Finance (No. 2) Bill

James Murray Excerpts

2nd reading
Wednesday 17th April 2024 Commons Chamber

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

I am grateful for the chance to respond on behalf of the Opposition in this Second Reading debate.

The Finance Bill follows last month’s Budget, in which the record of the Conservatives’ time in office was laid bare. After 14 years, the Conservatives have shown what they can deliver for the British people: higher taxes, falling living standards and lower economic growth. The truth is that after 14 years, they are out of time, out of ideas and out of touch with reality. They are out of time because whatever they say or try to do now, it is too late to repair the damage that they have done to the economy and to people’s standard of living. The Conservatives may now have implemented a reduction in national insurance—a cut that we support—but that comes amid a tax burden that is set to rise to its highest level in 70 years, and to rise in each and every year of the forecast period. The Government simply cannot escape the reality that under their plans, for every £5 they are giving back to families, they will be taking £10 in higher taxes. Giving with one hand and taking twice as much with the other—that is the reality of life under the Conservatives.

The Government are not just out of time, but out of ideas. In the Budget from which this Finance Bill came, the Conservatives performed what may be the biggest U-turn of this Parliament yet, and there is some tough competition on that. After years and years of the Conservatives opposing tooth and nail our plan to scrap non-dom status, the Chancellor stood in this Chamber last month and adopted our approach as his own. I recall the Financial Secretary’s immediate predecessor, the right hon. Member for Louth and Horncastle (Victoria Atkins), being a particularly passionate defender of non-dom status. I remember her declaring less than a year ago, during the Committee stage of a previous Finance Bill, that

“We have come to the conclusion that non-domiciled status is right”.––[Official Report, Finance (No. 2) Public Bill Committee, 16 May 2023; c. 44.]

How times change!

Despite the Government’s apparent U-turn, we have learned since the Budget through our careful analysis of the Government’s plans that loopholes remain in their approach to abolishing non-dom tax status. Alongside an unnecessary discount in year 1, there is a loophole that appears to have been intentionally designed to allow non-doms to stash money away in offshore trusts, so that they can avoid being subject to inheritance tax, as any other member of the public is. Those loopholes must be closed, because if a person makes their home and does their business in Britain, they should pay their taxes here, too. People will look at those loopholes and rightly conclude that despite the Budget’s U-turn, this Prime Minister just cannot bring himself to sort out the non-dom problem once and for all.

[Richard Fuller]

If I may say so, the hon. Gentleman is clutching at straws. There may be a few hundred million pounds here or there in what the Government propose doing to tighten up supposed loopholes, but as he is aware, the Labour party wants £28 billion spent on its green investment. Which taxes will he raise to pay for that?

[James Murray]

I fear that the hon. Gentleman is slightly out of date. Going into the general election, we have set out very clearly our plan to invest in the transition that we need in our energy supply and our economy, and how we would pay for that—through a strengthened windfall tax, alongside prudent investment. He may scoff at what we say about the non-dom tax loopholes, but we are talking about £1 billion in the first year and £2.6 billion over the course of the next Parliament. That money should go to our public services, rather than intentional loopholes allowing some people to get away with paying hundreds of millions of pounds less in tax.

The Conservatives are not just out of ideas, but out of touch with reality. They made that very clear in last month’s Budget, from which this Finance Bill arose. At the end of his Budget speech, the Chancellor made an astonishing £46 billion unfunded commitment—leaving a gaping hole in the public finances—when he pledged to abolish national insurance altogether. Since then, Government Ministers have had countless opportunities to row back from or U-turn on that commitment, but they have been determined not to. Earlier today, the Prime Minister had three chances to rule out cuts to the NHS, cuts to the state pension or tax rises to pay for his £46 billion unfunded tax cut. Each time, he refused to do so.

[Nigel Huddleston]

Will the hon. Gentleman give way?

[James Murray]

I will in a second. It is quite astonishing that the Conservatives are content to go into the general election with a £46 billion black hole in their plans, and that they refuse to say whether that £46 billion commitment will be funded by tax rises elsewhere or cuts to spending. I give way to the hon. Gentleman, so that he can confirm exactly how the Government will pay for that £46 billion black hole.

[Nigel Huddleston]

I very rarely intervene from the Dispatch Box, but I cannot help myself this time. The hon. Gentleman and I have had multiple conversations about this. He cannot differentiate between an aspiration and a policy commitment. His £28 billion was a policy commitment; what we have laid out is an aspiration. They are two different things.

As for the hon. Gentleman’s scaremongering about the possible hit to pensions or the NHS, he knows full well that those suggestions are absolutely not true, because national insurance does not wholly pay for health, benefits, or indeed pensions. He is either scaremongering or exhibiting complete and utter financial illiteracy. Total spending on the NHS is over £160 billion, and welfare spending is over £260 billion, massively dwarfing the total amount raised by national insurance. He either does not understand that, or is irresponsibly scaremongering, because he has known for a long time that national insurance and other payments are topped up by general taxation. He should know better.

[James Murray]

I thank the hon. Gentleman for his mini-speech. I feel I may have touched a nerve. He talks about people being scared; yes, I think people are scared when they hear the Government making a £46 billion unfunded spending commitment and not saying how they will pay for it. When the previous Prime Minister made an unfunded tax cut commitment of a similar order of magnitude, we know what havoc that caused in the economy, and people are still paying the price in higher mortgage payments and rent payments. I will just say to the hon. Gentleman that I gave him a chance to rule out cuts to the NHS or the state pension, or tax rises elsewhere, to pay for this black hole. I am not quite sure if he did that—maybe he has not got the line from his boss in No. 10 Downing Street—but the truth is that until the Government rule those things out, people will rightly worry about the impact his unfunded commitment will have on the economy.

The pledge the hon. Gentleman was speaking about sounds like exactly the sort of pledge that the right hon. Member for South West Norfolk (Elizabeth Truss) would approve of, because it comes to almost exactly the same amount as her Government’s unfunded tax cuts. Of course, the previous Prime Minster has been touring the TV studios and talking to newspaper journalists in recent days, saying, among other things, that people who claim that she crashed the economy are

“either very stupid or very malevolent”.

I wonder if the Minister would like to intervene to say whether he shares that view. No? He is not leaping to his feet now. I would have thought he would; I would have thought that Treasury Ministers would want to put as much distance as possible between themselves and the previous Prime Minister. Instead, with their £46 billion unfunded commitment, they seem determined to be a tribute act. Frankly, whatever the previous Prime Minister says, people across Britain know what impact her time in office is having on all of us, as we face higher mortgages and higher rents as a direct consequence of her economic recklessness.

That is the context in which we are debating this Finance Bill. The context is one of a Government who are out of time, out of ideas and out of touch with reality, and of a country that is feeling the impact of 14 years of Conservative economic failure. Even a simple clause such as clause 2, which sets the main rates of income tax, highlights the impact on ordinary people of decisions taken by this Government. Although the basic and higher rates of income tax are unchanged by this Bill at 20% and 40%, the tax burden on working people is rising as a result of the income tax personal allowance and the higher rate threshold being frozen from 2021-22 to 2027-28. Those tax thresholds would ordinarily have risen this April, but instead they are in the middle of a six-year freeze. According to the Office for Budget Responsibility, which I assume the Minister has respect for, these freezes will create 3.7 million extra taxpayers by 2028-29 and mean that 2.7 million more people will be paying the higher rate.

The truth is that, even taking into account any reductions to national insurance rates, the freezes in thresholds and the rises in council tax mean that by the end of the forecast period, the average family will still be £870 worse off. As the Resolution Foundation noted at the time of Budget, despite the reductions in national insurance, there will still be a net rise of £20 billion a year by 2028-29 in personal taxes. It pointed out that those over the state pension age, who do not benefit from national insurance cuts, will be particularly badly hit, and will face an average tax rise of £960 a year. The reality has been summed up by Paul Johnson, the director of the Institute for Fiscal Studies, who said following the Budget:

“This remains a parliament of record tax rises.”

That is the record of the Conservatives in government.

[Dr Luke Evans]

There is a certain Leader of the Opposition who, when standing for their post, said that as part of their No. 1 pledge, which was for economic justice, they would increase income tax for the top 5% of earners and reverse corporation tax cuts. If the hon. Gentleman’s party was voted into government, would it stand by that pledge? That too would increase the tax burden significantly.

[James Murray]

I am sorry, but I did not quite follow the hon. Gentleman’s question. I can, however, respond to the general point that I think he was making. We have been very clear that this is a Parliament of record tax rises. The tax burden is set to be the highest in 70 years, and we think that the tax burden on working people should be lower. However, we would only ever support tax rises if they were responsible, and done on a basis of economic security and stability.

[Dr Evans]

Will the hon. Gentleman give way?

[James Murray]

I will make some progress, because I have made that point quite clearly.

The tax burden has been pushed to a record high, and we have also seen a record number of changes and U-turns on tax rates and reliefs under this Government. That applies not just to personal taxation, but to tax rates and reliefs relating to businesses. Let us consider the Chancellor’s approach to the rate of corporation tax, which the Bill sets at 25% in clause 12. In July 2022, during his leadership bid, the current Chancellor 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 U-turn on what he inherited and to commit to raising that tax from 19% to 25%. He has been typical of the Conservatives in lacking any certainty, predictability or consistency, and we know how damaging that is to businesses that are trying to make investment decisions.

As the shadow Chancellor set out, if we win the next general election, we will bring back certainty by capping 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 threatened to undermine UK competitiveness. We believe that the current rate of 25%—the lowest in the G7—strikes the right balance between what our public finances need and keeping our corporation tax competitive in the global economy. We also recognise the importance of stability and predictability in the reliefs available to businesses. We have seen a great deal of chopping and changing in capital allowances in recent years—indeed, this is a rare example of a Finance Bill from this Government that does not change the annual investment allowance or expensing regime.

We have made it clear that if we win the next general election, we will publish a road map for business taxation in our first six months in office, to give businesses the stability, predictability, and long-term plan that is so important to those making investment decisions. We have been pushing for a proper windfall tax on the profits of oil and gas companies operating in the North sea. The Government, despite initial opposition, U-turned on that and adopted some of our proposals with the introduction of the energy profits levy. Ahead of the general election, we have set out our plans to make the windfall tax stronger, and to raise more revenue to support our country’s energy transition, but it is also right that we give as much certainty as possible to those companies affected.

[Mary Glindon (North Tyneside) (Lab)]

Does my hon. Friend agree that we need a domestic oil and gas sector and offshore energy sector to deliver for the economy, to deliver energy security, and to bring in the investment needed for transition? After all, the North sea has powered our economy and our country for decades, and it can do so for decades to come.

[James Murray]

My hon. Friend is right to say that it is important that we offer as much certainty as possible to those companies affected. We recognise that by its very nature, the windfall tax is expected to be a one-off levy in response to extraordinary profits, and will ultimately come to an end. We have set out that if we win the next general election, the energy profits levy will end no later than the end of the next Parliament. We also fully support the energy security investment mechanism in clause 19, and the signal that it gives, which helps with investor confidence in the UK’s offshore energy sector.

We will not oppose the Bill on Second Reading, and we look forward to detailed consideration of its clauses in Committee. However, the wider context in which the Bill has been published lays bare the record of the Conservatives in government. That record is one of falling living standards for people across Britian, and the highest tax burden in 70 years. It is one of economic stagnation, from a party that is out of ideas and has been unable to provide the stability that businesses need. It is also one of recklessness with the public finances, both when the previous Prime Minister crashed the economy, and now that the current Prime Minister has made a £46 billion unfunded pledge to scrap national insurance. It is time to turn the page and turn a corner—time to give British people the chance to change our country’s Government by calling a general election.

--- Later in debate ---

[Richard Fuller]

My right hon. Friend has voiced the concern that I know will rest on the conscience of my hon. Friend the Minister, and he is right to add that. May I put a second conscientious point to the Minister—this point was also made by the shadow Minister, the hon. Member for Ealing North (James Murray)—which relates to the scoring for contaminated blood? That was not included in the Budget, which will have disappointed a considerable number of Members of Parliament from all parts of the House. It would be helpful if the Chancellor came forward with some view on that. Will my hon. Friend look at that?

Thirdly, will the Minister be encouraged by the words of my right hon. Friend the Member for Wokingham (John Redwood) and his analysis of the charges imposed on the Treasury by the Bank of England as a result of the quantitative tightening policies? The UK’s policies on quantitative tightening are exceptional. Few other central banks—many of which indulged in the bizarre quantitative easing policy 15 years ago, after the financial crash under the last Labour Government—do it, and it is now a real charge that has real effects on the real economy in the country. The exceptional way in which we are treating quantitative tightening charges—essentially, we take them on the books, the Treasury gets charged for it, and it has to go into the scoring that the OBR and others do—does not go on in other European countries. There is discretion on how it can be put across, and in the US the charges are absorbed but the Government are not charged. That is an important policy point, and I would be interested to hear whether the Minister would accept an amendment on that in Committee, although I think not.

Prosaically, or simply, HMRC has been in the headlines for not answering phone calls and for saying it would go on holiday. I am pleased that the Minister reversed that straightaway, and I know many taxpayers will be pleased about that. Many who will be looking to fill in their self-assessment forms will be surprised that they cannot download form SA100—they have to call HMRC to download a copy, whether or not they want to file it by paper. That seems a little odd, if HMRC’s phonelines are under pressure. Will the Minister, who has been responsive on points to date, look into that?

I will turn to the shadow Minister’s speech—I like him too. As he in his own mind “prepares for government”, he and his colleagues may wish to get a better grasp on reality. When he rightly talks about the importance of setting clarity for investment, it is important that those looking at investment think that those in charge of the public finances know what is going on. He talked about record tax rises under this Government. Let me ask him these questions. Did he disagree with funding of the furlough programmes? Did he disagree with the energy price support? Did he disagree with the increase in funding for the NHS? Did he disagree with record numbers of police officers? If he did not disagree with any of those, he would recognise, if he had a grasp on reality, that he would have to fund those through increased taxation or increased—[Interruption.] He has an answer, so would he like to come in? [Interruption.] Mr Deputy Speaker, I thought he had an answer.

[James Murray]

The hon. Gentleman is asking me what I disagree with. I disagree with the low growth that has been true of this Government. I disagree with billions of pounds being wasted in covid fraud and in other ways by the Government. I disagree with how the Government are now overseeing the highest tax burden in 70 years and have no plan to get the economy growing. That is what I disagree with.

[Richard Fuller]

The hon. Member mentioned growth rates, fraud and the record tax burden. I was making a point about the record tax burden, and he cannot respond to that challenge by repeating that he is concerned about it. He talked about low growth—he should go to Germany or France, which have lower growth than the UK. He should go to the majority of G7 countries, where he will find lower growth than in the UK. He is mistaking—[Interruption.] Would he like to intervene again? No.

I am trying to be helpful, obviously. The hon. Member and the shadow Treasury team wish to be taken seriously, but he will know that the points about growth are difficult to work through, with western economies not growing as fast as they have done. The UK is growing faster on average than other countries, and he needs to give some credit for that rather than just say that low growth is the case.

More importantly, if the hon. Member and the Labour party believe in furlough, the energy price schemes, the record increase in NHS funding and more police—they supported most of those programmes—they must recognise that those must be paid for in government, and that means hard choices. What the Prime Minister and the Chancellor have done is make those hard choices. Making people feel bad about historical hard choices is not a policy for a future Government.

--- Later in debate ---

[James Murray]

We seem to be engaging in an unexpected back-and-forth. The hon. Gentleman did not mention covid fraud. As he might know, we have set out our plans for a covid corruption commissioner. Would he support that—yes or no?

[Richard Fuller]

Of course, everyone supports cracking down on fraud, and I would be very happy—[Interruption.] If I may, I would be happy to look at the Labour party’s specific proposals. But the hon. Member will also know that when the Labour party talks about fraud, particularly when it comes to personal protective equipment and the furlough programmes, it conflates two things. For example, with the coronavirus loan programmes, Labour is conflating moneys that have not repaid because businesses have gone bust, or because companies have not paid them back yet, with moneys that have been lost fraudulently. When I look at his proposals, I want to ensure that when Labour talks about the amounts that have been lost, they relate to actual examples of fraud and not to the ways in which, in a difficult situation where people’s businesses could have been closed, money was given out by the Treasury to others. If that is the case, I am happy to look at that.

My second point to the Opposition—before I get on to what I want to say—is that I hold no torch for the former Prime Minister, my right hon. Friend the Member for South West Norfolk (Elizabeth Truss), but when the hon. Member and his colleagues talk about crashing the economy and about people’s mortgage rates, as I think the Leader of the Opposition did at Prime Minister’s questions, may I gently urge them to look at the Bernanke review that has just been completed on Bank of England forecasting? That has a number of important points about how the Bank of England could improve its forecasting. It also compares interest rates for the seven central banks that Ben Bernanke, the former head of the US Federal Reserve, has used as his comparators—in figure 12 in the report. If the hon. Member looks at that, he will see that UK interest rates in 2019 were in the middle of the pack, UK interest rates in 2020 were in the middle of the pack, UK interest rates in 2021 were in the middle of the pack, UK interest rates in 2022 were in the middle of the pack and UK interest rates in 2023 were in the middle of the pack. UK interest rates as we enter 2024 are in the middle of the pack. It is simply not true to say that something exceptional happened to UK interest rates in any part of this Parliament. Again, if the hon. Member wishes to be taken seriously in government, he needs to get a grip on reality, not on fantasy.

I will now turn, if I may, to the things that I would like to say. [Laughter.] I did promise the Whips that I would take only 10 minutes, so I promise to take only 10 minutes, from now. Clause 12 sets the corporation tax rate. I see my friend the hon. Member for Mid Bedfordshire (Alistair Strathern) in his place on the Opposition Benches. I think that both he and I are pleased that Government and Opposition Front-Bench Members have made clear their commitments for full expensing. That is particularly important to the people of Bedfordshire because there is a potential investment pending in his constituency. I would like to put on record our thanks to the two Front-Bench teams for setting out the clear future framework for how that will work.

Let me turn to income tax rates in clause 2, because it is important to look at the history. As my hon. Friend the Minister mentioned, the record of successive Conservative Governments from 2010 for working people in this country is strong. He mentioned the increase in the personal allowance from £6,475 in 2010 to £12,570 this financial year. That is a 21% real increase. However, my hon. Friend did not mention the change in the minimum wage, which has gone up from £5.80 in 2010 to the living wage now of £11.44. That is a 23% real increase in wages. Higher wages for working people and lower taxes for those on lowest incomes is a very strong record.

However, my hon. Friend needs to look at the higher rate threshold, because in 2010 it was £37,400, and now it is £37,700. In today’s money, the 2010 amount would be set at £59,800. In essence, there has been a 37% decrease in earnings when people hit the higher threshold. It may not be popular politically, but economically such a substantial differentiation in the way we tax people on middle and high incomes from those on low incomes has long-term implications. After the Budget, people who have retired, have been thrifty and saved money and have a private pension now find themselves complaining that, although they are getting their increase in the basic pension—or maybe not—they are being dragged into the higher rate of taxation. Successive Conservative Governments have rewarded work—they have wanted people to work hard, be entrepreneurial, and grow their businesses and the economy—so please, can we look at the ways in which that particular threshold should change?

Quite rightly, the Prime Minister and the Chancellor have indicated that they wish to simplify taxation on working people. That is completely consistent with the long-run approach of the Conservatives to taxation on work. The aspiration to reduce national insurance is an excellent way of looking at that. Unlike the Opposition, I would say that there is a difficulty in politics of finding times to make quite significant changes. This may be such a time—I know that Ministers will be looking at this—partially because we have quite significant issues of overall taxation that we need to reduce, but there is the opportunity for other reasons as well. Reallocation of existing taxes is easier when the tax burden is exceptionally high. I am a low-tax Conservative. I recognise, unlike some, that when we buy things, we have to pay taxes on them. But we know that this tax rate is unusually high, and we know that we will reduce that tax burden. It is a propitious time to look at ways of reducing national insurance contributions over the next five years.

The Budget forecasts fiscal drag to be £28 billion to £33 billion per annum for the next three or four years. There is an ethical and moral case for wanting to give back more money to people by reducing national insurance contributions. However, my proposal is for the Government to consider not that national insurance reductions should go directly into pay packets, but that national insurance contributions should be added to people’s long-term savings through compulsory savings schemes. Many countries have recognised that the idea of state pensions being based upon the “never, never” is not a secure way to provide for long-term pensions. We have never really grasped the nettle in this country—Singapore did it right at the start and Australia did it in the 1990s. There is an opportunity for us to build on the work that Sir Stephen Webb did in the coalition Government through changes to national insurance contributions. That would ensure that working people are the first generation to have a truly secure pension that is their money, where they do not have to rely on the vagaries of what a particular Chancellor of the day might do to pensions, and they would have only one tax on their wages during their career. Finagling people in other parties like to increase taxes, and having two taxes to increase gives them more flexibility. An opportunity would be provided to extend the savings stake—the way that people save for things—beyond providing for their retirement, so that they could, as they do in Singapore, put money into their first home. By looking in a new way at how we treat citizens in this country, we could move towards a savings state and away from a socialist never-never state. I leave my hon. Friend the Minister to consider those comments.

Finance (No. 2) Bill

James Murray Excerpts

Committee of the whole House
Wednesday 8th May 2024 Commons Chamber

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

I rise to speak on behalf of the Opposition to new clauses 1 and 4, which stand in my name and that of my hon. Friend the Member for Hampstead and Kilburn (Tulip Siddiq).

“This remains a parliament of record tax rises.”

Those are not my words but those of Paul Johnson, the director of the Institute for Fiscal Studies, following the spring Budget from which this Finance Bill derives. However, the IFS was not alone in its view. In response to the Budget, the Institute for Government was clear as well, saying that taxes were set to rise

“to a post-war high as a result of decisions made by Conservative chancellors over the past 14 years.”

Meanwhile, the National Institute of Economic and Social Research described the Chancellor’s announcements in March as a

“low-key budget…unlikely to unlock the UK’s growth and productivity problems”.

The verdict is clear. People in Britain are facing higher taxes, squeezed living standards and weaker public services, and they have a Government who are unable to undo the damage that they have caused. No matter what the Conservatives now say or do, the truth is that the tax burden is set to rise to its highest level in 70 years. The decisions taken by Conservative Chancellors in this Parliament—and, let’s face it, there have been a few of them—mean that the average family will face a tax bill that is £870 a year higher by 2028-29. For pensioners, it is even worse: people over the state pension ago do not even benefit from any changes in national insurance, which means that pensioner taxpayers will pay an eye-watering £960 more a year by the end of the forecast period.

People across Britain are struggling to make ends meet as they find their wages squeezed and taxes rising relentlessly, yet the Conservatives have decided to tell the British public that they have never had it so good. I note that Ministers are trying to do that again today, telling us that their plan is working, although that is not the reality of life for people who, at the next general election, will be asking themselves whether they and their families feel better off than they did 14 years ago. It is that reality that new clauses 1 and 4 seek to expose: as the Conservatives gaslight the British people, our new clauses are there to call them out.

New clause 1 does that by requiring the Government to come clean over how many people will be liable to pay income tax at 20% and 40% in the current tax year, how the number has changed over the last three years, and how it will change in the three years ahead. We want the Government to admit the impact that their six-year freezing of the income tax personal allowance and the higher rate threshold will have. According to the Office for Budget Responsibility, 3.7 million more people will be paying tax by 2028-29, and 2.7 million more will be paying the higher rate, as a result of the Government’s threshold freezes. Will the Minister repeat those figures and admit that they are correct? We believe that the Chancellor should be honest about this too, and that is what new clause 1 seeks to achieve.

We know that the outcome of the Conservatives’ decisions during the current Parliament is hitting pensioners who pay tax especially hard: because taxpayers over the state pension age do not benefit from any of the changes in national insurance, they will feel the impact of the Conservatives’ tax rises even more. That is why we tabled new clause 4—again, requiring the Chancellor to come clean about the impact of his and his predecessors’ policies. The new clause requires the Chancellor to set out the number of pensioners who will be liable to pay income tax this year and in each of the next three years, and what the average pensioner’s tax bill will be. Pensioners deserve to know the truth about how the Government’s decisions will affect them, and they have good reason to be concerned about this Government.

While Labour has guaranteed that the pensions triple lock will be in our manifesto and protected for the duration of the next Parliament if we win, the Conservatives refuse to say what impact on pensioners their £46 billion unfunded pledge to abolish national insurance altogether would have. As the shadow Chancellor, my right hon. Friend the Member for Leeds West (Rachel Reeves) said yesterday, it is a tax bombshell aimed squarely at Britain’s pensioners. The Conservatives are refusing to say how they would pay for this massive commitment, so it is hard not to suspect that they are concealing their plans to make pensioners pay the bill. Perhaps they will pay for the revenue lost through the abolition of national insurance by making changes to pension rates or to the state pension age, but if they are planning to keep pensions the same and make up the revenue by raising the basic and higher rates of income tax, that would mean an 8% increase in income tax rates.

My colleagues and I have asked Ministers time and again to come clean about how they would pay for their plans, but they resolutely refuse to do so. They could clear this up right here, right now, by either abandoning their unfunded commitment or explaining how they would pay for it. I would happily give way if the Minister would like to do that, but I suspect that he will not. We know that the Conservatives find the reality of their tax-raising record so hard to bear that they would rather hang on to a reckless, unfunded plan to abolish national insurance to make them feel better about themselves and to desperately try to keep their divided party together. It is crystal clear that for the Conservatives it is party first, country second.

We also know that the Conservatives’ high tax record goes hand in hand with their record of low growth in the economy. Indeed, one of the reasons taxes are so high is the fact that economic growth has been so weak over the past 14 years. Again, no matter what the current set of Ministers say, the idea that the economy is turning a corner is simply not reflected in reality. The truth is that our economy is smaller per person than it was when the right hon. Member for Richmond (Yorks) (Rishi Sunak) became Prime Minister. Our country is forecast by the OECD to have economic growth of just 1% next year, weaker than that in every other G20 country except Russia. If, under the Conservatives, the UK economy had grown at the average OECD rate, it would now be £140 billion larger—and that growth would have provided an extra £50 billion in tax revenues to be invested in our public services. Instead, economic growth is on the floor, taxes are going up, and public services are falling over. That is the Conservative doom loop that we are in. We know that the only way out of the doom loop of ever-rising taxes with nothing to show in return is to get the economy growing with Labour’s plan.

Labour’s plan for economic growth is driven by the need for stability, investment and reform. Stability, something so sorely lacking in the recent years of Conservative chaos, must be the basis of a secure and responsible approach to the economy, and with strong fiscal rules, a new fiscal lock and respect for independent institutions, we will put stability at the heart of our approach.

[Jonathan Edwards]

At the beginning of his speech the hon. Gentleman mentioned Paul Johnson, whom the press has quoted today as saying that the Government and the Opposition are tied to the same fiscal path. Is that an ideological decision or a general election tactic? I am genuinely interested in hearing the answer.

[James Murray]

We in the Labour party believe that having fiscal rules that are iron-clad is essential to being trusted to manage the economy in a responsible way that puts family security and family finances first. Having strong fiscal rules and stability underpinning every other decision that we make is absolutely essential to everything that a Government might hope to do. Indeed, that stability forms the foundation for getting the economy growing, because with stability we will be able to work in partnership with businesses to remove the barriers to investment, using catalytic public investment to unlock more than £20 billion from the private sector to invest in the industries of the future. To support that investment, we will reform the systems that our economy needs to thrive, from reform of our planning system and employment rights to devolving powers to elected Mayors on transport, skills, enterprise, energy and planning. That is how Labour will begin to grow the economy if we win the next general election.

We know that a new approach and a new Government are needed, because that is what people across the country are telling us. People want a new approach whereby they can feel better off, rather than struggling to make ends meet as their taxes rise relentlessly. The Conservatives are desperate to distract from the mess they have created. They go from the simply unbelievable, like the Chancellor claiming yesterday that they had abolished low pay, to the unbelievably reckless, like their £46 billion unfunded plan to abolish national insurance. But no matter what they say, or how hard they try to pretend that their plan is working and that people in Britain have never had it so good, people know the reality of life. People know that taxes are at record levels.

Today we want the Conservatives to at least come clean and admit how many more people are paying tax as a result of their decisions in this Parliament, and how hard they are hitting pensioners in particular. Frankly, however, no matter whether they come clean, come the general election, people across Britain will ask themselves whether they and their family feel better off today than they did 14 years ago. The answer to that question is the reality from which the Conservatives cannot hide.

[Sir John Redwood (Wokingham) (Con)]

I have declared my business interests in the Register of Members’ Financial Interests.

I rise to speak in support of tax-cutting proposals. We are not discussing the national insurance reductions in this group of clauses, but both previous speakers have spent some of their time discussing them because they are relevant, as they are the other side of the issues related to the correct levels and thresholds for income tax, which are the proper matter of our current debate. I wanted any kind of tax cut in the Budget, because we are over-taxed and the right kinds of tax cuts can speed up growth, which all the major parties in this House want, although there are some disagreements about the exact mix of policies that might create it.

The first thing we need from the Treasury is for its official forecasts and those of the OBR to have greater belief in the fact that if we promote more growth by cutting some tax rates, we may end up with more tax revenue. The best generator of more revenue to pay for our public services is a growing economy. The best generator of more growth is productivity improvements, and there is particular scope for such improvements in the public sector. The public sector was badly damaged by the covid experience. We lost a lot of productivity through the hasty and unnecessary reorganisation of public services during the pandemic, but we are finding it hard work and slow going to get the lost productivity back.

I welcome the fact that, in the latest set of Budget numbers, the Government have put in future productivity recoveries over the next few years, but it is slow progress, even to get back to the levels of productivity in 2019. I put it to the Government that they do not need to spend extra money on new technology, such as artificial intelligence, to get back to the levels of 2019. They may wish to recommend schemes for AI investment to get above 2019 levels but, by definition, we were able to get to 2019 levels of productivity without AI, because it had not been invented at that stage.

There should be more common agreement about the urgency of productivity recovery in public services. We are missing out on at least £20 billion due to the productivity problems that have developed since 2020 and the lockdown experience. However, there is also a source of extra revenue from lower taxes, because if we cut tax rates in the right way, we will generate more cash, rather than less. I think everybody now agrees that cutting certain taxes has that effect, because it is quite obvious that if we impose certain kinds of turnover or activity taxes, they will lower turnover and activity. Indeed, many taxes are imposed with a moral wish to lower activity or usage rates. For example, alcohol and tobacco attract higher taxes because the wish is that people buy them less or, in the case of tobacco, do not buy them at all. We get the same effect with things that we should be promoting.

--- Later in debate ---

[The Second Deputy Chairman of Ways and Means (Mr Nigel Evans)]

I call the shadow Minister.

[James Murray]

Thank you, Mr Evans, for the opportunity to speak on behalf of the Opposition to new clauses 2 and 3, which are in my name and that of my hon. Friend the Member for Hampstead and Kilburn (Tulip Siddiq).

Earlier this afternoon, we pressed the Government on the impact of tax rises, particularly stealth tax rises, on families and pensioners. Of course, it is not only taxpayers and their families who are struggling to make ends meet under the Conservatives. Businesses in Britain are struggling too, and when I meet those from businesses across all sectors, of all sizes and in different parts of the country, they are clear that they want a Government who support them to succeed and grow. What the people I speak to from businesses want from Government, first and foremost and above all else, is stability, predictability and a plan for growth. Stability is greatly prized by businesses, which want to make decisions about investment and growth, which are critical to creating jobs and making people across Britain better off.

--- Later in debate ---

[Sir Christopher Chope (Christchurch) (Con)]

It is a pleasure to follow the hon. Gentleman. I wish to speak briefly on clause 12 stand part and the new clause to which he has just spoken.

Clause 12 is a simple clause. The title is “Charge and main rate for financial year 2025”, and it states:

“Corporation tax is charged for the financial year 2025…The main rate of corporation tax for that year is 25%.”

Just over four years ago, I was re-elected to this House on a Conservative party manifesto that said that we would keep corporation tax at 19% and would not increase it. As the hon. Member for Ealing North (James Murray) just reminded us, the Chancellor of the Exchequer thought that 19% was far too high, and he had a radical proposal to reduce it to 15%. At the time, I did not buy into that leadership bid of his, but it is clear now that it was an extraordinary gesture, completely at odds with what he must believe, because I presume that he supports clause 12, which sets corporation tax for the following year at 25%. That is far too high. I voted against the increase originally, and if clause 12 stand part was pressed to a Division today, I would certainly vote against it.

It was with some incredulity that I listened to the hon. Member for Ealing North. His new clause 2 talks about reviewing the impact of section 12. The incoherent subsection (1) says:

“The Chancellor must, within three months of this Act being passed, conduct a review of the impact of section 12 of this Act.”

Obviously, section 12 will not come into effect until the 2025 financial year, while the Bill will be on the statute book within a couple of months. What would be the point of conducting, within three months of that date, a review into something that will not come about until next year? If the new clause mentioned reviewing the impact of the current high levels of corporation tax, I would be with him. [Interruption.] He is shouting at me from a sedentary position. I will happily give way to him, so that he can make his point. Let us have a debate. If he does not want to engage in debate, so be it.

All I am doing is reading out the terms of the hon. Gentleman’s new clause 2. If he wishes to resile from that, let him say so. I am sure that, even at this late stage, Mr Evans, you would accept him withdrawing the new clause because its terms do not bear out what he is telling us.

[James Murray]

The hon. Gentleman invites me to respond. The key point of the new clause, as I am sure he realises, is to make it clear that Labour would cap corporation tax at 25% for the whole of the next Parliament. Does he agree with that?

[Sir Christopher Chope]

No, I do not, because that would be capping corporation tax at far too high a level. I would like to see it reduced, ideally back to 19%, as soon as possible. I certainly would not support any notion that we should stick with a 25% rate for the duration of the next Parliament.

That intervention was interesting. If that is the purpose of the hon. Gentleman’s new clause, I think we can say that it is rather opaque, because it does not say, for example, “Between 2025 and 2030, corporation tax shall be set at the rate of 25%”. It says that there should be

“a review of the impact of section 12 of this Act.”

What would the review look at? One thing would be how the 25% rate of corporation tax provided for by section 12 had affected

“investment decisions taken by businesses”.

Surely we know—I think he said so in his remarks—that having corporation tax set at 25% adversely affects businesses making investment decisions, including decisions on whether to increase their investments, or whether to invest in the United Kingdom for the first time. It is because such adverse investment decisions have been taken by businesses that, as he accepts, we have low growth, coupled with rising taxes and a stagnant economy.

It surprises me that more of my colleagues do not wish to engage in this debate. I very much support those Government Members who believe that the Chancellor of the Exchequer’s main objective should be to grow our economy, rather than stifle it through high taxes and more regulation, which seems to be what is happening.

In a sense, the hon. Gentleman has answered his own question—high rates of corporation tax adversely affect investment decisions taken by businesses—so why do we need a review to establish that? How can he both want a review because he does not know the answer to that question, and be so confident about its results that he can announce today that corporation tax will be at 25% for the next five years? It seems a pointless exercise. One is left with the feeling that the main parties have very similar policies on many aspects of taxation.

--- Later in debate ---

[Gareth Davies]

We agree. We want taxes to come down, but we are not going to announce tax decisions from this Dispatch Box outside fiscal events. It is clear for all to see that this Conservative Government believe in lower taxes. We have reduced national insurance contributions for 29 million people by some 30% in just the last six months, and the record is very clear on that.

[James Murray]

The hon. Gentleman says that the Government are not in the habit of making policy commitments outside the normal fiscal process. Does that mean the £46-billion unfunded black hole created by the promise to abolish national insurance is no longer a policy of this Government?

[Gareth Davies]

It is neither unusual nor incorrect for a Government, or any party, to set out a long-term ambition to let the public know where we stand on taxation and what we want to see in the future. In 2010, for example, we said that we wanted to increase the personal allowance for income tax to £10,000, and we met that. Actually, we exceeded it. It is now over £12,500, so a person in this country can earn £1,000 every month without paying any tax at all. That is a long-term ambition that we have delivered.

[James Murray]

The Minister is being generous in giving way. I notice that he is keen to talk about a long-term ambition to abolish national insurance. Yesterday, the Chancellor of the Exchequer said at Treasury questions that

“our policy is to abolish employees’ national insurance”.—[Official Report, 7 May 2024; Vol. 749, c. 437.]

Was the Chancellor wrong?

[Gareth Davies]

As I said, it is a long-term ambition. It is right for a party that is serious about governing to set a direction for the country. I know it is an unusual idea for the hon. Gentleman that having a plan for government is the right thing to do, but we have made it very clear to the British people that, if they vote for a Conservative Government at the next general election, their taxes will come down.

The amendments before the Committee propose that we publish information that is already publicly available. They are not needed, so I urge the Committee to reject them.

Question put and agreed to.

Clause 12 accordingly ordered to stand part of the Bill.

Clauses 13 and 19 ordered to stand part of the Bill.

New Clause 2

Review of impact of section 12

“(1) The Chancellor must, within three months of this Act being passed, conduct a review of the impact of section 12 of this Act.

(2) The review must consider how the rate of corporation tax provided for by section 12 affects—

(a) investment decisions taken by businesses,

(b) the certainty of businesses about future fiscal and market conditions.

(3) For comparative purposes, the review must include an assessment of how the factors in subsection (2)(a) and (b) would be affected by maintaining corporation tax at a rate no higher than that set out in section 12 until the end of the next parliament.”—(James Murray.)

This new clause requires the Chancellor to conduct a review of how the rate of corporation tax set by the Bill set out in clause 12 affects business investment and certainty, including what the effect would be of capping it at its current level for the next Parliament.

Brought up, and read the First time.

Question put, That the clause be read a Second time.

Finance (No. 2) Bill

James Murray Excerpts

Committee stage
Tuesday 21st May 2024 Public Bill Committees

[The Financial Secretary to the Treasury (Nigel Huddleston)]

It is a pleasure to serve under your chairmanship, Mrs Latham, and I thank all hon. Members for their participation in today’s debate. I also thank those who have submitted written evidence on a variety of the clauses we will discuss today, including the Institute of Chartered Accountants in England and Wales, the Chartered Institute of Taxation, the Low Incomes Tax Reform Group and others, and all those who have contributed to consultations as part of this Finance Bill process.

Clause 5 makes changes to the high income child benefit charge, or HICBC, as it is commonly called. It increases the threshold at which child benefit begins to be withdrawn, from £50,000 to £60,000. The Government are also increasing the threshold at which child benefit is fully withdrawn, from £60,000 to £80,000. That means that 1% is withdrawn for every £200 of income that exceeds £60,000; previously, the rate was 1% for every £100 of income that exceeded £50,000, and child benefit was fully removed once individuals earned £60,000 or above.

The HICBC is a tax charge and was introduced in January 2013 for recipients of child benefit payments, or their partners, on higher incomes. It applies where the highest earner has an adjusted net income—that is, their total taxable income, less certain reliefs, such as pension contributions—above the threshold, which is rising to £60,000. For individuals with incomes above the top of the taper, which is rising to £80,000, the tax charge is equal to the full amount of the child benefit payment.

The changes will ensure that the HICBC continues to withdraw child benefit from high-income families, as it was designed to, without unfairly penalising those on middle incomes. By halving the rate at which HICBC withdraws the child benefit gain, the Government are improving people’s incentives to continue working or to take up more hours. The Office for Budget Responsibility estimates that, as a result of both changes, those already working will increase their hours by a total equivalent to those of around 10,000 full-time individuals by 2028-29.

The changes made by clause 5 will have a positive impact for around 485,000 families, who will gain an average of £1,260 in 2024-25, which they can put towards the cost of raising their children. That includes around 170,000 individuals who will no longer be liable for HICBC, and 135,000 individuals currently paying the HICBC who will have it reduced. The remaining 180,000 are the families currently not claiming child benefit or families opting out of getting child benefit payments who are now eligible to receive payments without incurring a tax charge.

The increase in the HICBC’s adjusted net income threshold reaffirms the Government’s commitment to rewarding working families, by allowing them to keep as much of their hard-earned money as possible in a sustainable way. I therefore commend the clause to the Committee.

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

It is a pleasure to serve on this Committee with you in the Chair, Mrs Latham. I am pleased to respond on behalf of the Opposition in the Public Bill Committee stage of the Finance (No. 2) Bill.

As we have heard from the Minister, clause 5 increases the adjusted net income threshold for the high income child benefit charge from £50,000 to £60,000, with effect from the 2024-25 tax year. The clause also amends the rate at which the high income child benefit charge applies to individuals with adjusted net incomes of between £60,000 to £80,000 in a tax year, and contains an administrative easement to prevent backdated child benefit payments from triggering a charge in 2023-24.

As we all know, due to high levels of inflation during the current Parliament, families across the country have felt the impact of threshold freezes, particularly in relation to income tax. Millions of people will be paying income tax for the first time or paying it at higher rates as a result of high inflation and the frozen thresholds. Similarly, the fixed nominal thresholds for the high income child benefit charge mean that more and more people will have been affected by the charge as a result of inflation. The adjustment to the thresholds in this clause will therefore be a welcome step for many families, and brings the number of individuals affected by the high income child benefit charge closer to what Parliament envisaged when the policy was introduced in the Finance Act 2012.

Although we support the measures in the clause and will not oppose them, we would appreciate some clarification from the Minister on one point. In particular, we understand that subsection (2) effectively halves the rate of clawback in the calculation of the charge, so the child benefit is fully withdrawn when the relevant adjusted net income reaches £20,000 above the initial threshold —that is, £80,000. I am grateful to the Chartered Institute of Taxation for pointing out that, because the clawback happens across a wider range of incomes, some individuals will be caught out by higher marginal rates of tax and will therefore likely need to file a self-assessment return. Is the Minister concerned that that will introduce more complexity into the tax system, and if so, what is he doing to communicate these changes so that taxpayers are not caught out?

Finally, we understand that the Government will be moving the assessment of the charge to a household basis from April 2026. I would be grateful if the Minister confirmed when the Government will announce further details about the consultation on that change. Will he also set out the details of what he is doing to consult industry and professional bodies about it?

[Drew Hendry (Inverness, Nairn, Badenoch and Strathspey) (SNP)]

It is a pleasure to serve under your chairmanship, Mrs Latham. We will not be opposing the clause, but I do want to make some comments about this paltry measure, which will help very few people in a cost of living crisis that the Conservative Government are trying to pretend is over and done with—in fact, they are saying that that is the case. That is not the reality for people in their homes across the nations of the UK.

The Minister said that the intention of this provision —I think I am quoting him correctly—was to allow people to “keep as much of their hard-earned money as possible.” That reflects incredibly badly on the way that this Government have conducted themselves by artificially boosting the cost of living through reckless actions such as Brexit and, of course, the mini-Budget. If they wanted to do something that was meaningful to help families, they could have copied the Scottish child payment in Scotland, which has lifted 100,000 children out of poverty. But no: they have decided to do this. They have also decided to keep the two-child limit on universal credit. That should be scrapped, and the Labour party should be joining in calls for that to be scrapped. The rape clause has no place in our society, and this measure will not go far enough to help families.

--- Later in debate ---

These clauses boost transactions in the property market while raising revenue. They remove the opportunity for abuse of multiple dwellings relief, and give public bodies certainty about their exemption from SDLT. I commend the clauses to the Committee.

[James Murray]

Clause 6 applies to residential property gains by individuals, trustees and personal representatives. As the Minister set out, it reduces the higher rate of CGT that applies to such gains from 28% to 24%. The new rate will apply to disposals made on or after 6 April 2024. As we understand it, the lower rate is intended to remain at 18%, and the CGT rates that apply to carried interest gains remain unchanged.

The Government’s policy paper on this matter claims that the measure will be revenue positive for the Treasury and will generate more transactions in the property market, benefiting individuals who are looking to move home or get on to the property ladder. The Opposition will not oppose moves that reduce the rates of tax while also raising greater income. However, I would like to ask the Minister for more detail on the Exchequer impact of this measure. The Government’s policy paper reports expected spikes in revenue of an additional £310 million and £350 million in 2024-25 and 2025-26 respectively. That then falls significantly to an additional £45 million in 2026-27, and to just £5 million by the end of the forecast period in 2028-29. I would be grateful if the Minister set out his explanation for this pattern of expected income. Is he confident that there will be a permanently higher level of income as a result of this change after the end of the forecast period?

Clause 7 abolishes multiple dwellings relief—a relief from stamp duty land tax available on the purchase of two or more residential properties in a single transaction or linked transactions. The change will apply to purchasers of dwellings in England and Northern Ireland that have an effective date of transaction on or after 1 June 2024.

SDLT is a tax on the purchase of land or property, and ordinarily the amount of tax chargeable is calculated on the basis of the total amount paid for land or property. MDR, meanwhile, was introduced in 2011 with the intention of reducing a barrier to investment in residential property and to promote the private rented sector housing supply. We know that the Government evaluations have shown very little evidence that MDR achieved its original aims in a cost-effective way. We believe that clamping down on dubious claims and abusive tax reliefs is the right thing to do, so we will support the clause, but I have a few points of clarification to which I would be grateful for the Minister’s response.

First, I would like to ask the Minister about the reasoning behind the introduction of MDR in 2011. I understand that in September 2010, the coalition Government said in response to a consultation that

“the Government will not be taking these proposals forward at the present time”.

However, at the Budget of March 2011, a few months later, they announced that they would indeed introduce changes to the SDLT rules for bulk purchases of residential property. Does the Minister know why the Government at the time changed their mind?

Secondly, the Minister referred to abuse of the relief, so I would be grateful if he shared with us any figures or estimates of the cost of abuse of MDR since its introduction in 2011. Thirdly, we note that the Government said that they will engage with the agricultural industry to assess whether there are specific impacts of their changes to MDR that should be given further thought. Will the Minister let us know whether he is consulting with any other sectors?

Finally, the Chartered Institute of Taxation has indicated that for the domestic buyer in the build-to-rent sector, the divergence between the rates of SDLT applicable to residential property and those in the non-residential sector is large. There is a great deal of complexity in the system, so is the Minister aware of the potential for anomalies and for new behaviour to emerge around the acquisition and definition of property? I would welcome his assurance that he will work closely with relevant stakeholders to ensure there are no unintended consequences to the changes in the clause.

Clause 8 makes changes to the rules for claiming first-time buyer relief from stamp duty land tax in cases where the purchaser is buying a new lease via a trust or nominee. It applies to purchasers of dwellings in England and Northern Ireland, with an effective date on or after 6 March. We know there have been instances of first-time buyers using trusts or nominees to conceal their identities to protect themselves from behaviours such as domestic violence and stalking. The clause corrects issues arising over the eligibility of such claims. It provides an amendment to correct a defect in the relief in order to ensure that the underlying buyer, not the nominee, is eligible for SDLT, and we will not oppose it.

As we have heard, clause 9 amends out-of-date references and definitions used in legislation relating to the SDLT exemption for registered providers of social housing. As the explanatory notes make clear, that is to ensure that all registered providers of social housing that purchase property with the assistance of a public subsidy are not liable for SDLT. The measure seeks, first, to update outdated references following changes to social housing legislation; secondly, to extend the definition of public subsidy to include receipts from the disposal of social housing; and finally, to amend the definition of registered providers of social housing to confirm that certain entities such as English local authorities are eligible for the exemption, which removes an uncertainty.

The changes are set to apply to transactions on or after 6 March 2024, but we understand from stakeholder representations that there is some uncertainty relating to the “clarifications” set out in the measure. Can the Minister confirm whether purchases made before 6 March by local authorities will be treated as separate to this clause, or has any scope been given in the exemption for those purchases made before that date?

Clause 10 removes public bodies from the scope of the higher rate of SDLT of 15%. As the explanatory notes set out, that is consistent with the treatment of public bodies in relation to the annual tax on enveloped dwellings, which does not apply to public bodies. Given that this is a corrective measure, we will not oppose it, although the Chartered Institute of Taxation has pointed out that with the measure not being retrospective, there are concerns among stakeholders. We understand, again, that the measure will apply from 6 March, the date of the Budget when the measure was announced. Can the Minister clarify what the situation will be for a public body such as a local authority that may have incurred a 15% SDLT liability in the weeks immediately before this change was announced?

As the Minister set out, clause 11 restricts the scope of agricultural property relief and woodlands relief to property located in the UK. As the Government’s policy paper states, the former measure was put in place to ensure compatibility with EU law; it expanded the scope of agricultural property relief and woodlands relief to property located in the European economic area. Now that the UK has left the EU, this measure reverses those changes, so that property located in the EEA will again be treated the same as property located in the rest of the world. This is a technical measure, and we will not oppose it.

Question put and agreed to.

Clause 6 accordingly ordered to stand part of the Bill.

[The Chair]

With the leave of the Committee, I will put the Question on clauses 7 to 11.

--- Later in debate ---

[Nigel Huddleston]

Clauses 14 and 15 make changes to better support the UK independent film industry. That is in recognition of the sector’s cultural importance and its role in growing and supporting UK talent. The Government have heard from several representatives of the British film industry, including the British Film Institute, about the specific challenges that the independent film industry faces. The Government also recognise the vital role that independent film plays in incubating UK talent.

The changes made by clauses 14 and 15 substantially increase the level of audio-visual expenditure credit available to smaller budget films from 34% to 53%. This increased rate for qualifying films is referred to as the UK independent film tax credit. The 53% tax credit will be applied on up to 80% of a film’s production costs, up to a cap of about £15 million. That translates into £31.80 back for every £100 spent, after accounting for corporation tax at 25%.

Films will also need to meet the criteria of a new British Film Institute test, with the expectation that films will have either a UK writer, a UK director or be certified as an official co-production. Clauses 14 to 15 set out the bulk of the measure, but further detail, including on the additional test, will be provided in a statutory instrument in due course.

Productions that start principal photography from 1 April 2024 will be eligible, and companies will be able to make claims from 1 April 2025 on expenditure incurred from 1 April 2024. The UK independent film tax credit is a transformational, generous, enhanced tax credit, which will boost the production of UK independent films and incubate UK film talent.

[James Murray]

As we have heard from the Minister, clause 14 introduces a higher rate of expenditure credit for independent films, defined as films below a maximum budget that have either a UK director or writer, or are an official international co-production. As the Government’s policy paper on this measure makes clear, the basic rate of credit under the audio-visual expenditure credit scheme is 34%. Independent films will now receive a rate of 53%, with the amount of credit capped to relevant global expenditure of £15 million. The Opposition strongly support the UK’s creative sector as one of the areas of the global economy in which Britain is world leading. As such, we will not oppose any measures that provide certainty and greater opportunities for growth in that critical sector.

Clause 15 provides the administrative framework for the previous clause and sets out that the higher rate will be available only on expenditure incurred from 1 April for films that commenced principal photography on or after that date. We understand that claims can in turn be made from 1 April 2025, so I would like to ask the Minister about the role of His Majesty’s Revenue and Customs, because we know that the new schemes will need to be properly explained through new guidance and may require new staff, as the Government’s policy paper makes clear. What is HMRC doing to ensure that the guidance remains timely and up to date for those wanting to make a claim? What will HMRC do to support those who want to apply for the credit so that they can understand how it operates? Similarly, what allocation of staff will be made to administer the measure?

[Nigel Huddleston]

I thank the Opposition for their support. I think there is agreement across the House on the vital role of the world-leading UK creative industries, and, in particular, our thriving film sector. In answer to the broad question put by the hon. Member for Ealing North, further information will provided by a statutory instrument that we will discuss in due course. His Majesty’s Revenue and Customs will have a role in that, and the precise resource allocation is an operational decision for it. As the Minister who oversees HMRC, I will pay close attention to the issue and I will ensure that it is properly resourced. This is a very important policy area and we want to ensure that it is successful. Again, I am afraid that I will ask the hon. Gentleman to be a little patient and wait for the details in the statutory instrument, but we are consulting key stakeholders on that.

Question put and agreed to.

Clause 14 accordingly ordered to stand part of the Bill.

Clause 15 ordered to stand part of the Bill.

Clause 16

Increase in theatre tax credit

Question proposed, That the clause stand part of the Bill.

--- Later in debate ---

[James Murray]

As the Minister has set out, from 1 April 2025 the rates of theatre tax relief, orchestra tax relief, and museum and galleries exhibition tax relief will be set permanently at 40% for non-touring productions and 45% for touring productions and all orchestra productions. As we know, the so-called creative reliefs were previously set at 20% and 25% respectively. They were temporarily increased on 27 October 2021 to help the sector in its economic recovery from covid-19. As the Government’s policy paper notes, the rates were due to taper to 30% and 35% from April 2025. We welcome the fact that they will now be set permanently at 40% and 45% from next year.

We also note that, by way of these clauses, the Government are removing the 2026 sunset clause on the museums and galleries exhibition tax relief so that it becomes a permanent relief with no expiry date. In previous debates on earlier Finance Bills, I have asked the Minister to give clarity and certainty to the creative sectors, so I am pleased to say that that has been given to the UK’s world-leading theatres through these clauses. As I have said, we in the Opposition stand wholeheartedly behind the UK’s creative industries, and we will of course not oppose the measures set out today.

[Drew Hendry]

I briefly want to endorse the comments about these sectors requiring support. It is good to see some support for the sectors here, but we would like to see more in the future.

--- Later in debate ---

[Nigel Huddleston]

We have moved forward very quickly today. I thank everybody for their participation: you, Mrs Latham, all the officials in the House, the Clerks, and all those who have been working on the Bill at HMRC, HMT and other Government Departments. I repeat my thanks to the external stakeholders for their comments and to all those who have been involved in consultations. In particular, I thank the Chartered Institute of Taxation, the Institute of Chartered Accountants in England and Wales, and the Low Incomes Tax Reform Group for their contributions to this Committee, including in written form, and all those who have participated today.

I look forward to the Bill progressing smoothly through its final stages. I thank everybody involved.

[James Murray]

I add my thanks to my colleagues in the Opposition: my fellow shadow Minister, my hon. Friend the Member for Hampstead and Kilburn; the Opposition Whip, my hon. Friend the Member for Gower; and, of course, the Back Benchers who have joined us for this lengthy Committee session. [Laughter.] I place on the record my thanks to all the House authorities and to third parties, particularly the Chartered Institute of Taxation, whose expertise is always greatly valued.

[Drew Hendry]

I, too, rise to pass on my thanks: to you, Mrs Latham, for chairing, and to all the staff and others who have been involved. Whether we agree or vehemently disagree—often, as we have seen today, there are big disagreements—we never forget those people who work hard to produce the documentation and supporting information in all the arms of Parliament, including the House of Commons Library. Thank you.

Question put and agreed to.

Bill accordingly to be reported, without amendment.

Finance (No.2) Bill

James Murray Excerpts

3rd reading
Thursday 23rd May 2024 Commons Chamber

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

Madam Deputy Speaker, may I begin by paying tribute to you for your years of service and thank you for your guidance? If I may, I will tell one brief anecdote, which is actually from a previous Finance Bill. I had not quite realised that it was my duty to move the Opposition’s amendments before the time of voting, as I was distracted by being in conversation with my hon. Friend the Member for Hove (Peter Kyle) at the time. The Chamber was full. I think that you cleared your throat three times at me until I finally moved the amendment. On the way out, the right hon. Member for Maidenhead (Mrs May) said to me, “You will never forget that, will you?” It is true—I will not. That was great advice and guidance that will stick with me throughout any future years that I may have in this place, depending on the election. Thank you very much.

We are here to consider the Third Reading of the Finance Bill, which the Opposition hope will be the last in the line of 14 years’ worth of Conservative Finance Bills. The Bill comes after 14 years of Conservative failure on the economy and leaves a legacy of higher taxes, falling living standards and stagnant economic growth. The truth is that whatever the Conservatives say or try to do, whether in the Chamber today or on the campaign trail over the next six weeks, it is too late to repair the damage that they have done to the economy and to people’s standard of living.

I do not think that any of us were expecting to be completing the Bill’s remaining stages in the rushed end of this Parliament. Many of us had assumed that the Prime Minister would call the election later in the year, and I still have not heard why he ultimately decided to call it for July. I have one theory, which is that he realised that prolonging the general election would raise the prospect of there being another Finance Bill in which the Government may have had to legislate to end the non-dom tax status.

Let us face it: the Prime Minister really does not want to get rid of the non-dom tax status. Maybe he thought this was a way to avoid the Conservatives having to keep their promise to end it. I am afraid that he may still be disappointed as, if Labour wins the general election, we will end the non-dom tax status and the new loopholes planned by the Conservatives once and for all. Now that we are to have a general election, perhaps the Conservatives will finally tell us how they will pay for their £46 billion unfunded spending commitment to abolish national insurance altogether. Given their track record, I will not be holding my breath.

The Opposition have tried to amend the Bill during its passage to force the Government to come clean about the impact that their six-year freezing of the income tax personal allowance and the higher rate threshold is having on taxpayers across the country. We have tried to force the Chancellor to set out what impact his and his predecessors’ policies are having on pensioners, and how more of them will pay tax and more of them will have higher tax bills as a result of decisions made by the Conservatives. Alongside the impact on individual taxpayers, we have tried to amend the Bill to encourage the Government to follow our plan to bring back certainty for businesses by capping the rate of corporation tax at 25% for the whole of the next Parliament.

Finally, we sought to give certainty to the oil and gas industry by being clear that our strengthened windfall tax or energy profits levy would end no later than the end of the next Parliament. We were disappointed, though sadly not surprised, that none of our amendments became part of the Bill.

The Opposition will not oppose the Bill’s Third Reading, but let me close by saying two things. First, I pay thanks to the Clerks and the House of Commons staff for all their support throughout the Bill’s passage and to outside organisations, including the Chartered Institute of Taxation in particular, for all their help not just with this Finance Bill, but with all six Finance Bills for which I have been responsible as a shadow Minister. May I also put on record my appreciation for the way in which the Financial Secretary to the Treasury and the Exchequer Secretary to the Treasury have drawn a line between the tough and sometimes barbed exchanges we have in the Chamber and their courtesy and respectfulness outside the Chamber? That is not always the case in politics, but when it happens, I believe that it makes the House of Commons a better place while not for a second compromising on the sharpness of the political questions that we are here rightly to contest.

Ultimately, we are all here to do what is best for our country, and I do not believe that five more years of the Conservatives would serve that goal. Not only have they become defined by chaos and division, and put party before country at every turn, it is also clear that they have done too much damage to the economy. They have squeezed living standards too much, and they have stretched public services to breaking point. I hope that this is the last in a 14-year line of Conservative Finance Bills, because the country needs change. We finally have the chance to ask the British people what Government they want for the next five years. I hope that they will put their trust in our changed Labour party to change our country for the better.