigate the complex transition between the two existing schemes. It is anticipated that the reduction of the intensity threshold in the R&D-intensive businesses scheme from 40% to 30% from April this year will allow around 5,000 extra SMEs to qualify for an enhanced rate of relief. A one-year grace period will also be introduced, providing certainty for companies dipping under the 30% threshold that they will continue to receive relief for one year. This is a vital measure for so many R&D-focused businesses, which inherently have peaks and troughs of activity. Taken together, these changes will provide £280 million-worth of additional relief per year by 2028-29 to help drive innovation in the UK.

--- Later in debate ---

[The First Deputy Chairman of Ways and Means (Dame Rosie Winterton)]

I call the shadow Minister.

[James Murray]

I rise to speak to the new clauses in my name and that my hon. Friend the Member for Hampstead and Kilburn (Tulip Siddiq).

Clause 21 and schedule 12 relate to the implementation of pillar 2 of the OECD/G20 inclusive framework on base erosion and profit shifting. Labour supports this clause and schedule as they are intended to modify the existing multinational and domestic top-up taxes introduced in the Finance (No. 2) Act 2023, to make sure these new taxes work as intended. We have long supported the global deal on the taxation of large multinationals, as we want to see it working as effectively as possible.

We know that the OECD guidance on implementing the deal is coming out in tranches, so it is important that UK legislation is updated to reflect that. We recognise that, as with any global deal of this scale, its details are complicated and its implementation will take time, yet we have been clear throughout its development that we support the principle of a global agreement as a crucial step in making the tax system fairer, thereby helping to make sure that British businesses that pay their fair share of taxes are not undermined.

Indeed, nearly three years ago, in April 2021, I first set out in the Commons our support for a global deal to make that tax system fairer, to make sure that a level playing field is there for British businesses and to stop the international race to the bottom on tax for large multinationals. The Treasury Ministers at the time appeared at first lukewarm in backing plans emerging from the United States for a global deal. Eventually, however, the then Chancellor, now the Prime Minister, began to support the deal in public. We were glad that the current Prime Minister seemed to have come round, but I am not sure all his Back Benchers have. For instance, I wonder whether the hon. Member for North East Bedfordshire (Richard Fuller) would agree with the Prime Minister when he said:

“We now have a clear path to a fairer tax system, where large global players pay their fair share wherever they do business.”

We agree with the Prime Minister on that point, but I just wonder whether everyone on the Conservative Benches does. I am reading some of their faces and I think the answer is clear. Could it be that the Prime Minister lacks support from prominent Back Benchers within his own party on a policy he is now championing? Surely not. But Treasury Ministers should rest assured that if their Back Benchers pull any tricks on clause 21, they will have our support for it to pass.

Oral Answers to Questions

James Murray Excerpts

Tuesday 19th December 2023 Commons Chamber

[Mr Speaker]

I call the shadow Minister.

[James Murray (Ealing North) (Lab/Co-op)]

Throughout the pandemic, people across the country made extraordinary and heart-wrenching sacrifices, yet as they did so, a small minority were instead making millions of pounds by ripping off the taxpayer. With conflicts of interest, defective goods and exorbitant profit margins, it has been greedy and grubby and this Conservative Government have enabled it all. As taxpayers, we want our money back, so Labour will create a covid corruption commissioner to chase down every pound we can. Does the Minister have any idea just how angry people are that our country has been taken for a ride?

[Laura Trott]

The hypocrisy is absolutely astonishing. During the pandemic the shadow Chancellor wrote that the strategy of turning to big-name UK manufacturers was not delivering the supply that was needed. Yes, we procured things very fast—we needed to do that to get things to the frontline—and we are trying to get back every single penny that was lost to fraud, but we make no apology for doing whatever we could to get PPE to the frontline as quickly as possible.

[James Murray]

The Minister’s response really does not reflect the seriousness of the situation. This is not just one bad apple; this is a rotten culture that goes to the very top, with £8.7 billion lost on wasted PPE and £7.2 billion lost to covid fraud. That is £15.9 billion of public money gone at a time when people and public services are struggling. Can the Minister remind the House who was Chancellor at the time that all of this was signed off?