Agricultural and Business Property Reliefs: OBR Costing
James Murray Excerpts(7 months, 3 weeks ago)
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Victoria Atkins (Louth and Horncastle) (Con) (Urgent Question)
To ask the Chancellor of the Exchequer what assessment she has made of the Office for Budget Responsibility’s supplementary forecast information release on the costing of changes to agricultural and business property relief.
The Exchequer Secretary to the Treasury (James Murray)
At the autumn Budget, we took difficult decisions on tax, welfare and spending that were necessary to restore economic stability, fix the public finances and support public services. We had to do that to address the mess we inherited from the previous Government, which the right hon. Member for Louth and Horncastle (Victoria Atkins) will remember well, having served in that ill-fated Government. We have taken these decisions in a way that makes the tax system fairer and more sustainable.
The Government are better targeting agricultural property relief and business property relief to make them fairer. These reforms mean that despite the tough fiscal context, the Government are maintaining very significant levels of relief from inheritance tax beyond what is available to others.
Under the current system, the benefit of the 100% relief on business and agricultural assets is heavily skewed towards the wealthiest estates. According to the latest data from His Majesty’s Revenue and Customs, 40% of agricultural property relief benefits the top 7% of estates making claims. That is just 117 estates claiming £219 million of relief. It is a similar picture for business property relief, with more than 50% of it being claimed by just 4% of estates making claims, which equates to 158 estates claiming £558 million in tax relief. Our reforms mean that individuals can access 100% relief for the first £1 million of combined business and agricultural assets, and 50% thereafter. Given the nil rate bands, this means that a couple can pass on up to £3 million between them to a direct descendant, inheritance tax free.
Yesterday, the Office for Budget Responsibility published further details on the data sources and modelling used to estimate costings across a number of the tax measures announced at Budget, including the reforms to agricultural property relief and business property relief. The costing is the same as published at Budget, and the approach to modelling the costing is typical and in line with other tax policies. As the Government have set out, the reforms mean that almost three quarters of estates claiming APR in 2026-27, including those that also claim BPR, will not pay more inheritance tax. This is a fair approach that protects farms while also fixing the public services we all rely on.
Mr Speaker
I call the shadow Secretary of State for Environment, Food and Rural Affairs.
Victoria Atkins
Having inherited the fastest-growing economy in the G7, the Chancellor’s Budget has led to the highest borrowing costs since the pandemic, growth flatlining, business confidence plummeting and job freezes. Who has Labour chosen to pay the price for its economic illiteracy? Pensioners, family businesses and farmers. For months, farmers, farming businesses, professional advisers and economists, and now eight major supermarkets, have warned the Chancellor that she has got her figures wrong, but Ministers cleave desperately to their soundbites. Let us hope that they listen to the OBR.
Yesterday, the independent OBR released additional information about this particular measure and reiterated the “‘high’ uncertainty” of the predicted yield. It noted that the yield of the measure is likely to be reduced by 35% because of behavioural responses, and that it is unlikely to reach a steady state for 20 years. The OBR also expressed grave concerns about the impact on older individuals and their ability to plan. In short, the reassurances provided by Ministers are falling almost as flat as the economy.
The Chief Secretary to the Treasury has lectured this House about the perils of sidelining the OBR. In light of its analysis, will the Minister now commit to a full and proper review of this dreadful policy? The public have noticed that Government Ministers are failing to answer reasonable questions about their policies, so will the Minister please give straight answers to the farmers and businesses watching our proceedings today?
In light of the new analysis, how many farms does the Treasury think will be affected by the changes to APR, APR/BPR and BPR alone? What assessment has he made of the Central Association of Agricultural Valuers’ finding that the Chancellor has underestimated the number of farms affected by the changes by a factor of five? How many tenant farmers will be evicted? As worrying reports of suicides among farmers begin to emerge, will the Minister please do what the Secretary of State for Environment, Food and Rural Affairs has failed to do and measure the number of suicides over the next 12 months, so that we can understand the human cost of this policy?
Finally, why does the Minister think that Tesco, Sainsbury’s, Asda, Morrisons, Marks & Spencer, Aldi, Lidl and the Co-op have all come out against this tax policy and believe the Treasury’s figures to be wrong? Why does he think they are wrong and he is right?
James Murray
I think there may be some confusion on the Conservative Benches about what the OBR data shows. The data published by the OBR yesterday refers to exactly the same costing as was published at Budget. It sets out the approach to modelling and the costing, which is typical and in line with other tax policies. Indeed, the OBR’s statement makes it clear that:
“The OBR’s role is to provide independent scrutiny and certification of whether the Government’s policy costings are reasonable and central.”
That is exactly what the OBR has done in publishing the extra information, which shows the modelling behind the data that was published at the time of the Budget.
The shadow Secretary of State asked about the data. The data on the number of affected estates claiming APR and, indeed, APR/BPR—some 530 is the upper estimate—is in table 1.1 of the OBR document published yesterday. That is consistent with what we have been saying for many months since the Budget. I think Opposition Members are confusing the value of farms with the value of claims under inheritance tax. The only way to truly understand the impact of changes to inheritance tax policy on inheritance tax claims is to look at the claims data itself.
We are working in partnership with the large supermarket chains to make sure they are driving economic growth. We are very clear that some of the decisions we had to take in the Budget were difficult decisions that will have consequences, but we are determined to work with businesses across the country to drive economic growth, which is the No. 1 mission of this Government.
Chi Onwurah (Newcastle upon Tyne Central and West) (Lab)
The people of Newcastle upon Tyne Central and West love the local produce provided by local farmers in our fantastic markets, such as Grainger market, and they enjoy the beautiful countryside of Northumberland, which has been shaped by generations of sustainable farming. However, we cannot help but be aware that most of that land is owned by, for example, the Duke of Northumberland, big landowners and those seeking to minimise their tax exposure, so does the Minister agree that, by keeping this loophole open for so long, the country has pushed up land prices and pushed out the next generation of young farmers?
James Murray
There certainly is evidence that the current inheritance tax system has caused people to use these reliefs for tax planning and to avoid inheritance tax bills. My hon. Friend alludes to the broader question of the fairness and sustainability of this measure. As I mentioned earlier, 40% of agricultural property relief benefits the top 7% of estates, and 50% of business property relief benefits the top 4% of estates. The Leader of the Opposition has said that she thinks this is a good way to prioritise public money, but we think it is neither fair nor sustainable.
Steve Darling (Torbay) (LD)
After years of the Tories failing our rural communities, including with a dodgy and utterly shameful Australian trade deal, it is a great pity that the new Government have picked up the baton. From Orkney to the Isles of Scilly, Liberal Democrat colleagues are extremely concerned about the impact of these proposals.
The report published yesterday clearly demonstrates the uncertainty about the income from the misguided family farm tax over the next two decades. In the light of this, and given that it will hit older farmers in particular and those who put food on the tables of the United Kingdom, will the Minister do the right thing and scrap this tax?
James Murray
The OBR document published yesterday refers to the level of uncertainty associated with this policy, which is exactly what was set out at the time of the Budget, and it is a typical way in which the OBR responds to new measures. What was published yesterday simply reiterates the OBR’s conclusions from the end of October.
Callum Anderson (Buckingham and Bletchley) (Lab)
Does my hon. Friend agree that, once again, the Conservative party has failed to agree with the tough decisions we have made and has no idea how to raise the revenue to finance the public services that benefit rural communities like mine in north Buckinghamshire?
James Murray
My hon. Friend is absolutely right. The party opposite—in fact, the parties opposite—routinely support the Government’s spending and investment decisions but will not support any of the difficult decisions we have to take to fund them.
Simon Hoare (North Dorset) (Con)
The weight of public and business opinion is not with the Minister on this issue, and the body of expert opinion speaking out against this tax proposal is now overwhelming. The Minister is a kindly man, so I wonder if he will indulge me. What would he be saying if he were in opposition and that weight of opinion was being expressed against a Conservative Government’s Treasury policy?
James Murray
The hon. Gentleman is a kindly man, too. I value the conversations that he and I have had outside the Chamber. People looking at this policy, and all our policies in the Budget, will recognise that we had to take difficult decisions, and will understand the context: our inheritance from the previous Government. We recognise the toughness of those decisions—they were not easy to make—but we prioritise balancing the public finances and economic stability, because that is how we get investment in growth, which our country so badly needs.
Mr Alistair Carmichael (Orkney and Shetland) (LD)
One of the witnesses before the Environment, Food and Rural Affairs Committee told us that the Government’s changes hit the people the Government say they are protecting, and protect the people the Government say they are hitting. It is difficult to improve on that analysis of what is proposed. It really does not have to be like that. There is a sensible debate to be had about reforming inheritance tax to stop the super-rich from sheltering their wealth while still protecting family farms. His Majesty’s Revenue and Customs has its technical consultation coming up. Why does the Minister not agree to broaden its terms, engage with the farming communities, and look for a way to protect family farms and get at those who are sheltering their wealth in land?
James Murray
The policy that we are implementing includes generous provisions to protect family farms—the £1 million entire relief from inheritance tax for agriculture and business property assets. That is in addition to the nil-rate bands that people can access as part of the general inheritance tax scheme. We think that strikes the right balance between making sure we raise money for the public finances and protecting family farms.
Dame Harriett Baldwin (West Worcestershire) (Con)
Mr Speaker, have you noticed a pattern—that on a Thursday, a Treasury Minister will be asked to come to the Commons to answer an urgent question, and there will be barely a soul on the Labour Benches behind them when they do?
Dame Harriett Baldwin
The Office for Budget Responsibility forecasts that the measure will raise £500 million in revenue by 2029, which, in the context of tax revenues of over £1,150 billion, is a very small number. What value does the Minister put on food security for the United Kingdom?
James Murray
Obviously, the Government put the highest priority on food security. That is why our policies set out to support it, and the farming sector more widely. The policy is one of many difficult decisions that we had to take in the Budget to balance the public finances, support public services and provide the economic stability we need for investment and growth.
Sarah Dyke (Glastonbury and Somerton) (LD)
I have heard from many farming businesses across Glastonbury and Somerton over the last few months, but one farm in Hurcot near Somerton recently wrote to me to describe the anguish and stress that the changes to the APR and BPR have caused them. As in the case of many farming businesses, their succession planning has focused on the primary landowner retaining the farm until death. How will the Minister explain to them that according to the OBR, the potential loss of their family farm business is likely to have little impact on the public finances, and that the policy will hit the oldest farmers hardest?
James Murray
The OBR’s publication yesterday sets out the costings that were in the October Budget. There is no difference between the costings set out in October and what the OBR set out yesterday. It simply showed more of the background behind how they calculated those costings, for transparency and so that people are aware. Indeed, it says in the report that that is done in an effort to improve the public debate and ensure that people understand what is behind the data published at the time of the Budget.
As I said to several Opposition Members, clearly this was one of many tough decisions that we took in the Budget to balance the public finances, but we also made sure that there is greater protection from inheritance tax under our proposed reform scheme than is available more widely.
John Lamont (Berwickshire, Roxburgh and Selkirk) (Con)
The Labour Government’s family farm tax will be catastrophic to farmers in my constituency in the Borders. I will join many of them and their tractors in Kelso on Saturday, when the farming community comes together to show its displeasure and disapproval of this policy. Farmers will struggle to pay this tax, so what assessment have the Government made of the policy’s impact on vets, feed merchants, machinery suppliers, and all the other people who support the rural economy?
James Murray
Supporting the rural economy, public services and investment right across the country is part of Labour’s national mission to get the economy growing, but the prerequisite for that investment and economic growth is stable public finances. Without economic stability, we cannot proceed to the investment and growth that we all so desperately need. That is why the decision to target agricultural property relief and business property relief was taken, alongside all the other difficult decisions that we took in the Budget.
Dave Doogan (Angus and Perthshire Glens) (SNP)
This measure is now revealed to be spectacularly ill-considered, leaving aside the fact that it is also a breathtaking betrayal of farmers, who were promised before the election that this would not happen. The measure groups intergenerational farmers with speculative millionaires seeking to dodge tax by getting involved in farming. It has put an immediate brake on investment in farming, which threatens to lower yields and drive up food prices. That then threatens to put inflationary pressures on the UK economy, which is already in a perilous state. This Government cannot just agree with the OBR when it suits them. They must agree with the OBR regardless of what it says. Will the Minister please respectfully pause the measure, take some time to think about this, and come up with something that will actually deliver for the Treasury but not push our family farming sector under.
James Murray
There still seems to be confusion among Opposition Members about what the OBR publication set out. It reiterates the costings that were published at the time of the Budget, on 30 October. It explains how those costings were arrived at, so that people can understand the calculations behind them, but the costings are the same as those published at the time of the Budget.
Jerome Mayhew (Broadland and Fakenham) (Con)
Mr Speaker, if you look at the Register of Members’ Financial Interests, you will see a reference to my family farm in my constituency. Last Sunday, I drove one of our tractors to Fakenham racecourse to support the farmers’ protest against the APR and BPR. I talked to other farmers, and the key complaint was that there had been no consultation on the changes, and no time for older farmers to adjust their affairs. All those concerns have been rubbished by Ministers time and again, most recently today. Now that the OBR confirms that it is more difficult for older people to restructure their affairs quickly, will the Government finally listen, show some humility, and consult on how best to tackle the tax shelterers while still protecting our farmers?
James Murray
The comments in the OBR publication yesterday about older individuals reference a point that has been made since the Budget in debates in this place and elsewhere. We have pointed out that our reform of agricultural property relief and business property relief maintains generous exemptions from inheritance tax; £1 million is subject to relief, and there is the 50% relief beyond that, the existing nil-rate bands, and other exemptions in the system.
Wendy Chamberlain (North East Fife) (LD)
Unusually, in Scotland tenant farms can be passed down as inheritance. I have been asking the Treasury whether it has made an assessment of the impact on such farms, given that their farmers cannot sell land to meet the APR liability that they might face. So far, the answer appears to be that there is no assessment, so I ask the Minister for an answer from the Dispatch Box: is he aware of agricultural tenancies under the Agricultural Holdings (Scotland) Act 1991, and has he made an impact assessment?
James Murray
The way to calculate the impact of changes to inheritance tax policy is to look at the inheritance tax claims that have been made, and that is what we have used as the basis for our calculations. In fact, the OBR publication yesterday confirms that it used HMRC’s data on inheritance tax reliefs in the past and inheritance tax projected forward, and it is on the basis of that data that we designed our policy.
Charlie Dewhirst (Bridlington and The Wolds) (Con)
The Minister has just confirmed that the Treasury’s modelling is based on agricultural property relief and joint agricultural and business property relief claims, yet tax experts have said in evidence to the Environment, Food and Rural Affairs Committee that many family farms will wrap their agricultural land into a single business property relief claim, so the Treasury’s modelling does not take into account family farms that have used a BPR-only claim, tenant farmers who use BPR, and the many rural family businesses that will also use BPR. Will the Minister please take this opportunity to look at this again, before his Government wreck the countryside?
James Murray
As I set out earlier, the need to reform business property relief is as strong as the need to reform agricultural property relief, in order to have stable public finances and a fair and sustainable tax system. As I set out, 40% of APR goes to the top 7% of estates, and 50% of BPR goes to the top 4% of estates. Given the fiscal context that we inherited, that kind of unfairness is not sustainable. When balancing the books, we need to develop the tax system in a way that is sustainable and gives us the economic stability that we desperately need after the mess that the previous Government left us.
John Milne (Horsham) (LD)
Farmers have made their inheritance tax plans in good faith, based on existing rules. In effect, the measure is a retrospective change to tax law, so will the Minister agree to at the very least delay its implementation until the effects are properly understood by both farmers and the Government?
James Murray
The Government are committed to delivering the reforms announced in the Budget. We have carefully considered their impact, and designed the policy to provide generous exemptions from inheritance tax for small family farms and businesses, while ensuring that we balance the public finances as fairly as possible.
Harriet Cross (Gordon and Buchan) (Con)
In the light of the uncertainty in the OBR’s report; the fact that the policy will hit elderly farmers the hardest and put food security at risk; and the fact that rural communities will suffer the most, given the impact on tenants and young farmers, and the wider agricultural sector, does the Minister really still believe in this policy?
James Murray
The OBR’s allusion yesterday to a degree of uncertainty is exactly the same as what it said at the time of the Budget. The costing is exactly the same as what it published at the time of the Budget. Yesterday, the OBR published more information about how the costing was arrived at, but the costing itself, the degree of uncertainty and the calculations remain exactly the same as at the time of the Budget.
Richard Tice (Boston and Skegness) (Reform)
The Minister just mentioned balancing the public finances—those are the key words—through these measures. We have just had the debt figures for December, which are 20% higher than the OBR expected them to be just two months previously. At what point will the Minister and the Government recognise that they have got this badly wrong and change course?
James Murray
We recognise that when the Conservative party was in government, it got it badly wrong. The country decided to change course, which is why they elected us into government to fix the public finances, put our public services back on their feet, boost investment and get the economy growing.
Lincoln Jopp (Spelthorne) (Con)
They say that one ought to build one’s enemy a golden bridge. I think the compromise and pause proposed by the National Farmers Union is an elegant solution. That golden bridge is now being signposted by Tesco, Aldi, Lidl, the Co-op, and all the major retailers the Minister claims to be engaging with. Why does he not just pause, go back, listen, and review the policy?
James Murray
As I set out in answer to a previous question, the Government are committed to delivering the reforms announced in the Budget. They were carefully calibrated to retain generous inheritance tax exemptions, while ensuring that we balance the public finances as fairly as possible.
Max Wilkinson (Cheltenham) (LD)
Bence Builders Merchants in my constituency has been providing good local produce and good local jobs since the Earl of Aberdeen was in power. The owner, Paul Bence, fears that the combination of business property relief changes and changes to employer’s national insurance mean that there is a huge disincentive to invest further. Does the Minister share my constituent’s concern?
James Murray
I thank the hon. Gentleman for raising his constituent’s concern. I do not know the specifics of the case, but more broadly, investment decisions depend above all else on a stable economy and stable public finances. Without the hard work that we have done since taking office to fix the public finances and bring back economic stability, investment would be hampered, and our growth ambitions would not materialise in the way that we are determined to ensure happens.
John Cooper (Dumfries and Galloway) (Con)
There will be a rally on Saturday, and the Minister appears to imagine that this indicates acclamation for his policy. We heard earlier in the week from the hon. Member for Falkirk (Euan Stainbank) and today from the hon. Member for Newcastle upon Tyne Central and West (Chi Onwurah)—both well-known rural areas—that this is all about the landed estates and wealthy people, but I can assure the Minister that the farmers I will speak with in Castle Douglas on Saturday are tenant farmers and family farmers, and they face being put off the land after generations. Is he really suggesting that I should tell them they have nothing to worry about?
James Murray
I am not going to tell the hon. Gentleman what he should say to his constituents, but what I can tell him about the Government’s policy is that we have reserved generous inheritance tax reliefs for people in the situations he describes. I encourage anyone who is concerned to seek advice, to understand exactly how the new rules might apply to them.
Jim Shannon (Strangford) (DUP)
Sometimes I am absolutely flummoxed—we probably all are—by the Chancellor’s intent to tax working family farms, which we all know will result in the loss of small farms, the sale of the land and a reduction in food security. Now it seems that the OBR agrees that it will not make savings. Will the Minister commit to meeting Cabinet colleagues urgently to remove the sword of Damocles that is hanging above small family farms and hurting the agrifood sector as a whole? I say to the Minister that there is a way forward: increase the threshold from £1 million to £5 million, and family farms will be saved.
James Murray
I thank the hon. Gentleman for his question, but I think it was based primary on the OBR publication yesterday. I reiterate the point I have made several times now: that OBR publication reiterated the costings and figures set out at the Budget, it reiterated the level of uncertainty associated with the measure, as published at the Budget, it provides more detail behind that, but the conclusion is the same as it was on 30 October.
Mr Carmichael
On a point of order, Mr Speaker. Before questioning the Minister, I should have reminded the House of my entry in the Register of Members’ Financial Interests. My failure to do so, for which I apologise, was inadvertent—I just got carried away with the excitement of the moment.
Oral Answers to Questions
James Murray Excerpts(7 months, 3 weeks ago)
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Antonia Bance (Tipton and Wednesbury) (Lab)
The Exchequer Secretary to the Treasury (James Murray)
The UK carbon border adjustment mechanism will be introduced in 2027. It will ensure that imports face a carbon price that is comparable with domestic products, giving UK industry the confidence to invest without its decarbonisation efforts being undermined. UK steel producers will continue to benefit from high levels of free allowances in the UK emissions trading system until at least the end of 2026, protecting them against carbon leakage via high-emission imports.
Antonia Bance
Newby Foundries and Alucast in my constituency of Tipton, Wednesbury and Coseley have raised with me the impact of the UK CBAM coming into effect later than, and differing from, the EU CBAM. This could threaten domestic steel production and make the export of metal products to the EU more difficult. Can the Minister please support the UK’s steel and metal finishing industries by reassuring me that the UK CBAM will not be weaker than the EU CBAM, and will he meet me and other steel MPs to discuss this?
James Murray
As I have set out, the UK CBAM will mitigate the risk of carbon leakage by placing a carbon price on some of the most emissions-intensive industrial goods imported into the UK, including in the iron and steel sector. The UK CBAM is designed for the UK context, and in some areas, its emissions scope is wider than the EU CBAM—in respect of indirect emissions, for instance. The first CBAM industry working group was held earlier this week, and I understand that a representative of the UK steel sector attended. I will make sure that my officials continue to engage with the industry sectors most affected, and I am very happy to discuss this further with my hon. Friend.
Sir Gavin Williamson (Stone, Great Wyrley and Penkridge) (Con)
Heavy industry, whether it is steel, ceramics or so many other areas, is totally dependent on low energy costs. The trajectory is that energy costs are rising, especially in industry, whether as a result of regulation or world markets. Many other countries are doing more to protect their heavy industries by making sure they can have low input costs for energy. What more can the Minister do to protect our heavy industry in the future?
James Murray
The No. 1 thing for industry and households is to bring down the cost of energy. That is why we are investing in renewable home-grown energy for the future, to make sure we have energy independence, energy security and, crucially, lower bills for those households and businesses.
Steve Darling (Torbay) (LD)
The Exchequer Secretary to the Treasury (James Murray)
The Government announced a range of measures at the autumn Budget to support SMEs, including in the retail, hospitality and leisure sectors. They include more than doubling the employment allowance, freezing the small business rates multiplier, extending RHL relief to 40%, maintaining the small profits rate and reducing the duty on qualifying draught products, which represent 60% of alcoholic drinks sold in pubs.
Bobby Dean
The Labour manifesto committed to replacing the business rates system. However, last week at the Treasury Committee, the Minister seemed to rule out the kind of comprehensive reform that the Liberal Democrats and others have been campaigning for, and indicated that there might only be a tinkering around the edges of rates and reliefs. Can the Minister confirm today whether the Government still intend to replace the business rates system, or will they just be tinkering around the edges of this broken system?
James Murray
I think that retail, hospitality and leisure businesses, which are the backbone of our high street, might object to the idea of permanently lower tax rates as “tinkering around the edges”. That is a fundamental change that we want to bring in from April 2026 to make sure they have stability, certainty and permanently lower rates. Alongside it are our wider ambitions in the “Transforming Business Rates” discussion paper, which I invited the hon. Gentleman to read and respond to at last week’s Treasury Committee.
Michael Wheeler
I draw Members’ attention to my declaration in the register of interests.
Retail is an important part of the economy in my constituency, which includes many wonderful independent businesses. Will, who runs the excellent Wandering Palate in Monton, wrote to me about the challenges he is facing. Will the Minister outline the measures the Government are taking to support small business owners like Will in my constituency and across the country to enable our high streets to thrive?
James Murray
I thank my hon. Friend for his question and for referencing Wonderful Palate, the business in his constituency. I do not know the details of the rateable value of that property, but I point the owner to the fact that we are retaining small business rate relief, freezing the small business multiplier next year and extending the retail, hospitality and leisure relief in 2025-26. I also point the owner of that business and other businesses to our future plan, as I mentioned, to have permanently lower tax rates for retail, hospitality and leisure businesses with values of below £500,000, as well as to consider reforms to small business rate relief to better support businesses that want to expand into a second premises.
Steve Darling
What consideration have Ministers given to exempting the seasonal tourism industry from the national insurance hikes set to kick in this summer? That would benefit Paignton zoo and Splashdown in the Torbay constituency.
James Murray
We set out the details of our decision to increase the rate of national insurance contributions from employers and to reduce the threshold, and we have added the different benefit we will give, particularly to small businesses and charities, by more than doubling the employment allowance. The employer national insurance contribution changes were among the toughest we took in the Budget, but they were necessary to repair the public finances and deliver the economic stability that is so crucial for investment and growth.
Mr Speaker
We have had the former Chair of the Treasury Committee, so let’s now have the current Chair.
Dame Meg Hillier (Hackney South and Shoreditch) (Lab/Co-op)
My hon. Friend the Exchequer Secretary rightly said that small and medium-sized enterprises are a vital part of our high streets and our economy, and one of the biggest changes is, of course, the change to business rates. He was not tempted at the Select Committee last week to give more detail on the timeframe for that, but many businesses want certainty about business rates as they go forward. May I tempt him to give an indication of the Government’s thinking about how quickly this change might be introduced and whether the small business rate relief is likely to survive or to be subsumed into a new regime?
James Murray
I thank the Chair of the Select Committee for her questions. If she did not succeed in tempting me at the Select Committee, I doubt she will succeed today, but I can reassure her that the decisions we have set out about introducing the permanently lower business rate for RHL—retail, hospitality and leisure—properties below a £500,000 rateable value will be coming in from April 2026. Specifically in relation to small business rate relief, I can confirm that the Government are committed to retaining that. One of the options we are looking at in our “Transforming business rates” discussion paper is how to support businesses that want to expand into a second premises, thereby growing the business, because at the moment there is the cliff edge where they lose small business rate relief.
Richard Fuller (North Bedfordshire) (Con)
Confidence on Britain’s high streets is sliding faster than the Chancellor will be down the ski slopes of Davos later today. With retail sales down—rather than up, as expected in the run-up to Christmas—and with the British Retail Consortium saying that two thirds of stores will raise prices to cover her national insurance increases, when will the Minister accept that the Chancellor’s economic strategy of raising taxes and increasing regulations is not working?
James Murray
I am glad to know that the shadow Minister’s morning was well spent cooking up that line about the Davos ski slopes. What he will know, and what sectors across the economy will know, is that having a stable economy is a prerequisite for the investment we need to get the economy growing. That is why we had to take difficult decisions at the autumn Budget, including those to increase the rate of employer national insurance contributions. Alongside that increase, however, we more than doubled the employment allowance and set out our plans to have permanently lower tax rates for high street RHL properties from April 2026.
Daisy Cooper (St Albans) (LD)
A number of small high street businesses will be hit hard by the Government’s jobs tax and the dramatic reduction in business rates relief, and House of Commons Library research that I commissioned shows that from April 2026 the Government’s reforms to business rates could leave small and independent businesses in effect subsidising the big chains. Will the Chancellor meet me and a delegation of small and independent businesses from St Albans so that we can make the case for fairer reforms and for wholesale reform of the broken business rates system?
James Murray
One of the problems with the Liberal Democrats is that they support all our spending plans, but they do not support any of the tax changes to fund them. This is a prime example. When we talk about increasing employer national insurance contributions, we acknowledge that that was one of the toughest decisions we took at the Budget, but it was necessary to fix the public finances and provide support for those public services, which I note the Liberal Democrats are very keen to support.
Frank McNally (Coatbridge and Bellshill) (Lab)
Olly Glover (Didcot and Wantage) (LD)
The Exchequer Secretary to the Treasury (James Murray)
During the passage of the National Insurance Contributions (Secondary Class 1 Contributions) Bill, we set out clearly how the scheme would work to reimburse costs for public departments or local government. That measure is in line with what the previous Government attempted to do with the health and social care levy. Where third-party private contractors are engaged, those costs will be considered by local government or other public sector organisations in the round.
Brian Leishman (Alloa and Grangemouth) (Lab)
Mr Speaker
Order. Mr Lowe, topical questions are meant to be short and punchy. I am sure that you are very good at that normally.
James Murray
One of my key priorities as Exchequer Secretary and the Minister with responsibility for HMRC is to oversee a programme of transformation at HMRC to improve its customer service, to digitise the service, to close the tax gap and to ensure that we have the modern, reformed service that we need for the future.
Steve Witherden (Montgomeryshire and Glyndŵr) (Lab)
James Murray
As my hon. Friend set out, decisions on eligibility for covid-19 financial support were taken by the previous Government. The current Government have no plans to assess the financial compensation scheme, but the covid-19 inquiry has recently launched its module to investigate the economic response to the pandemic. The Government are committed to learning from its findings.
Sir Edward Leigh (Gainsborough) (Con)
When I visited St Barnabas hospice in Lincoln recently, the chief executive told me that it was having to pay £350,000 extra every year to cover the national insurance increase. I do not expect an answer now, but as we all agree that palliative care is so important and we want to encourage it, and the Terminally Ill Adults (End of Life) Bill started its Committee stage today, will the Government keep that increase for hospices under review?
James Murray
We have been clear since the Budget that the decision to raise employer national insurance contributions was one of the toughest we have taken as a Government, and we recognise that it has consequences for businesses. However, we think all businesses will benefit in future from the economic stability that this decision will bring; it will drive investment and growth across the country.
Chris McDonald (Stockton North) (Lab)
James Murray
What we accept is that the difficult decisions we took at the Budget enabled extra funding to be put into the NHS. GP surgeries have had a funding settlement that considers all the pressures on them in the round.
Sonia Kumar (Dudley) (Lab)
My constituency has a proud industrial heritage, with manufacturing still worth £1 billion a year to the local economy from sectors that account for nearly 10% of the UK’s total economic output. What steps have the Government taken to promote the growth of the manufacturing sector and ensure that towns like Dudley continue to build on their industrial traditions?
Agricultural and Business Property Relief
James Murray Excerpts(8 months ago)
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The Exchequer Secretary to the Treasury (James Murray)
It is a pleasure to speak in this debate with you as Chair, Dr Allin-Khan. I congratulate the right hon. Member for Beverley and Holderness (Graham Stuart) on securing this debate. Likewise, he is always thoughtful in his contributions, so I am always glad to hear from him and indeed the interventions that he allowed during his speech.
I know hon. Members have raised questions about the reforms that we are making, and I will try to address as many of them as I can. However, let me start by briefly reminding hon. Members of the economic context in which the decisions were taken. At the autumn Budget, we took difficult but necessary decisions on tax, welfare and spending
to restore economic stability, fix the public finances and support public services, as a result of the situation that we inherited from the previous Administration. We took those tough decisions in a way that will make the tax system fairer and more sustainable. The decision to reform agricultural property relief and business property relief was not taken lightly. The reforms mean that, despite the tough fiscal context, the Government will maintain significant levels of relief from inheritance tax, beyond what is available to others.
Richard Foord
I do not question the Minister’s difficult inheritance, but the Labour party adviser Dan Neidle suggests that the plan to slap inheritance tax on farms worth more than £1 million should be replaced with a much higher threshold with a clawback mechanism, perhaps for land over £20 million that is sold. That would tackle the Dysons of the world without affecting small family farms. What does the Minister think of that proposal?
James Murray
I am just about to come on to the details of the reforms that we have made to agricultural property relief and business property relief. If the hon. Gentleman waits a moment, he will see some of the reasoning behind the decisions that we took.
The Government recognise the role that the reliefs play, particularly in supporting farms and small businesses, and under our reforms that will continue. The case for reform is underlined by the fact that the full unlimited exemption, which was introduced in 1992, had become unsustainable. Under the current system, the benefit of the 100% relief on business and agricultural assets has become heavily skewed towards the wealthiest estates. According to the latest data from HMRC, 40% of agricultural property relief benefits the top 7% of estates making claims. That is 117 estates claiming £219 million of relief.
It is a similar picture for business property relief. More than 50% of business property relief is claimed by just 4% of estates making claims. That equates to 158 estates claiming £558 million in tax relief.
James Murray
I have only a few moments, so I will make progress.
The Leader of the Opposition has made it clear that she would prioritise that tax break within the public finances, but we do not believe it is fair or sustainable to maintain such a large tax break for such a small number of the wealthiest claimants, given the wider pressures on the public finances. It is for those reasons that the Government are changing how we target agricultural property relief and business property relief from April 2026. We are doing so in a way that maintains a significant tax relief for estates, including for small farms and businesses, while repairing the public finances fairly.
Let me be clear that individuals will still benefit from 100% relief for the first £1 million of combined business and agricultural assets. On top of that, as we know, there will be a 50% relief, which means that inheritance tax will be paid at a reduced effective rate of up to 20%, rather than the standard 40%. Importantly, those reliefs sit on top of the existing spousal exemptions and nil-rate bands. Depending on individual circumstances, a couple can pass on up to £3 million to their children or grandchildren free of inheritance tax.
Harriet Cross
At the Oxford farming conference, the Secretary of State suggested that farms should diversify to be more profitable, but diversification has become a lot less incentivised because that all gets wrapped up into the BPR, as well as the APR. Does that not completely negate the Secretary of State’s argument for diversification if it will all be taken away in tax?
James Murray
My right hon. Friend the Secretary of State made an important point about diversification, but whatever category the assets fall into, a couple can pass on up to £3 million to their children or grandchildren free of inheritance tax; that applies across agricultural and business property relief. The point I was making is that the agricultural and business property relief sit on top of the existing transfers and nil-rate bands, so when considering individual circumstances, we must look at the details of the situation that an individual or couple face.
I have a minute left, so I will be brief. Some hon. Members questioned the statistics about how many estates will be affected. We are very clear—we have published the data, and the Chancellor has written to the Treasury Committee about it—that up to 520 estates claiming agricultural property relief, including those claiming business property relief too, will be affected by these reforms to some degree. That means that about three quarters of estates claiming agricultural property relief, including those also claiming business property relief, will not pay any more tax as a result of these changes in the year they are introduced. All estates making claims through these reliefs will continue to receive generous support at a total cost of £1.1 billion to the Exchequer. The Office for Budget Responsibility has been clear that it does not expect this measure to have any significant macroeconomic impacts.
I thank all hon. Members who have contributed today, and I am grateful to the right hon. Member for Beverley and Holderness for securing this debate.
Motion lapsed (Standing Order No. 10(6)).
Debt Advice Services
James Murray Excerpts(8 months ago)
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The Exchequer Secretary to the Treasury (James Murray)
I congratulate my hon. Friend the Member for Walthamstow (Ms Creasy) on securing the debate. I very much recognise and have seen the work she has done over the years to raise the profile of responsible consumer credit practices and effective debt advice. I thank my hon. Friend the Member for Congleton (Mrs Russell) for her contribution and specifically for raising the experience of her constituents.
Credit, when offered responsibly, can be an essential tool for people who have to manage unexpected costs or who need to smooth their cash flow. As a Government, we want to support consumers in having access to credit when they need it. But, at the same time, we are determined to ensure that access to credit comes with robust protections to ensure that lending is affordable and consumers are protected when things go wrong. That is why in October last year we published a consultation on a proposed regulatory regime for “buy now, pay later” products. The regime will introduce better protections for millions of consumers and will bring “buy now, pay later” firms into the regulatory perimeter of the FCA. That in turn will mean that firms offering “buy now, pay later” products will be required to pay specific annual FCA fees and levies. Among those is the financial guidance levy, the proceeds of which fund free debt advice services.
As I turn to the importance of debt advice, I pay tribute to the thousands of debt advisers across the country for the critical work they do to provide support for those in need.
Ms Creasy
We all value the debt advisers. As my hon. Friend has just said, “buy now, pay later” companies do not yet contribute to the levy that pays for those people, but the companies themselves have said that they would make voluntary contributions. Would the Treasury consider approaching them to get that money ahead of their being part of the regulatory landscape, so that we can have more of these brilliant debt advisers?
James Murray
I am sure that Treasury officials and the Economic Secretary to the Treasury, my hon. Friend the Member for Hampstead and Highgate (Tulip Siddiq), will be in close contact with the sector about any proposals they have. It is important to emphasise that because of the regulations we are consulting on for the new regime, that will mean that “buy now, pay later” firms will be required to pay those specific fees and levies, which will help fund free debt advice services. We know that funding those services is important because intervention through debt advice services not only prevents financial difficulties from escalating, but protects people’s overall mental health and wellbeing. More widely, there are positive effects for families, communities and the economy at large.
As a new Government, we are committed to supporting national and community-based services through the Money and Pensions Service, or MAPS as it is commonly known. Those services provide advice to hundreds of thousands of individuals and families in need in England. In December, MAPS published its first debt advice impacts report, which showed that across 2023-24 people accessing debt advice through MAPS-funded services gained an estimated £48 million of extra income. That underlines the fact that for many people, advice not only allows them to deal with their debt problems, but helps them to find a way forward with more money in their pockets. Eighty-seven per cent of people who received MAPS-funded debt advice said they would recommend the service to someone in a similar situation.
Outside of England, the UK Government provide funding through the financial services levy to the devolved Governments in Scotland, Wales and Northern Ireland. As debt advice is a devolved matter, the devolved Governments have responsibility for delivering those services within their nations and for tailoring provision to the needs of their local communities.
My hon. Friends spoke about the gap between those who need debt advice and those who are currently accessing it. The Government recognise that gap and the need to tackle it. Funding levels, which my hon. Friends mentioned, are regularly reviewed to reflect demand, inflation and evolving needs. The MAPS debt advice budget for the upcoming financial year will be communicated in the usual way in the spring, and I will ensure that my hon. Friends are informed.
My hon. Friend the Member for Walthamstow mentioned the MAPS consultation last year on the future of its debt advice commissioning strategy. MAPS published its response to that consultation in October, setting out its commitment to increasing debt adviser wellbeing, further building advisers’ skills and delivering digital transformation across the debt advice sector. As part of its efforts to address unmet demand for debt advice, MAPS has also launched its debt advice modernisation fund, a grant initiative designed to support projects aimed at enhancing and modernising debt advice services in the not-for-profit sector. Projects are currently under way and will be completed by the end of March.
My hon. Friends touched on the wider issue of financial inclusion. I assure them that the Government are taking further steps to ensure that individuals can access the financial services they need.
Warinder Juss (Wolverhampton West) (Lab)
In my constituency, the Whitmore Reans Welfare Centre, a voluntary organisation, signposts individuals to the debt advice that they need. In the past, the centre received funding for a part-time or full-time caseworker, but it is finding it increasingly difficult to provide the kind of one-to-one advice mentioned earlier, which is so useful for residents. Can the Minister give any advice on how to help organisations of that nature so that constituents can be signposted to, and given, one-to-one advice?
James Murray
I thank my hon. Friend for raising that constituency case and highlighting the important work that that organisation does for his constituents. I cannot comment from the Dispatch Box on individual funding decisions, but he underlines the importance of tailoring to local need. Although there may be a national priority to ensure that people are provided with debt advice, individual local debt advice agencies will need to tailor their services to the needs of their communities. He is an excellent advocate for his constituents in that regard.
Alongside the debt advice services that the debate has focused on, it is important, as I was saying, that individuals can access the financial services that they need. That is why the Government announced in December our intention to develop a financial inclusion strategy that will aim to further tackle barriers to individual and household ability to access affordable and appropriate financial products and services. The strategy will be supported by a committee that the Economic Secretary to the Treasury convened for the first time in December, which will consider the problem of debt.
I will turn my attention briefly to the work that the Government are doing to support vulnerable individuals and businesses repaying debt to the public sector. The Government debt management function functional centre, based in the Treasury, convenes the debt fairness group—a collaboration with the debt advice sector that identifies opportunities to continuously improve public sector debt recovery processes. The functional centre’s work includes debt management toolkits to support public sector bodies dealing with those facing physical and mental health challenges, and to help them identify and support the 8.7 million adults in the UK who have experienced economic abuse.
I thank my hon. Friend the Member for Walthamstow once again for raising this important matter. I have no doubt that she will continue to be a champion on the issues that we have discussed. The Government remain committed to providing accessible debt advice and promoting financial inclusion. We are committed to ensuring that everyone has the support they need to manage their finances effectively and build a more secure future for themselves and their family.
Question put and agreed to.
Crown Estate Bill [Lords]
James Murray ExcerptsTuesday 7th January 2025
(8 months, 1 week ago)
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The Exchequer Secretary to the Treasury (James Murray)
It is a pleasure to close this debate on the Crown Estate. May I wish you, Madam Deputy Speaker, a happy new year?
I am grateful to the shadow Minister for his comments today, as well as for the contributions of all my hon. Friends. I am particularly grateful for the Opposition’s support for the Bill in general, which they display by their absence this afternoon. I welcome the questions set out by the shadow Minister and I will go through some of those in my remarks.
As the Chief Secretary to the Treasury noted in his opening speech, the purpose of the Bill is to bring the legislation governing the Crown Estate into the 21st century by making a targeted and measured enhancement to its powers and governance. Without the Bill, the Crown Estate would continue to be restricted in its ability to compete and invest and would therefore be limited in its ability to deliver returns to the public purse. The Bill therefore broadens the scope of the activities that the Crown Estate can engage in, enabling it to further invest in the energy transition that we know is so crucial. It empowers the Crown Estate to invest in capital-intensive projects more effectively and, critically, the measures will unlock more long-term investment, increasing the contribution that the Crown Estate can make to creating high-quality jobs and driving growth across the UK.
I turn to some of the points raised in the debate. I appreciate the shadow Minister’s broad support for the Bill’s aim. On his specific question about the Crown Estate’s borrowing powers, the Bill is clear that any borrowing undertaken by the Crown Estate can only be from the Treasury or otherwise with Treasury consent. The Treasury will, of course, ensure that any borrowing is consistent with our fiscal rules. There will, as has been noted, be a memorandum of understanding in place between the Treasury and the Crown Estate, and that will govern how borrowing powers will be exercised. As with any public sector borrowing, the Treasury will ensure that that is consistent with managing public money principles to ensure value for money for the taxpayer.
The shadow Minister also asked specific questions about commissioners’ pre-appointment scrutiny. I want to set out for him how the appointment of other commissioners is likely to work. The Crown Estate commissioners who manage the Crown Estate are appointed by His Majesty on the recommendation of Ministers. The appointment process is governed by the code for public appointments. The reforms in the Bill will not alter the fundamental statutory basis of the Crown Estate, which is as a commercial business that is independent of government, operates for profit, competes in the marketplace and needs to recruit the highest quality talent to its board of commissioners. Within that context, it would not be appropriate for either the Government or Parliament to place further requirements on the recruitment process.
The shadow Minister also asked about chief executive pay. The details of a chief executive’s remuneration are a matter for the Crown Estate board, which is operationally independent of government, as I set out. As the Crown Estate is statutorily an independent, commercial organisation, which returns hundreds of millions of pounds in profit to the Exchequer every year, continuing the success is crucial and it requires the organisation to have the freedom to compete for the top talent in the commercial world.
We know that cheap executive remuneration in this context is set at the lower end of the private sector peer group, which is agreed with the Treasury. The majority of the package is in fact conditional on performance, which ensures that the chief executive rewards are heavily dependent on delivering long-term value to the Exchequer. The shadow Minister also asked about governance when it comes to the Crown Estate and Great British Energy. I can set out to him the operational matters in regard to the partnership, but they will be determined in their final detail by the passing of the great British Energy Bill, which is currently going through Parliament. Once it completes all its legislative stages, the partnership will be subject to an agreement between the Crown Estate and Great British Energy. Although the partnership agreement itself will not be published, given that it will be commercially sensitive, the Crown Estate has committed to publish information relating to the partnership as part of its existing annual report. This will include a report on the activities of the commissioners under that partnership and any effects or benefits resulting from the activities of the commissioners that entails.
The shadow Minister asked a specific question about the amendment on the seabed, which was debated in the other place by Lord Livermore. As hon. Members may know, on Report of the Crown Estate Bill in the Lords, the Financial Secretary to the Treasury committed to bring forward an amendment, if it were needed, to restrict the ability of the Crown Estate to sell the seabed. That was in response to concerns from peers that the seabed, which is owned by the Crown Estate, is a unique asset and therefore special protections may be warranted. As the Financial Secretary noted at the time, the law on the ownership of the seabed is complex, so officials are working with the Crown Estate to establish the extent to which the Crown Estate can currently sell the seabed. If it is established that further legislation is required to restrict the ability of the Crown Estate to sell the seabed, we will look to bring forward an amendment at Committee stage.
Finally, the shadow Minister mentioned the measures on salmon that were inserted in the Bill in the other place. There is a fundamental question about whether the Bill is an appropriate vehicle for a debate about the rights of salmon and protecting animal rights in that context. In England, Wales and Northern England, to which the Bill applies, there is on Crown Estate-owned land only one relevant area—one relevant salmon farm. The issue really relates more widely to Scotland, which is governed by Crown Estate Scotland and not by the provisions in this Bill. We know that fisheries policy is the responsibility of devolved Government in Scotland. All fish farming in England is regulated with the intention to ensure that it is carried out in a responsible manner. Given that virtually all salmon aquaculture in the UK takes place in Scotland, the matter is really one for a different debate.
As well as the comments from the shadow Minister, we also heard from the Liberal Democrat spokesperson, the hon. Member for South Cambridgeshire (Pippa Heylings). Many points that she raised have been covered in what I have said so far, although she raised an additional point that aligned with comments by the right hon. Member for Orkney and Shetland (Mr Carmichael) about how the Crown Estate will balance the expansion of offshore renewables with the needs of the fishing industry, marine wildlife and so on. I wish to set out briefly the Government’s position on that matter. We know that the Crown Estate is committed to sustainable management of the seabed and, where appropriate, it collaborates with industry stakeholders, marine licence bodies and environmental non-governmental organisations to ensure that activities on the seabed are conducted responsibly.
As with any developer, the proposals of the Crown Estate go through a standard planning application process, which includes the relevant environmental assessments. Under the Crown Estate strategy, it has an objective to take a leading role in stewarding the natural environment and biodiversity. Key to delivering that aim is managing the seabed in a way that reduces pressure on, and accelerates the recovery of, our marine environment. The Bill will not directly impact on how much commercial fishing takes place in areas managed by the Crown Estate.
My hon. Friend the Member for Reading Central (Matt Rodda) raised an important point around grid connections and grid connectivity, which are vital to ensuring that our plans to move towards clean energy are effective. His points were important as part of the connection between the Crown Estate and Great British Energy, which we have been talking about during the debate. One benefit of the Crown Estate working with Great British Energy is that they can work together to speed up the process of developing clean energy projects, including co-ordinating planning requirements and grid connections, as well as leasing land to de-risk and speed up projects so that private developers can get on and build them. That will be crucial to unlocking the private investment and speeding up the deployment of clean energy infrastructure. As well as de-risking private sector investments, GB Energy and the Crown Estate will directly co-invest in clean energy infrastructure. That will include floating offshore wind and carbon capture projects.
Several of my hon. Friends made important points around local community benefits and supply chains. I thank in particular my hon. Friends the Members for Mid and South Pembrokeshire (Henry Tufnell), for Truro and Falmouth (Jayne Kirkham) and for Camborne and Redruth (Perran Moon) and the hon. Member for Inverness, Skye and West Ross-shire (Mr MacDonald). They all focused on the importance of community benefits, local supply chains and investment in jobs and skills. My hon. Friend the Member for Great Grimsby and Cleethorpes (Melanie Onn) made a helpful set of points around the importance of long-term community benefit—that is, people who are not just building infrastructure, making a one-off payment and then leaving, but actually making a long-term investment in the area and the people who live there. She referred to Projekt Renewable in her constituency, and it would be interesting to discuss that with her after the debate.
Looking more broadly at what the Crown Estate has been doing and intends to do on investing in local community benefit, it is committed to working with local communities and partners to enable employment and skills opportunities. For example, it has allocated £50 million through the supply chain accelerator to stimulate green jobs. It is also developing a green skills pipeline from a GCSE in engineering skills for offshore wind, seed-funded by the Crown Estate and developed with Cornwall college, to a post-16 destination renewables course with Pembrokeshire college. The Crown Estate is partnering with the employment charity Workwhile to create green construction apprenticeships.
On offshore wind specifically, the Crown Estate has worked on upskilling frontline Department for Work and Pensions work coaches to be well equipped to support job seekers in the offshore wind industry through the offshore wind learning programme and specifically in relation to offshore leasing round 5, which hon. Members have mentioned. The Crown Estate has designed the leasing process in such a way that developers have to make commitments to deliver social and environmental value as part of the development of new wind farms, including a requirement to provide an apprenticeships plan and a skills development plan.
The Crown Estate is also committed to working with communities to ensure that future generations can make the most of the opportunities that marine energy will bring. It is working closely with local educational institutions, such as Falmouth marine school, where it helped develop a pre-16 engineering programme to build skilled local workforces, alongside other initiatives, including the marine internship programme and a recent partnership with the Sea Ranger Service, which is based in Port Talbot.
We heard from the hon. Member for Ynys Môn (Llinos Medi), who asked questions about the devolution of the Crown Estate and its functions to Wales. Some of the points she raised were addressed by my hon. Friends, but it is important to recognise that the proposed powers in the Bill will be of huge benefit to Wales. Combined with its existing scale, expertise and track record, the Crown Estate is uniquely placed to help drive the activities required, such as de-risking and developing offshore renewable energy and other emerging offshore technologies to realise the potential of the Celtic sea. I would be concerned that further devolution of the Crown Estate in the manner suggested could fragment the renewable energy market and undermine the strong international investor confidence in the UK to the detriment of both Wales and the wider UK. It would risk creating further complexity and delay our drive for energy security and net zero at a time when simplicity and accelerated deployment are essential. That is why the Government believe that the existing provisions are the best way to ensure that the assets of the Crown Estate are managed most effectively to benefit people across Wales, England and Northern Ireland.
The hon. and learned Member for North Antrim (Jim Allister) spoke of his concern about environmental impacts. Offshore wind is essential to meeting our net zero and energy security objectives, which I hope he supports, but to get the wider balance right, the habitat regulations assessment process ensures that we can deliver our offshore wind requirements while maintaining environmental protections. The Government are also consulting on revisions to the national planning policy framework to increase support for renewable energy schemes in order to tackle climate change while safeguarding environmental resources.
I thank my hon. Friends the Member for Lichfield (Dave Robertson) and for York Outer (Mr Charters) for their particularly impassioned support for the principles behind the Bill and what it sets out to achieve. As my hon. Friend the Member for Lichfield said, it is crucial for investment, growth and modernising the Crown Estate for the 21st century. My hon. Friend the Member for York Outer focused on the power of the Bill’s measured reforms to modernise the Crown Estate and support growth in a fiscally responsible way while generating revenue that will benefit our constituents across the country.
I hope that I have managed to address hon. Members’ points. As my right hon. Friend the Chief Secretary to the Treasury and I have set out, the Bill delivers a targeted and measured enhancement to the Crown Estate’s powers and governance, thereby modernising it for the 21st century. It broadens the scope of activities that the Crown Estate can engage in, enables it to further invest in the energy transition, and empowers it to invest more effectively in capital-intensive projects. Critically, the measures in it will unlock more long-term investment and increase the contribution of the Crown Estate to generating high-quality jobs and driving growth across the UK. Growth is at the heart of our Government’s mission. I commend the Bill to the House.
Question put and agreed to.
Bill accordingly read a Second time.
CROWN ESTATE BILL [LORDS] (PROGRAMME)
Motion made, and Question put forthwith (Standing Order No. 83A(7)),
That the following provisions shall apply to the Crown Estate Bill [Lords]:
Committal
(1) The Bill shall be committed to a Public Bill Committee.
Proceedings in Public Bill Committee
(2) Proceedings in the Public Bill Committee shall (so far as not previously concluded) be brought to a conclusion on Tuesday 11 February.
(3) The Public Bill Committee shall have leave to sit twice on the first day on which it meets.
Proceedings on Consideration and Third Reading
(4) Proceedings on Consideration shall (so far as not previously concluded) be brought to a conclusion one hour before the moment of interruption on the day on which proceedings on Consideration are commenced.
(5) Proceedings on Third Reading shall (so far as not previously concluded) be brought to a conclusion at the moment of interruption on that day.
(6) Standing Order No. 83B (Programming committees) shall not apply to proceedings on Consideration and Third Reading.
Other proceedings
(7) Any other proceedings on the Bill may be programmed.—(Christian Wakeford.)
Question agreed to.
CROWN ESTATE BILL [LORDS] (MONEY)
King’s recommendation signified.
Resolved,
That, for the purposes of any Act resulting from the Crown Estate Bill [Lords], it is expedient to authorise
(1) the payment out of money provided by Parliament of any expenditure incurred by the Treasury under any other Act that is attributable to the Act;
(2) the payment out of the National Loans Fund of any sums payable out of the fund under any other Act that is attributable to the Act.—(Christian Wakeford.)
National Insurance Contributions (Secondary Class 1 Contributions) Bill
James Murray ExcerptsTuesday 17th December 2024
(8 months, 4 weeks ago)
Commons ChamberRead Full debate National Insurance Contributions (Secondary Class 1 Contributions) Act 2024-26 View all National Insurance Contributions (Secondary Class 1 Contributions) Act 2024-26 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts Amendment Paper: Committee of the whole House Amendments as at 17 December 2024 - (17 Dec 2024)
Iqbal Mohamed
Everyone in my constituency, and indeed in the whole country, knows that the last Tory Government decimated public services after 14 years of austerity, mismanagement, negligence and a sole focus on the rich, at the expense and neglect of the poor working class and the public sector. I sympathise with the new Government, and I will try to provide constructive support.
I wholeheartedly welcome the Government’s announcements in the Budget of increased investment in education, the NHS, infrastructure projects and other public services, but, like many other people in the House and throughout the country, I do not agree with the approach taken to the funding of those investments. Members on both sides of the Committee have indicated today that failing to protect key sectors and services such as general practices, care homes, pharmacies, childcare providers and third sector providers may have been an oversight or a mistake on the Government’s part, but I am not so sure. On the basis of the Government’s other blanket policies on abolishing the winter fuel allowance, imposing VAT on all private schools including low-fee and charitable schools and removing business rates relief from all private schools and charities without any announcement of safeguarding or compensatory measures to protect these services and sectors, it appears to have been a deliberate, or negligent, decision.
It is clear that the Government inherited a dire state of affairs that requires huge investment, which must be paid for in a responsible way. I am sorry to say that the way that has been chosen by this new Labour Government is not the right one. Viable and progressive alternatives are available to the Government to raise finances for the necessary investment rather than inflicting the increase in national insurance contributions on the impacted bodies. Let me suggest a couple of easy measures that would support the Government’s investment. One possible solution is the imposition of a 2% wealth tax on assets over £10 million, which would raise the amount predicted to be raised by national insurance contributions; another is the closing of corporation tax loopholes that allow corporations to save billions and to offshore profits.
The Exchequer Secretary to the Treasury (James Murray)
I am conscious that I have only a few moments to speak. I will not go through the four clauses of the Bill, as I take it that everyone will have read it already. I will instead go directly to the amendments that have been tabled, ahead of potential votes in a few moments.
I will address the amendments tabled by the hon. Members for St Albans (Daisy Cooper), for Angus and Perthshire Glens (Dave Doogan), for Leicester South (Shockat Adam), for Grantham and Bourne (Gareth Davies), and for Lagan Valley (Sorcha Eastwood). These amendments seek to exclude certain sectors, including healthcare providers, educational settings and charities, from the new rate and threshold for employer national insurance. As hon. Members know, the changes in the Bill before us represent one of the difficult but necessary decisions that the Government have had to take to fix the foundations of our economy and our public finances.
James Murray
I cannot give way. I have given way to the hon. Gentleman many times in recent weeks, but I have about four minutes in which to address everyone’s comments.
As hon. Members have set out, we recognise that the changes we are making today will have an impact on employers. Making these changes was a tough decision that we did not take lightly, but we are also clear that the revenue raised from the measures in this Bill and others in the Budget will play a critical role in both restoring economic stability and getting the NHS back on its feet. As a result of the measures in this Bill and the wider Budget measures, the NHS will receive an extra £22.6 billion over two years to deliver 40,000 extra elective appointments a week.
The Government will provide support for Departments and other public sector employers on additional employer national insurance costs, including central Government, public corporations and local government. Independent contractors, including primary care providers, social care providers, charities such as hospices and nurseries will not be supported with the costs. That is the same as was the case with the changes to employer national insurance rates under the previous Government’s plans for the health and social care levy.
Primary care providers—general practice, dentistry, pharmacy and eye care—are important independent contractors that provide nearly £20 billion-worth of NHS services. Every year, the Government consults each sector about what services they provide, and about the money to which they are entitled in return under their contract. As in previous years, the issue we are debating today will be dealt with as part of that process in the round. The Department of Health and Social Care will confirm funding for general practice, dentistry and pharmacy for 2025-26 as part of the usual contract process later in the financial year, including through consultation with sectors.
I turn to adult social care. The Government have provided a real-terms increase in core local government spending power of around 3.2% for 2025-26, including at least £680 million of new grant funding for social care. The funding can be used to address the range of pressures facing the adult social care sector; again, they will be considered in the round.
Some hon. Members have tabled amendments to exclude charities from the new national insurance rate and threshold. However, it is important to recognise that charities can benefit from employment allowance, which this Bill has more than doubled from £5,000 to £10,500. That will benefit charities of all sizes, particularly the smallest. The Government also provide wider support for charities, including hospices, via a tax regime. This tax regime is among the most generous in the world, with tax reliefs for charities and their donors that are worth just over £6 billion for the year to April 2024.
I recognise that some hon. Members have shown an interest in the impact of this Bill on childcare settings, as highlighted in the amendments tabled by the hon. Members for St Albans, for Grantham and Bourne, and for Lagan Valley, and in the new clause tabled by my hon. Friend the Member for Walthamstow (Ms Creasy). Early years providers have a crucial role to play in driving economic growth and breaking down barriers to opportunity. We are committed to making childcare more affordable and accessible, which is why the Government committed in our manifesto to deliver the expansion of Government-funded childcare for working parents, and to open 3,000 new or expanded nurseries, by upgrading space in primary schools to support the expansion of the sector. Despite the very challenging circumstances that the Government inherited, the Chancellor announced in her Budget in October significant increases to the funding that early years providers are paid to deliver Government-funded childcare places. This means that the total funding will rise to over £8 billion in 2025-26.
New clause 4, tabled by my hon. Friend the Member for Walthamstow, specifically refers to the eligibility criteria for employment allowance. I can assure her that they have not changed, except for the removal of the £100,000 threshold, which will mean that more organisations are able to access employment allowance. The eligibility of a particular organisation will depend on the make-up of an individual business’s work, which can be determined following detailed guidance from His Majesty’s Revenue and Customs. While every organisation will need to check its eligibility for the employment allowance, it is likely that many childcare providers will be able to access it.
Finally, I will turn to the amendments to exclude universities from the new rate and thresholds for employer national insurance. We greatly value UK higher education in creating opportunity, being an engine for growth in our economy and supporting local communities. The Budget provided £6.1 billion of support for core research and confirmed the Government’s commitment to the lifelong learning entitlement. The Secretary of State for Education has confirmed that the maximum fees in the academic year 2025-26 will rise, for the first time since 2017, from £9,250 to £9,535. This was a difficult decision, which demonstrates that the Government are serious about the need to put our world-leading higher education sector on a secure footing. I would like to continue, Madam Chair, but I should stop now—
James Murray
I beg to move, That the Bill be now read the Third time.
The Bill seeks to put into law one of the toughest decisions we made at the Budget in October. As I set out in earlier stages of the Bill, we recognise that there will be impacts on employers as a result of the changes, with employers facing difficult decisions. It will implement a difficult but necessary decision that, along with others, is critical to raising the revenue needed to fix the public finances, get public services back on their feet and restore economic stability.
The Bill before us has three measures: first, an increase to the main rate of employer secondary class 1 national insurance contributions from 13.8% to 15%; secondly, a decrease in the secondary threshold for employers from £9,100 to £5,000 per year from 6 April 2025; and thirdly, changes to the employment allowance to support small businesses. The measure will protect small businesses and charities by more than doubling the employment allowance from £5,000 to £10,500 pounds a year from April 2025. In addition, the £100,000 eligibility threshold will be removed.
Through the measures in the Bill and others in the Budget, the Government are taking the difficult but necessary decisions to fix the foundations of our economy. If hon. Members in other parties choose to vote against the Bill, the British people will see that they are voting to ignore the fiscal mess that we inherited. They are voting to cut investment in the NHS and to increase borrowing for day-to-day spending.
Finally, I reiterate my thanks to hon. Members who have participated in the debate, and I extend my thanks to all the officials for their support. I commend the Bill to the House.
LGBT Financial Recognition Scheme Payments: Income Tax Exemption
James Murray Excerpts(9 months ago)
Written StatementsRead Full debate Read Hansard Text Read Debate Ministerial Extracts
The Exchequer Secretary to the Treasury (James Murray)
Today, the Government have confirmed ex gratia payments made under the LGBT financial recognition scheme will be exempt from income tax. The scheme is designed to offer financial recognition to those who served under, and suffered from, the ban on LGBT personnel serving in HM armed forces between 1967 and 2000.
This decision to grant an income tax exemption ensures that applicants receive the full payment amount, marking an important step toward addressing the historic wrongs faced by LGBT personnel and veterans in the past.
The Government will legislate via secondary legislation to formalise this tax exemption in due course.
[HCWS305]
Finance Bill
James Murray ExcerptsWednesday 11th December 2024
(9 months ago)
Commons ChamberRead Full debate Finance Act 2025 View all Finance Act 2025 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts Amendment Paper: Committee of the whole House Amendments as at 11 December 2024 - (11 Dec 2024)
The Exchequer Secretary to the Treasury (James Murray)
This Government believe that all children should have the opportunity to succeed. That opportunity should not be limited by who they are, where they are from or how much their parents earn. We are determined that a young person’s background should not limit what they can achieve. That is why, despite the dire fiscal situation that we inherited and the numerous tough choices that it has entailed, the Chancellor prioritised investment in education at the Budget in October.
At that Budget, the Chancellor announced real-terms growth of 3.4% in education funding, including a £2.3 billion increase to the core schools budget in England for the next financial year. This funding supports the recruitment of 6,500 additional teachers, in line with the Government’s commitment, and includes £1 billion for the special educational needs and disabilities system, to help the 1 million pupils in the state system with special educational needs.
This Government will make sure that all children get the high-quality education that they deserve, as well as high-quality school buildings; funding has been announced for the school rebuilding programme, and for school maintenance, so that we can begin to tackle the maintenance backlog. These changes are crucial first steps to improving education for all children and meeting the aspirations of parents across the country.
Investment in education has to be paid for, so I turn to the focus of this debate: our decision to end the VAT exemption for private school fees. In July, the Chancellor announced that the Government will end tax breaks on VAT and business rates for private schools. These policies are expected to raise £1.5 billion in their first full year, rising to over £1.8 billion a year by 2029-30.
Graham Stuart (Beverley and Holderness) (Con)
Has the impact on the market of children being withdrawn from schools been greater than expected? In my time as a Minister, I always found that the Treasury rather underestimated the dynamic impact of policy change. I would be interested to hear his reflections.
James Murray
I thank the right hon. Gentleman for his question on the impact of the policies on children’s education. I will come to the details shortly, but to give him an overview of the forecast impacts, we estimate that ultimately there will be around 37,000 fewer pupils in the private sector. That is a combination of pupils who will never enter the private sector in the first place and those who will leave. They represent around 6% of private school pupils. We expect most of the moves to take place at natural transition points, such as when a child moves from primary to secondary school or at the beginning of exam courses.
Sir Oliver Dowden (Hertsmere) (Con)
If the intention of the Government is that the moves should happen at natural transition points, why did they decide to impose the change from January? Whatever one’s views on the merits of the policy, that is not really fair on the parents affected. Indeed, one could say it is cruel.
James Murray
It is right that these changes be implemented as soon as possible to raise the funding that we need to deliver on our education priorities. As a result of the policies coming into effect in January, we will raise a forecast £460 million of additional revenue in 2024-25. We are ambitious for the state education system, and we want to get on with delivering the changes that we committed to in the manifesto.
Dr Ben Spencer (Runnymede and Weybridge) (Con)
I must declare that I, like many parents in Surrey, have chosen independent education for my children. A freedom of information request earlier this week regarding empty school places in Surrey showed that in the ’25-26 academic year, there are zero spare places in year 9, zero in year 10 and zero in year 11. The Minister will know that in independent schools, many children in those years take international GCSEs and baccalaureates. What is his message to those children, who have no place and will have their exam training disrupted because of his spiteful policy?
James Murray
Local authorities and schools already have processes in place to support pupils who move between schools at any point in the academic year. Analysis carried out by the Department for Education under the previous Government suggests that each year, almost 60,000 secondary school moves take place not at normal transition points or over the school holidays. We fully expect the majority of moves to take place at natural transition points or in the school holidays, rather than within the school year.
I have been clear that ending these tax breaks for private schools has been a difficult decision, but it is necessary to secure additional funding that will help us to fulfil the commitments we made to improving education for all.
Simon Hoare (North Dorset) (Con)
The Minister continually refers to tax breaks. They are not tax breaks. Why can he not just be honest with the House and admit that this is the first time that any Government in a civilised democracy has imposed a tax on learning and education?
James Murray
Let me explain to the hon. Gentleman how public finances work. Funding a tax relief or a tax break is equivalent to public spending, because it is money that cannot be spent on something else. The Conservatives have committed, through their new leadership, to repealing this policy if they win the next general election. That implies cutting state education—cutting the investment in education for all that we are prioritising.
James Murray
I will not give way because I am making a clear point. We have to make choices in politics about what to prioritise. We have said that the VAT tax break for private school fees is not something that we want to prioritise. We want to spend that money instead on improving state education for all children.
Simon Hoare
I am grateful to the Minister for giving way a second time, and I am so grateful for the public finance lesson. Surely he has to accept that as no tax is placed on learning in any sector in the educational landscape across the United Kingdom, this measure is not a tax break. It is not that there is a tax break for one sector while others have a tax imposed. This is an imposition of a new tax in the educational sphere. It is not a tax break because no educational establishment pays VAT.
James Murray
Given the record of the Conservatives over the past 14 years, I do not think it is ridiculous to assume that they might need some education on how public finances work, with the mess that we inherited and the desperate need for us to restore fiscal responsibility to public finances. Restoring that fiscal responsibility requires us to take decisions that are difficult but necessary to raise the finances to fund our priorities. We have taken the decision that we will not support a VAT exemption for private school fees and that we will invest the money that we raise in state education to ensure that the aspirations of every parent across this country can be fulfilled. That is a decision I will defend every time I am in this Chamber.
Josh Fenton-Glynn (Calder Valley) (Lab)
My constituents would be surprised that there is no tax exemption on tampons, which are used by close to 50% of society, yet there is a tax exemption for VAT on private schools, which are used by less than 5% of the country. Does my hon. Friend not agree that it is a mark of the priorities of Conservative Members that they are so quiet about the former but not the latter?
James Murray
My hon. Friend is right to point out that decisions on VAT reliefs are political choices. Indeed, the Opposition are showing which side of that choice they land on when it comes to education; through their new leadership, they are choosing to prioritise a tax break for private school fees over investment in state education. That is a political choice. I am very happy to stand behind where we are on that side of the debate.
I will turn to some of the clauses in detail. The changes made by clause 47 will remove the VAT exemption from which private schools currently benefit on the education, vocational training and boarding they provide. Let me be clear: this policy does not mean that schools must increase fees by 20%, and the Government expect schools to take steps to minimise the increases for parents. Schools can reclaim VAT paid on inputs and make efficiency savings to minimise the extent to which they need to increase fees. Many schools have already committed publicly to capping fee increases at 5% or absorbing the full VAT costs themselves.
Dr Luke Evans (Hinckley and Bosworth) (Con)
One of the schools in my area has posed a question on VAT. It has combined fees, within which things like meals are included. It is not clear from Treasury guidance whether the school would have to separate those fees out, creating another accounting problem—in order to have separate VAT and travel, for example, as part of the fees—when currently it is all one unit. Could the Minister provide clarity on that? When I met the Schools Minister, he was unable to give me an answer, and was going to go away and speak to the Treasury about what that looks like. This will have real impacts for this school, which will have to decide how to set out its accounting, and whether it has to include the fees or separate them out into several different blocks.
James Murray
I thank the hon. Gentleman for his specific question. Let me just be clear that I am not giving tax advice for that particular school in my response, because I would always assume that any school would get its own tax advice. In general, the VAT treatment of a particular supply is determined by the predominant supply, so there are options available to schools. I am happy to pick the matter up with him outside the Chamber and to make sure he has the details in writing. As I said, I would not want to give specific advice to that school, but it is worth the school getting advice on the VAT treatment of the fees it charges based on the predominant supply.
I will return to the impact of the policy we are proposing and the changes in clause 47. Government analysis suggests that the impact of the VAT policy on private and state school sectors is likely to be very small—ultimately leading, as I was saying a few moments ago, to 37,000 fewer pupils in the private sector, which includes both pupils who will never enter the private sector and those who will move.
Dr Neil Shastri-Hurst (Solihull West and Shirley) (Con)
A particular subset of pupils affected by this policy are those in receipt of the continuity of education allowance. The revised figures for the CEA, released recently, do not fully protect those pupils from the uplift on VAT on school fees. What assessment have the Government made of the impact of this policy on retention and recruitment into our armed forces and our diplomatic service?
James Murray
I thank the hon. Gentleman for raising the continuity of education allowance, because the Government greatly value the contribution of our diplomatic staff and serving personnel. The continuity of education allowance is therefore provided to ensure that the need for frequent mobility does not interfere with the education of their children. As he may know, the Ministry of Defence and the Foreign, Commonwealth and Development Office have increased the funding allocated to the continuity of education allowance, to account for the impact of any private school fee increases on the proportion of fees covered by the CEA, in line with how the allowance normally operates.
The Government have carefully considered the impacts of the policies set out in clause 47 and received a wide range of representations covering topics that have already been raised in the debate today. The Government received more than 17,000 consultation responses, and my officials and I have met those representing schools, local authorities and devolved Governments. As a result of these representations, the Government have made several changes to the legislation, including to clarify the treatment of nurseries. In deciding on the final design of the policy, we have made sure that schools are treated fairly and consistently.
A number of hon. Members have raised with me concerns about the impact of this measure on particular types of schools and on different pupils, so I am glad to have this chance to address some of those points. First, to protect pupils with special educational needs that can be met only in a private school, the local authorities and devolved Governments that fund these places will be compensated for the VAT they are charged on those pupils’ fees. Secondly, as I just mentioned in response to the intervention on military and diplomatic families, the Ministry of Defence and the Foreign Office have agreed to increase the funding allocated to the continuity of education allowance to account for the impact of private school fee increases.
The Government are aware that while many schools have always offered schemes enabling the prepayment of fees, there were concerning reports of some parents using such schemes in an attempt to avoid these fees being subject to VAT. The Government believe that allowing fees paid from the date of the July statement to the date this policy comes into force to be paid without charging VAT on them would be unfair on the vast majority of families who will be unable to pay years-worth of fees in advance. The changes made by clause 48 will therefore introduce anti-forestalling provisions that will apply to all prepayments of private school fees and boarding services on or after 29 July 2024 and before 30 October 2024. Finally, clause 49 sets out the commencement date for these changes, which will apply to any fees paid on or after 29 July 2024 relating to the term starting in January 2025.
To conclude, the reason the Government are raising funding from the changes we are debating today is to increase investment in the state education system. Every parent aspires for high-quality education for their children. The removal of the VAT exemption for private schools will help to support the Government’s investment in schools and ensure that every child has a chance to thrive. We are determined to be a Government who enable the aspirations of all parents to be met and who ensure that all children have the opportunity to succeed. I therefore commend these clauses to the Committee.
The First Deputy Chairman of Ways and Means (Judith Cummins)
I call the Opposition spokesperson.
Lewis Cocking
I thank the hon. Member. If he just waits for the next part of my speech, he may get the answer to his intervention.
The Government’s plan will put all that at risk. Notably, Haileybury is planning to absorb as much of the financial hit as it can, rather than place the extra burden on parents. To do so, it must look at reducing expenditure and therefore its ability to offer financial support to Haileybury Turnford, painfully contradicting the Government’s argument that their policy will result in more spending on state school pupils. It is not just about money; greater financial pressures on Haileybury will inevitably lead to staff having less time and resources available to share with Turnford, and fewer opportunities for state school students at Haileybury Turnford as a result.
Ministers think that their policy will impact only the rich, but for nearly a decade a genuinely working-class community in my constituency has benefited from a state school and an independent school working together, which is exactly the kind of partnership that we should be encouraging. We should not be encouraging the politics of envy. Sadly, the changes that the Government are introducing through the Bill will bring all that to an end.
James Murray
Let me begin by thanking all hon. Members for their contributions. I will take a few moments to respond to some of the points raised and then to set out the Government’s view on the proposed new clauses.
The shadow Minister, the hon. Member for North West Norfolk (James Wild), addressed new clause 8, which was tabled by the right hon. Member for Central Devon (Mel Stride). I will come to the new clause in a moment, but for the avoidance of doubt let me reassure the shadow Minister that higher education and teaching English as a foreign language are both exempt from and not affected by this policy. I also reassure him that HMRC stands ready to support schools. It has already published bespoke guidance for schools, run webinars, updated registration systems and put additional resources in place to process applications.
Damian Hinds
In principle, what is the distinction between full-time private schooling and private tuition, from the point of view of what it is right to tax? Will he guarantee that no tax will be put on private tuition?
James Murray
If the right hon. Gentleman is referring to the comments I just made in response to the shadow Minister’s remarks, teaching English as a foreign language and higher education are exempt from the provisions of the Bill.
Damian Hinds
No, I mean families who send their child once or twice a week for an hour for academic study or something extra-curricular. Why should that be tax exempt, when if it is done for all the hours in the school week, it is not?
James Murray
In designing the Bill and making sure that it is clear, we decided to focus on those schools that provide full-time education. Following feedback during the consultation on the Bill, we decided to clarify some of the treatments, such as for nurseries, which I mentioned earlier, to ensure that they are treated appropriately. If they are fully stand-alone nurseries, they are not covered. In the original drafting of the legislation, we referred to nurseries that wholly comprise children below the compulsory school age. We changed that to wholly or almost wholly to ensure that having, for example, one pupil over compulsory school age would not trip a nursery into being covered.
James Murray
I am going to make some progress, because I will come to the right hon. Gentleman’s point in a moment, and I want to mention the points made by other hon. Members in the debate.
We heard from the hon. Members for Twickenham (Munira Wilson) and for Richmond Park (Sarah Olney). Yet again from the Liberal Democrat Front Bench, we see a party that is happy to support our extra investment in education for all children, but that cannot bring itself to support the measures that we put in place to help pay for that investment in education.
Sarah Olney
We have heard this point time and again from the Labour Benches. I want to say, one more time, that the Liberal Democrats put forward a fully costed programme in our 2024 general election manifesto, which had a range of tax-raising measures that would have paid for the changes we proposed and did not include VAT on school fees, for all the reasons the Minister has heard today.
James Murray
The reason why the Liberal Democrats hear this time and again from the Government Benches is that, time and again, they want all the benefits of investment without having to pay for it. That is a pattern that we see again and again in this Chamber.
James Murray
I am going to make some progress.
I thank my hon. Friends the Members for Falkirk (Euan Stainbank) and for Loughborough (Dr Sandher) for their comments. I feel that I am duty bound to add my congratulations to my hon. Friend for Loughborough on his engagement.
The hon. Member for Hinckley and Bosworth (Dr Evans) is not in his place—sorry, he is at the Bar. Perhaps he could come and take a seat on the Benches. He asked an important question to try to get some clarity about the VAT treatment of combined fees that cover school meals, transport and other services. I hope that my earlier answer gave him some reassurance on that.
I reiterate that I cannot provide advice for individual schools, but it is worth emphasising that the general principle is that if a school supplies a package of education for a single fee, that will normally be a single supply for VAT. That package could include a number of other elements such as transport or meals, alongside the main element of education. If it is a single supply, it is a single VAT liability. However, where a school supplies education and also supplies other elements for a separate fee, that will normally be treated as a separate supply. For example, if a school offers school meals alongside the education for a separate charge, those will normally be two different supplies, and they may have different VAT liabilities. Although the education would be subject to the standard rate of VAT, the school meals may be exempt, if they meet the conditions.
Dr Luke Evans
I am grateful for the Minister’s clarification on that point; I think he is hitting towards it. The school itself has everything grouped into one fee, which includes the transport, schooling and food. Its contention, therefore, is that it will have to break that all out, which means it will have to deal with all the accounting issues on top of this. It is just another burden to think about. I wonder whether the Treasury has thought about that and whether there will be further guidance—there is literally just one line in a piece of written guidance put out by the Treasury. Is there anywhere the school can raise this issue to work through the exact advice it needs? I appreciate that the Minister cannot give that advice directly to the school from the Dispatch Box.
James Murray
The way that we treat private school fees and the other charges that private schools may levy has to be consistent with the VAT principles more broadly, which is why I have tried to explain how the supply of education and the supply of other elements would interact with the VAT system more widely. I will hold back from giving specific advice about that individual school, but I would encourage it to contact HMRC to get advice about its specific registration. If the school staff read what I have just said in Hansard, I hope they will see some information that will help them to understand how to approach this issue.
Graham Stuart
As ever, the Minister is being very gracious in giving way. If someone were to establish a new educational establishment providing entirely modular educational elements that people could choose between, would that be subject to VAT, individually or collectively, or not?
James Murray
The right hon. Gentleman is tempting me into hypotheticals and into trying to give advice to a school that does not yet exist—I will hold back from that, because I think the principles of our Bill are very clear on what VAT at the standard rate is applied to and what can be made exempt, in line with the existing rules on VAT.
We heard several times from the right hon. Member for East Hampshire (Damian Hinds). I assure him that the Government costing has, of course, been fully scrutinised and certified by the Office for Budget Responsibility. He also spoke about capital funding. Obviously, pupil numbers fluctuate for a number of reasons. The Government have already announced more than £700 million to support local authorities over this academic year and the next to provide places in new schools and expand existing schools. I did note, however, that in response to an intervention by my hon. Friend the Member for Hartlepool (Mr Brash), the right hon. Gentleman seemed implicitly to admit to his Government’s failure to improve high-needs education in the state sector, which is precisely why our measures today are so important.
Damian Hinds
First, the Minister knows I said no such thing. I spoke about the additional investment that had gone into the high-needs budget under the previous Government, particularly since 2019, and said that there was more to do.
Since I am on my feet, can I ask him to expand on what he just said about capital? What he has just spoken about is capital for places that are already planned, but what if a lot more children present in some places? Has he budgeted for that capital? Does he guarantee that whatever capital goes to the DFE will be on top of the existing capital budget?
James Murray
As I said to the right hon. Gentleman, pupil numbers in schools fluctuate regularly for a number of reasons, and the Department for Education, and indeed the devolved Governments, already work with local authorities to identify pressures and take action where necessary. As I said in my earlier remarks to him, the Government already provide capital funding through the basic need grant to support local authorities in England to provide school places, and the Government have already announced £700 million over this academic year and the next, which can be used to provide places in new schools and to expand existing places.
Finally, the hon. Member for Bexhill and Battle (Dr Mullan) raised the motivation behind our policy, which other Opposition Members also spoke to. Let me be clear on this: our decision to fix the public finances to fund public services, including education, means that difficult decisions have to be taken. Our choice to end the VAT exemption for private school fees has been a difficult but necessary decision that will secure additional funding, which will help to deliver on our commitments to improve education for all.
Dr Mullan
I did not talk about motivation in my speech; I spoke about how the Minister has framed it. Does he accept that with a general taxation pot, where all the money goes into one amount that is doled out as the Government see fit, there is absolutely no basis for saying that children in the state sector have less because of the exemption of VAT for private schools? The two things are totally unconnected in the Budget and the financing of the Government.
James Murray
What is connected is that if we want to fund public services and fix the public finances, we have to take difficult decisions. This is one of those difficult decisions we are taking today: a difficult but necessary decision to restore fiscal responsibility after the mess we inherited from the Conservative party and to fund our public services. It is necessary to take those decisions, so that we can get that funding into education for all. If the hon. Gentleman does not want to take that decision, he is, in effect, denying the choices that we are making about funding public services.
I will now make some progress to address the new clauses tabled by Opposition Front Benchers. New clause 8, which was tabled by the right hon. Member for Central Devon, would require the Government to make a statement to Parliament about the impact of removing the VAT exemption for private school fees within six months of the Act being passed. It states that it
“must include details of the impact on…pupils with special educational needs and disabilities…small rural schools, and…faith schools.”
It would require the Government to
“make a statement about the impact of the removal of the exemption on schools that take part in the music and dance scheme”
within 18 months of the Act being passed.
I want to make it clear that in developing this policy, the Government carefully considered the impact it would have, including the impact it would have on pupils with special educational needs and disabilities, rural and urban schools, faith schools, and schools that take part in the music and dance scheme. As I said before, the Government considered a wide range of representations, including over 17,000 consultation responses, before finalising the policy design. The Government set out the expected impact of the measure in a tax information and impact note published at autumn Budget 2024 in the usual way.
I set out earlier today how the Government will ensure that those children with an EHCP, or its equivalent in other nations, will not be subject to VAT on any private school fees. I am not clear whether the right hon. Gentleman’s new clause, when it refers to “pupils with special educational needs and disabilities”
refers to only those in the private sector, or whether he intends the new clause to consider also the 1 million or more pupils with SEND in the state system. If it is the latter, I am sure he will welcome the extra £1 billion for high-needs funding next year that we have been able to announce thanks to our decisions on tax policy, including that which we are debating today. In addition, based on the evidence provided, it is not apparent that small faith schools will be more affected by this policy than other schools.
The hon. Member for Twickenham, the Front Bench spokesperson for the Liberal Democrats, tabled new clause 9. I think I have addressed most of those points already in my remarks today.
To conclude, I hope I have been able to reassure Members that the new clauses are not necessary, for the reasons I have set out. I therefore urge the Committee to reject new clauses 8 and 9.
Question put, That the clause stand part of the Bill.
Finance Bill
James Murray ExcerptsTuesday 10th December 2024
(9 months ago)
Commons ChamberRead Full debate Finance Act 2025 View all Finance Act 2025 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts Amendment Paper: Committee of the whole House Amendments as at 10 December 2024 - (10 Dec 2024)
The Exchequer Secretary to the Treasury (James Murray)
At the Budget in October, the Chancellor set out the decisions that we are taking to restore economic stability, put the public finances on a firm footing, and embed fiscal responsibility in the work of Government. Having wiped the slate clean of the mess we inherited, our Government can now focus on boosting the public and private investment that is essential for sustainable long-term growth. It is through sustainable economic growth across the UK that we will create wealth and provide security, making people across the country better off.
That goal of raising living standards in every part of the UK so that working people have more money in their pocket is at the heart of the Government’s plan for change that the Prime Minister set out last week. That plan also set out the Government’s commitment to securing home-grown energy, and to protecting bill payers by putting us on track to secure at least 95% clean power by 2030. Making the transition to home-grown energy has required us to take immediate action to unblock investment, including deciding to reverse the de facto ban on onshore wind. The Government have their part to play, alongside the private sector, in making sure that investment happens on the scale and at the pace that we need. That is why the clauses that we are debating are so important—they are a key mechanism for raising the funding that is needed for that investment to be delivered.
We are taking a responsible approach that recognises the role of businesses and their employees in the energy industries of today and tomorrow. Since we formed a Government, my colleagues and I have been working closely with the sector affected by the energy profits levy to make sure that the transition is managed in a way that supports jobs in existing and future industries. Our approach recognises that oil and gas will have a role to play in the energy mix for many years to come, during the transition, and it balances that with ensuring that oil and gas help to raise the revenue that we need to drive investment towards the energy transition. Our legislation delivers that approach, and I welcome the chance to set out the details of how it does so.
The clauses that we are debating concern the energy profits levy, a temporary additional tax on profits from oil and gas exploration and production in the UK and on the UK continental shelf. The levy was introduced by the previous Government in response to the extraordinary profits being made by oil and gas companies—and, it is fair to say, in response to substantial political pressure from Labour Members.
Harriet Cross (Gordon and Buchan) (Con)
Does the Minister believe that oil and gas companies are still making extraordinary profits?
James Murray
I believe that it is fair that the oil and gas industry makes a reasonable contribution to the energy transition. We need to ensure that during the transition from oil and gas, which will play a key role in our energy mix for years to come, the industry contributes to the new, clean energy of the future. The way to have a responsible, managed transition is to work with the industry and make sure that it makes a fair contribution, but to not shy away from making that transition at the scale and pace needed.
Sammy Wilson (East Antrim) (DUP)
Let me try to understand the Minister’s logic. First, he recognises that we will need oil and gas. Secondly, he is going to tax oil and gas companies. Thirdly, he is telling them that his Government are creating an environment in which there is no future for oil and gas, but he still expects them to invest. Where is the logic?
James Murray
I am glad that the right hon. Gentleman has given me a chance to set out why the Government plan is the right and balanced approach. We are ensuring that the oil and gas sector is supported in making the contribution that we know it will to our energy mix for many years to come, while asking it to contribute to the transition to clean energy. The oil and gas industry recognises that a transition to clean energy is under way. It wants to support investment and jobs in the industry but also to contribute to the transition. Taking a fair and balanced approach is the right way to protect the jobs and industries of today and tomorrow and, crucially, to protect bill payers, giving them permanently lower bills and greater energy independence. [Interruption.]
Tristan Osborne (Chatham and Aylesford) (Lab)
In the last financial year, the oil and gas industry made £6.1 billion in profit, despite the chuntering from Opposition Members. Does my hon. Friend agree that the Conservatives introduced the energy levy? We are simply ensuring that our oil and gas sector pays an equivalent sum, so that we can transition to a green energy future. This money is necessary for that transition to occur.
James Murray
My hon. Friend is absolutely right that we are asking oil and gas companies to make a fair and reasonable contribution towards our transition to clean energy. That transition is under way, and it is important for oil and gas companies to make a contribution, but that should happen in a way that protects the jobs and industries of today and tomorrow.
Wera Hobhouse (Bath) (LD)
The oil and gas giants were making eye-watering profits when the Conservative Government finally introduced a levy, although it had a loophole that let the oil and gas companies off the hook. The Government should support the Liberal Democrat amendment, which demonstrates how much of a missed opportunity that was, and how much money we could have raised, had the loophole been closed earlier.
James Murray
I am not entirely clear that that is what the Liberal Democrat amendment does. We have been clear that our intention is to end unjustifiably generous allowances. That is exactly what we are doing by abolishing the core investment allowance, which was unique to oil and gas taxation and is not available to any other sector in the economy.
Perran Moon (Camborne and Redruth) (Lab)
New research published in the last few days has found that fossil fuel companies reported profits of nearly $0.5 trillion during the 2022 energy crisis. By contrast, people struggled with fuel poverty and had to choose between heating and eating. One in seven households in my constituency is in fuel poverty. Does the Minister agree that the ability to extend and increase the energy profits levy is a key lever for addressing this imbalance and supporting households?
The Chairman
Order. That was neatly done, but interventions have to be very closely related to what we are debating here and now.
James Murray
I hope that my hon. Friend’s constituents will benefit from lower bills as a result of the investment that we are ensuring, by the public and private sectors, in the clean energy sources of the future.
We knew, when the Conservatives introduced the energy profits levy, that the extraordinary oil and gas profits were driven by global circumstances, including resurgent demand after covid-19, and the Russian invasion of Ukraine. Households in the UK, however, were particularly badly hit by higher oil and gas prices, as the Government at the time had failed to invest adequately in energy independence, or in measures such as home insulation. When the energy profits levy was introduced, an 80% investment allowance was also introduced, and this was later reduced to 29% when the levy rate increased from 25% to 35% in January 2023. An 80% decarbonisation investment allowance was later put in place for decarbonisation expenditure, which is money spent on the reduction of emissions from the production of oil and gas. The levy was initially set at 25%, but the previous Government increased it to 35% and extended it beyond 2025, first to 2028, and later to 2029.
As I mentioned, the Government recognise the continued role for oil and gas in the UK’s energy mix during the energy transition. We are committed to managing the transition in a way that supports jobs in existing and future industries, recognising that our offshore workers have the vital skills to unlock the clean industries of the future. I put on record my thanks to the offshore workers I met in Aberdeen in August for giving me some of their time and their views when I was there for a meeting with Offshore Energies UK and representatives of the sector. As I mentioned, it is essential that we drive both public and private investment in the transition to clean energy. Clause 15 therefore increases the energy profits levy by three percentage point—from 35% to 38%—from 1 November 2024. The clause also sets out the rules for apportioning profits for accounting periods that straddle the start date. As I have made clear, the money raised by these changes will help to support the transition to clean energy, enhancing our energy security and providing sustainable jobs for the future.
Clause 16 concerns allowances in the levy. The clause removes the 29% core investment allowance for general expenditure incurred on or after 1 November 2024, as I mentioned to the hon. Member for Bath (Wera Hobhouse). The Government have been clear about our intention to end unjustifiably generous allowances, and that is exactly what we are doing by abolishing the core investment allowance. We are bringing the level of relief for investment in the sector broadly in line with the level of capital allowances available to other companies operating across the rest of the economy through full expensing, which we have committed to maintaining. The energy profit levy’s decarbonisation allowance will be retained to support the sector in reducing emissions.
Qualifying expenditure includes money spent on electrification of production, or on reducing venting and flaring. The retention of the decarbonisation allowance reflects the Government’s commitment to facilitating cleaner home-grown energy. However, in the light of the increase to the levy, clause 16 also reduces the rate of the decarbonisation allowance to 66% in order to maintain the same cash value of the tax relief per £100 of investment.
Clause 17 extends the sunset of the levy by one year from 31 March 2029 to 31 March 2030. To provide the oil and gas industry with long-term certainty and confidence in the fiscal regime, we are retaining the levy’s price floor, the energy security investment mechanism.
Dave Doogan
Certainty is only good if it relates to a positive outlook, not a negative outlook. The hon. Member for Gordon and Buchan (Harriet Cross) asked a clear question about the duration. It was not about whether the sector pays fair taxes; we all believe that people should pay fair taxes. Does the Minister still believe that the industry is making extraordinary profits?
James Murray
I would like to explain to the hon. Gentleman how the energy security investment mechanism works, because that, to be fair, was put in place by the previous Government, and we are maintaining it. It says that if prices drop below a certain threshold for six months, the energy profits levy ceases early. That gives some certainty and predictability to the oil and gas sector. If prices go below that level, the sector can have confidence that the energy security investment mechanism will end the levy early. If that does not happen, the levy will continue, as we have said, until March 2030.
I am keen—I will set out a few more details later—to engage with the oil and gas sector on the regime post the energy profits levy, because it is important for oil and gas companies making decisions about investment to have certainty about what will happen up until March 2030, and to understand what the regime might be like thereafter. That is why I am looking forward to my conversations with the sector on what the post energy profits levy regime will look like.
Long-term certainty and confidence is being provided to the oil and gas sector by our retention of the levy’s price floor, the energy security investment mechanism, which I was explaining to the hon. Member for Angus and Perthshire Glens (Dave Doogan). It means that the levy will cease permanently if oil and gas prices fall below a set level for a sustained period. Furthermore, as I also just said, to provide stability for the long term, the Government will publish a consultation in early 2025 on how the tax regime will respond to price shocks once the energy profits levy comes to an end. That will give oil and gas producers and their investors predictability and certainty on the future of the fiscal regime, which will support their ability to continue investing, while also ensuring that the nation receives a fair return at a time of exceptional crisis.
James Murray
I thank hon. Members for their contributions to the debate. I will respond to some of the points raised, and set out the Government’s views on the new clauses. The Opposition spokesperson, the hon. Member for Grantham and Bourne (Gareth Davies), asked for confirmation of our decision to retain the energy security investment mechanism. I hope that he will take yes for an answer, because yes, I can confirm that the ESIM will remain in effect until 31 March 2030, when the energy profits levy is due to end. It will continue to be adjusted in line with consumer prices index inflation in future financial years. I hope that sets his mind at rest on that point.
The hon. Gentleman asked about modelling the impact of the energy profits levy. I am sure that he will remember from his time in the Treasury the role that the Office for Budget Responsibility plays. He will see that in the report that it published alongside the Budget, it forecast £12.6 billion being raised from the levy over the forecast period. Of course, the OBR will provide updated forecasts next year.
The hon. Gentleman and other hon. Members kept raising the phrase “extraordinary profits” when talking about trying to understand the position that the oil and gas sector is in. That links directly to the energy security investment mechanism, because prices remain higher than the price floor that we set. The energy security investment mechanism means that if prices fall sufficiently and return to historically normal levels, the levy will be disapplied. The relationship between the levy, profits and the maintenance of the energy security investment mechanism is key to understanding the Government’s approach.
The Liberal Democrats spokesperson, the hon. Member for St Albans (Daisy Cooper), asked about our choosing a 78% rate, how we set the rate for the energy profits levy, and about other attributes of the system being set up by the clauses under debate. We seek to achieve a balanced approach. We are raising the rate to 78%, extending the levy for a further year and removing the investment allowance, which we deem to be unjustifiably generous; yet we are maintaining 100% first-year allowances, the decarbonisation allowance, and the energy security investment mechanism. That strikes the right balance between ensuring that oil and gas companies continue to invest in oil and gas for years to come, and ensuring that they contribute to and support the transition to clean energy.
The hon. Member for Angus and Perthshire Glens (Dave Doogan) spoke about the need for long-term stability. I entirely agree that we need it. That is precisely what we seek to achieve by saying that the energy profits levy will come to an end in March 2030, by having a price floor in the ESIM—we have mentioned that several times—and by proceeding with our consultation on the post energy profits levy regime. That will give confidence to those thinking about investing in the oil and gas sector not just before the end of the energy profits levy, but post 2030.
The right hon. Member for East Antrim (Sammy Wilson) also mentioned long-term stability. He seems distracted right now, but I hope that will be of some reassurance to him. The hon. Member for Angus and Perthshire Glens said that a £78 investment relief is available in Norway, whereas the figure is £46 in the UK. I want to put on record that in the UK, while the energy profits levy remains in place, the sector continues to benefit from an £84.25 relief for every £100 of investment. I hope that gives him some reassurance on the points that he raised.
I thank my hon. Friend the Member for Earley and Woodley (Yuan Yang) for her thoughtful and informed contribution, which explained that our approach strikes the right balance. I must say, however, that I was disappointed by the contribution from the hon. Member for Waveney Valley (Adrian Ramsay), because he seemed not to support our moves to ensure that tax is not a blocker to CCUS, which will play an essential role in our progress towards net zero. The UK has a chance to be a world leader in that sector; I hoped that he would support our efforts to ensure that it is.
Two new clauses were tabled, which hon. Members spoke about. They require reports to be published. I can remember tabling many such new clauses over the last few years. New clause 2, tabled by the hon. Member for St Albans, would require the Government to produce a report setting out the fiscal impact of the removal of the energy profits levy investment allowance and the change to the decarbonisation investment allowance rate. New clause 3, tabled by the right hon. Member for Central Devon (Mel Stride), would require the Government to produce a report on the expected impact of the levy changes in a number of areas, including on capital expenditure in the UK oil and gas industry and on the Scottish economy.
The Government oppose new clauses 2 and 3 on the basis that they are unnecessary. We have already set out the impact of our measures in a tax information and impact note, which was published at the time of the Budget. That note states that the changes made to the energy profits levy will raise an additional £2.3 billion over the scorecard, and further data on the UK oil and gas industry is regularly published on gov.uk.
I hope that I have addressed some of the points raised by hon. Members, and have reassured them that the new clauses are not necessary. I urge the House to let clauses 15 to 18 and schedule 3 stand part of the Bill, and to reject new clauses 2 and 3.
Question put and agreed to.
Clause 15 accordingly ordered to stand part of the Bill.
Clauses 16 to 18 ordered to stand part of the Bill.
Schedule 3 agreed to.
New Clause 2
Report on fiscal effects: relief for investment expenditure
“The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained in clause 16 of this Act on tax revenue.” —(Daisy Cooper.)
This new clause would require the Government to produce a report setting out the fiscal impact of the Bill’s changes to the Energy Profits Levy investment expenditure relief.
Brought up, and read the First time.
Question put, the clause be read a Second time.
Draft Double Taxation Relief and International Tax Enforcement (Ecuador) Order 2024
James Murray Excerpts(9 months ago)
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The Exchequer Secretary to the Treasury (James Murray)
I beg to move,
That the Committee has considered the draft Double Taxation Relief and International Tax Enforcement (Ecuador) Order 2024.
It is a pleasure to serve on this Committee with you as Chair, Mrs Harris.
The order before the Committee gives effect to a first-time double taxation convention with Ecuador. It will provide a clear and fair framework for the taxation and administration of cross-border transactions between the United Kingdom and Ecuador, benefiting businesses and the economies of both countries by removing barriers to cross-border trade and investment. The DTC is based mainly on the OECD model tax convention, which contains a set of internationally agreed principles that make DTCs easier for businesses to understand and for tax administrations to apply.
I turn now to some of the main features of the DTC. It provides limits on the withholding taxes that can be charged on dividends, royalties and interest, which in many circumstances are less than the tax rates applied under Ecuador’s domestic law. There are specific exemptions for dividends and interest paid to pension funds and for interest paid to financial institutions, which will be of benefit to UK pension funds and to banks with interests in Ecuador.
The DTC limits the circumstances in which the trading profits of an enterprise based in one country may be taxed in the other country. That will be welcomed, for instance, by United Kingdom businesses looking to provide services to customers in Ecuador, such as in the life sciences, infrastructure and financial services sectors, as it will ensure that businesses will not face Ecuadorian withholding taxes on some payments for those services.
The agreement contains all the minimum standards introduced by the joint OECD and G20 project on base erosion and profit shifting. Those standards ensure that DTCs are not used to avoid or evade tax, and include a statement in the preamble that it is not a purpose of a DTC to create opportunities for tax evasion and avoidance, and a principal purpose test that denies treaty benefits in cases of abuse.
Another anti-avoidance rule included in the new treaty is a tie-breaker provision for determining corporate residence based on agreement by the competent authorities of each country. The DTC also allows for the exchange of information between the two countries to facilitate tax transparency and provides for mutual assistance in the collection of tax debts.
Together, these features strengthen both countries’ defences against tax avoidance and evasion. The order includes dispute resolution provisions that go beyond the minimum standard set out in the final recommendations of the BEPS project by providing that, where a taxpayer considers that the DTC has not been applied correctly, they can present their case to either tax authority, and not just where they are resident.
In summary, this agreement is one that the UK can welcome, fulfilling a long-held ambition to conclude a DTC with Ecuador and filling another gap in the UK’s network of DTCs in Latin America. It will provide a stable, long-term framework within which trade and investment between the United Kingdom and Ecuador can flourish. I commend the order to the Committee.
James Murray
I welcome the comments from the shadow Minister and his party’s support for this double taxation treaty.
First, on Ecuador’s ratification of the DTC, Ecuador has indicated that it will complete the process by the end of this year, which I think gives the shadow Minister the timetable he was seeking. If this Committee supports the DTC today, it will take effect from 1 January 2025, as long as the necessary diplomatic exchanges are all completed in time. Taxpayers and businesses in the UK will be able to benefit from the DTC provisions from that date.
The other questions the shadow Minister asked related to the explanatory memorandum and the relationship with pillar 2. There are provisions taken from the United Nations model tax convention, which many developing countries prefer, and which are present in many of the UK’s treaties. They reflect the support for developing countries as they want to engage in the process. Ecuador’s approach to pillar 2 more broadly is probably a question more for the Government of Ecuador than for me but, as the shadow Minister will know, we are committed to the effective delivery of pillar 2 in the UK and to ensuring that the necessary legislation is put in place. Indeed, there is legislation on that in the current Finance Bill, so I look forward potentially to his support for that Bill when it comes to the Chamber.
To conclude, this statutory instrument to approve the double taxation treaty will ensure that we have a modern DTC in place in both countries, providing a stable foundation for investment and growth, while at the same time, crucially, making it harder for people to avoid their taxes in the UK if that is something they are trying to do. I am grateful to the shadow Minister for his contribution and I hope the Committee will see fit to support the order.
Question put and agreed to.