Judith Cummins
Main Page: Judith Cummins (Labour - Bradford South)Department Debates - View all Judith Cummins's debates with the HM Treasury
Finance (No. 2) Bill
Judith Cummins Excerpts(1 day, 9 hours ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
I beg to move, That the clause be read a Second time.
Madam Deputy Speaker (Judith Cummins)
With this it will be convenient to discuss the following:
Government new clause 6—Offshore income gains: savings.
Government new clause 7—Pensions: abolition of the lifetime allowance charge.
New clause 1—Report on fairness and scope of the loan charge settlement opportunity—
“(1) HM Revenue and Customs must, within 12 months of the passing of this Act, lay before the House of Commons a report on the operation and impact of any loan charge settlement opportunity established under section 25 of this Act.
(2) The report under subsection (1) must in particular consider—
(a) whether the terms of the settlement opportunity are available to individuals who have previously settled or fully paid liabilities arising from disguised remuneration loan arrangements,
(b) whether the terms of the settlement opportunity are available to individuals with disguised remuneration loan arrangements falling outside the loan charge years specified in Part 7A of the Income Tax (Earnings and Pensions) Act 2003,
(c) the extent to which any differences in treatment between these groups and those eligible for the settlement opportunity affect perceptions of fairness, and
(d) the potential impact of such perceptions on future tax compliance and trust in the tax system.
(3) The report must include—
(a) an assessment of whether extending more favourable settlement terms to the groups described in subsection (2)(a) and (b) would improve fairness and consistency, and
(b) any recommendations HMRC consider appropriate in light of that assessment.”
This new clause would require HMRC to report on the operation and fairness of the new loan charge settlement opportunity. It would consider whether more favourable terms are, or should be, available to those who have a already settled or fully paid liabilities, and to those with arrangements outside the loan charge years.
New clause 2—Report on implementation customer service standards in relation to sections 253 to 258—
“(1) The Commissioners must, within six months of the commencement of sections 253 to 258, lay before the House of Commons a report setting out—
(a) customer service standards for persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970, including—
(i) maximum waiting times for telephone helpline calls,
(ii) minimum call answering rates,
(iii) maximum response times for written correspondence, and
(iv) availability of in-person support;
(b) measures taken to ensure adequate staffing and resources to meet those standards;
(c) data on actual performance against those standards in each quarter; and
(d) remedial action to be taken where standards are not met.
(2) The customer service standards published under subsection (1) must ensure that persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970 can access support through non-digital channels with service levels comparable to those historically provided before the introduction of Making Tax Digital.
(3) The Commissioners must publish an annual report on compliance with the customer service standards established under subsection (1), and lay a copy of the report before the House of Commons.”
This new clause would require HMRC to establish and publish customer service standards for tax payers exempted from Making Tax Digital requirements due to digital exclusion.
New clause 3—Report on winter fuel payment charge and related compliance and collection measures—
“(1) The Commissioners for HM Revenue and Customs must lay before the House of Commons a report on the operation and effects of the charge applied to winter fuel payments where an individual’s income exceeds the relevant threshold, including the compliance and collection arrangements introduced under section 55 and Schedule 10 in relation to that charge.
(2) The report under subsection (1) must in particular consider—
(a) the effect of the charge on people whose income exceeds the threshold by a small amount, and any resulting behavioural impacts,
(b) the administrative complexity and proportionality of introducing a tapered abatement for winter fuel payments,
(c) the potential effect of updating section 7 of the Taxes Management Act 1970 so that a winter fuel payment charge becomes a notifiable liability for tax assessment purposes, including the operation of penalties for failure to notify, and the interaction with existing exceptions for liabilities reflected in PAYE tax coding adjustments or where a taxpayer has already been issued a notice to file a self-assessment return, and
(d) the operation and effectiveness of any new PAYE regulation provisions that allow winter fuel payment charges to be collected via tax code adjustments in year, and which allow HMRC to repay any overpaid income tax related to the charge via the tax code within the same year.”
This new clause would require HMRC to report to Parliament on the operation of the winter fuel payment charge, including its effect on people whose income exceeds the threshold by a small amount. The report would also cover the implications of updating section 7 of the Taxes Management Act 1970 to make winter fuel payment charge liabilities notifiable for tax assessment purposes.
New clause 4—Implementing the prohibition of the promotion of certain tax avoidance arrangements—
“(1) The Treasury must, within six months of the passing of this Act, consult and report on—
(a) how to ensure the regulations specified under section 156(2) of this Act can address the potential for harm to individuals and small businesses from the promotion online and via social media of tax avoidance arrangements by professionals and by social media tax influencers,
(b) the potential for detriment to individuals who are liable for tax arising from such promotions, and
(c) what steps HMRC should take to inform the public of the risks posed by online tax avoidance arrangements.
(2) The Chancellor of the Exchequer must lay before Parliament a report on the outcome of the consultation under subsection (1), including the steps they plan to take to address any issues identified.
(3) In this section, “tax influencer” means an individual who—
(a) is not a tax professional,
(b) promotes, markets or otherwise encourages participation in a tax avoidance arrangement, and
(c) does so by means of a social media service, where that promotion is carried out—
(i) in the course of a business or trade, or
(ii) in consideration of, or in expectation of, any payment or other benefit, whether from a promoter of the arrangement or from the social media service, or
(iii) with the intention of increasing engagement with, or the monetisation of, content relating to the arrangement.”
New clause 8—Impact of section 84 (General betting duty charge on remote bets)—
“The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of section 84 of this Act on the size of the illegal betting market.”
This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of section 84 on the illegal betting market.
New clause 9—Impact of changes to gambling duties on the economy of Gibraltar—
“The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of sections 83 and 84 of this Act on the economy of Gibraltar.”
This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of sections 83 and 84 on the economy of Gibraltar.
New clause 10—Review of operation of the carbon border adjustment mechanism—
“(1) The Treasury must, each calendar year for five years following the passing of this Act, undertake a review of the operation of—
(a) Part 5, and
(b) Schedules 16 to 19.
(2) A review undertaken under subsection (1) must be conducted in accordance with sections 28 to 32 of the Small Business, Enterprise and Employment Act 2015.
(3) A review undertaken under subsection (1) must be completed as soon as reasonably practicable after the calendar year to which it relates.
(4) The Treasury must lay before Parliament a copy of each review carried out under this section as soon as reasonably practicable following the completion of the review.”
This new clause would place a duty on the Chancellor to conduct a post-implementation review of the operation of the carbon border adjustment mechanism one year after the implementation of the UK CBAM and every subsequent year.
New clause 11—Uprating of allowance amounts for agricultural property—
“The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”
New clause 12—Review of anti-forestalling provisions relating to Agricultural Property Relief—
“(1) The Treasury must conduct a review of the effects of the anti-forestalling provisions relating to Agricultural Property Relief.
(2) The review must, in particular, consider the effects of those provisions on—
(a) succession planning and intergenerational transfer of agricultural land and businesses,
(b) the viability and continuity of family-run farms,
(c) food security and domestic agricultural production,
(d) land management, environmental stewardship, and the condition of the countryside, and
(e) the availability of agricultural land for active farming.
(3) In conducting the review, the Treasury must consult such persons as it considers appropriate, including representatives of the agricultural sector.
(4) The Treasury must lay before the House of Commons a copy of the report within 12 months of the coming into force of the anti-forestalling provisions under this Act.”
New clause 13—Review of impact of Act on complexity of the tax system and administrative burdens—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained within this Act on the complexity of the tax system and the costs of tax administration.
(2) The report under subsection (1) must identify the measures in this Act which—
(a) add to the complexity of the tax system;
(b) reduce the complexity of the tax system;
(c) increase the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(d) reduce the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(e) increase the resources required for HM Revenue and Customs to administer the tax system and ensure compliance; and
(f) reduce the resources required for HM Revenue and Customs to administer the tax system and ensure compliance.
(3) The report must include an assessment of the impact of this Act on the complexity of the tax system, and on the time and cost of tax administration and compliance, for each of the following groups—
(a) pensioners;
(b) taxpayers on low incomes;
(c) personal taxpayers as a whole;
(d) self-employed people;
(e) microbusinesses;
(f) small and medium-sized businesses;
(g) large businesses;
(h) personal representatives who administer a person’s estate after their death;
(i) professional tax advisers; and
(j) HM Revenue and Customs.”
This new clause would require the Chancellor to conduct an assessment of the impact of the Act on the complexity of the tax system and on the time and cost of tax administration for taxpayers and their representatives, and for HMRC.
New clause 14—Review of impact on unemployment and youth employment—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report reviewing the impact of the provisions of this Act on levels of unemployment in the UK.
(2) The report under subsection (1) must, in particular, assess—
(a) the impact of the provisions of this Act on overall unemployment levels;
(b) the impact on employment levels for persons aged 16 to 24;
(c) the impact on rates of economic inactivity among young people;
(d) the effect on youth participation in apprenticeships, training, and entry-level employment;
(e) regional variations in youth unemployment arising from the provisions of this Act; and
(f) the impact on sectors with high levels of youth employment, including hospitality, retail, and the creative industries.
(3) The report must include an assessment of—
(a) the extent to which changes made by this Act have affected hiring decisions by small and medium-sized enterprises;
(b) any disproportionate impact on disadvantaged young people, including those from low-income households or with disabilities; and
(c) projected impacts over a three-year period following the passing of this Act.
(4) The Chancellor of the Exchequer must, following publication of the report under subsection (1), make a statement setting out what steps, if any, the Government proposes to take in response to its findings.”
This new clause requires the Chancellor to review and report on the impact of the Act on unemployment, with particular regard to young people aged 16 to 24.
New clause 15—Notification of taxpayers affected by frozen thresholds—
“(1) HM Revenue and Customs must take reasonable steps to identify individuals who, as a result of—
(a) the freezing of the starting rate limit for savings under section 9 of this Act, or
(b) the freezing of the personal allowance or the basic rate limit under section 10 of this Act, will—
(i) become liable to income tax for the first time, or
(ii) become liable to income tax at a higher rate than in the previous tax year.
(2) HM Revenue and Customs must ensure that each individual identified under subsection (1) is provided with a written notification before the start of the relevant tax year.
(3) A notification under subsection (2) must—
(a) explain that the individual’s tax liability is affected by the freezing of income tax thresholds,
(b) state whether the individual will pay income tax for the first time or move into a higher tax band, and
(c) provide information on where the individual can obtain further guidance about their tax position.
(4) HM Revenue and Customs must publish, no later than six months after the end of each affected tax year, a report setting out—
(a) the number of individuals notified under this section,
(b) the number of individuals who became income taxpayers for the first time as a result of sections 9 and 10, and
(c) the number of individuals who moved into a higher tax band as a result of those sections.
(5) In this section “written notification” includes electronic communication.”
This new clause would require HM Revenue and Customs to notify individuals who, as a result of the freezing of income tax thresholds in the Act, will pay income tax for the first time or move into a higher tax band.
New clause 16—Review of the impact of tax changes on household finances—
“(1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of changes introduced by sections 9,10 and 69 on household finances.
(2) The assessment must evaluate how households across different income levels are affected by these changes.”
This new clause requires the Chancellor of the Exchequer to assess and publish a report on how the freezing of tax thresholds to 2030-31 impacts households at various income levels.
New clause 17—Report on impact of sections 9, 10 and 69—
“Within three months of this Act being passed, the Chancellor of the Exchequer must lay before the House of Commons a report setting out—
(a) the number of taxpayers who will pay income tax at each rate during each tax year between 2026-27 and 2030-31 under sections 9, 10 and 69,
(b) the number of those taxpayers who are pensioners or are of State Pension Age,
(c) comparative figures for each tax year since 2020-21,
(d) comparative projected figures for each tax year to 2034-35, and
(e) comparative figures with a scenario under which normal uprating policy had been implemented for financial years 2020-21 through 2030-31.”
This new clause requires the Chancellor of the Exchequer to assess how many people will be in each income tax bracket from 2026-27 through to 2030-31, together with comparative figures before and after that period.
New clause 18—Review of the effect of sections 63 to 68—
“(1) HM Treasury must carry out a review of the effect of sections 63 to 68 of this Act (Pension interests).
(2) The review under subsection (1) must include an assessment of—
(a) the impact of those sections on individuals’ pension savings and beneficiaries, including on estate values and inheritance tax liabilities,
(b) the administrative effects on personal representatives, pension scheme administrators, and HM Revenue and Customs, and
(c) any behavioural effects on how pensions are used during life and on death.
(3) HM Treasury must lay before the House of Commons a report setting out the findings of the review under subsection (1) no later than six months after the date on which sections 63 to 68 come into force.”
This new clause would require HM Treasury to review and report on the effects of Clauses 63 to 68 of the Bill, which introduce inheritance tax charges on unused pension funds and death benefits, including their impacts on individuals, administrators, and behaviour, and to publish the findings to Parliament.
New clause 19—Administration of inherited pension pots—
“(1) HM Revenue and Customs must review the tax administration arrangements relating to inherited pension pots.
(2) The purpose of the review under subsection (1) is to ensure that—
(a) inheritance tax and related tax checks do not cause unreasonable delays in the payment of pension death benefits to beneficiaries, and
(b) bereaved families are able to receive pension benefits within a reasonable period following a member’s death.
(3) In carrying out the review, HM Revenue and Customs must have regard to—
(a) the cumulative administrative burden placed on personal representatives, pension scheme administrators, and beneficiaries,
(b) the interaction between inheritance tax reporting, clearance processes, and pension scheme payment rules, and
(c) any evidence of prolonged delays in the payment of inherited pension benefits.
(4) HM Revenue and Customs must publish the outcome of the review, including any proposed changes to its processes or guidance, within 12 months of the passing of this Act.”
This new clause would require the Government to address delays in the payment of inherited pension pots by reviewing HMRC’s tax administration processes, with the aim of preventing prolonged waiting periods for bereaved families.
New clause 20—Review of cumulative impact on the hospitality sector—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before the House of Commons a report assessing the cumulative impact on the hospitality sector of—
(a) the measures contained in section 86 of this Act, and
(b) changes to taxation and business costs affecting that sector introduced outside this Act since 2020.
(2) For the purposes of subsection (1)(b), changes to taxation and business costs include, but are not limited to—
(a) changes to employer National Insurance contribution rates or thresholds,
(b) changes to business rates, including reliefs and revaluations, and
(c) any other fiscal measures which materially affect operating costs for hospitality businesses.
(3) A report under subsection (1) must include an assessment of the impact of the matters listed in that subsection on—
(a) levels of employment across the United Kingdom within the hospitality sector,
(b) the number of hospitality businesses ceasing to trade,
(c) the number of new hospitality businesses established, and
(d) the financial sustainability of hospitality businesses.
(4) In this section, “the hospitality sector” means persons or businesses operating in the provision of food, drink, accommodation, or related services.”
This new clause would require the Chancellor of the Exchequer to assess and report on the cumulative impact on the hospitality sector of alcohol duty measures in the Act alongside wider fiscal changes, including employer National Insurance contributions and business rates.
Amendment 1, page 2, line 7, leave out clause 4.
This amendment removes the increase in dividend rates from the Bill.
Amendment 2, page 2, line 16, leave out clause 5.
This amendment removes the new savings rates of income tax from the Bill.
Amendment 3, page 2, line 21, leave out clause 6.
This amendment removes the new rates of income tax on property income from the Bill.
Amendment 4, page 4, line 31, leave out clause 7.
This amendment removes the property rates of income tax for 2027-28 from the Bill.
Amendment 5, page 5, line 20, leave out clause 10.
This amendment removes the freeze in income tax thresholds from the Bill.
Amendment 112, in clause 13, page 6, line 13, leave out from “means—” to “fifteenth” on line 16.
Amendment 113, page 6, line 20, leave out from “(1)” to end of line 23 and insert
“for “£3 million” substitute “£6 million””.
Amendment 114, page 6, line 27, leave out subsection (3)(d).
Amendment 115, page 7, line 1, leave out from “(1)” to end of line 4 and insert
“for “£30 million” substitute “£120 million””.
Amendment 116, page 7, line 5, leave out from “(2)” to end of line 13 and insert
“for “£30 million” substitute “£120 million””.
Amendment 117, page 7, line 10, leave out from “(1)” to end of line 13 and insert “for “250” substitute “500””.
Amendment 118, page 7, line 14, leave out from “(2)” to end of line 15 and insert “for “250” substitute “500””.
Amendment 119, page 7, line 25, leave out from “15 years” to end of line 27.
Amendment 120, page 7, line 28, leave out subsection (7).
Amendment 121, page 8, line 28, leave out sub-paragraph (4).
Amendment 122, in clause 14, page 8, line 36, leave out from “(5A))” to “, and” in line 38 and insert “, £20 million”.
Amendment 123, page 8, line 40, leave out from “company” to end of line 1 on page 9, and insert “, £10 million.”
Amendment 124, page 9, line 5, leave out from “section 252A)” to “, and” in line 7, and insert “, £40 million”.
Amendment 125, page 9, line 10, leave out from “company” to end of line 11 and insert “, £24 million.”
Amendment 126, page 9, line 15, leave out from “section 252A)” to “, and” in line 17 and insert “, £40 million”.
Amendment 127, page 9, line 19, leave out from “company” to end of line 21 and insert “, £24 million.”
Amendment 128, page 9, line 24, leave out sub-paragraph (b).
Amendment 129, page 9, line 38, leave out “that is not a specified Northern Ireland company”.
Amendment 130, page 10, line 4, leave out “that is not a specified Northern Ireland company”.
Amendment 131, page 10, line 10, leave out leave out subsections (6) and (7) and insert—
“(6) In section 186 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””
Amendment 132, in clause 15, page 10, line 30, leave out from “(6A))” to “, and” in line 32 and insert “, £20 million”.
Amendment 133, page 10, line 34, leave out from “company” to end of line 36 and insert “, £10 million.”
Amendment 134, page 11, line 4, leave out from “section 331A)” to “, and” in line 6 and insert “, £40 million”.
Amendment 135, page 11, line 8, leave out from “company” to end of line 10 and insert “, £24 million.”
Amendment 136, page 11, line 14, leave out from “section 331A)” to “, and” in line 16 and insert “, £40 million;”.
Amendment 137, page 11, line 18, leave out from “company” to end of line 20 and insert “, £24 million.”
Amendment 138, page 11, line 23, leave out subsection (6)(b).
Amendment 139, page 11, line 34, leave out leave out subsections (7) and (8) and insert—
“(6) In section 297 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””.
Government amendments 12 to 14.
Amendment 6, page 78, line 4, leave out clause 62.
This amendment removes the changes to the thresholds for Agricultural Property Relief and Business Property Relief from the Bill.
Amendment 7, page 78, line 11, leave out clause 63.
This amendment removes the imposition of inheritance tax on pension interest.
Government amendments 15 to 47.
Amendment 9, in clause 74, page 91, line 25, at end insert—
“(7) The Treasury must make regulations under subsection (1) within 60 days of the passing of this Act.
(8) Before making regulations under subsection (1), the Treasury must consult—
(a) organisations representing infected and affected individuals,
(b) the Infected Blood Compensation Authority, and
(c) bereaved families of victims who have died awaiting compensation.
(9) The regulations made under subsection (1) must make provision for identifying and assisting the estates of deceased victims in claiming inheritance tax relief, including—
(a) outreach to known affected families,
(b) assistance with evidence gathering where medical records have been destroyed,
(c) clear and accessible guidance in plain language, and
(d) a dedicated helpline staffed by trained caseworkers familiar with the infected blood scandal.
(10) The Treasury must, within 6 months of regulations under this section coming into force, and every 6 months thereafter, lay before Parliament a report on—
(a) the number of victims who have died since the previous report while awaiting compensation,
(b) the number of estates that have received inheritance tax relief,
(c) the average time taken to process claims for relief,
(d) any identified barriers preventing families from accessing their entitlement, and
(e) steps taken to expedite outstanding infected blood compensation claims.”
This amendment requires the Chancellor of Exchequer to make regulations under this section within 60 days of Royal Assent. It requires mandatory consultation with those directly affected, and a support service to help bereaved families navigate the system. It also places a six-monthly reporting requirement on the Government.
Amendment 10, page 94, line 4, leave out clause 77.
This amendment would maintain the existing zero-rating for the purposes of VAT on the full value of the lease of a vehicle to a disabled person supplied through the Motability Scheme.
Amendment 11, page 96, line 6, leave out clause 78.
This amendment would maintain insurance premium tax relief for all vehicles let to a disabled person and supplied through the Motability Scheme.
Amendment 101, page 103, line 29, leave out clause 86.
Government amendments 48 to 53.
Government amendments 56 to 61.
Amendment 8, page 442, line 2, leave out schedule 12.
This amendment would remove the changes to Agricultural Property Relief and Business Property Relief from the Bill.
Amendment 109, in schedule 12, page 442, line 20, leave out from “and” to end of line 23 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”.
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 110, page 442, line 29, leave out from “and” to end of line 32 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),”.
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 111, page 443, line 9, leave out from “and” to end of line 12 and insert—
“(b) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”.
This amendment would apply 100% agricultural property trust relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 89, page 444, line 16, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 102, page 444, line 16, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
This amendment, and Amendments 103 to 107, would allow landlords to access 100% relief from inheritance tax where they have let land or farms to tenant farmers on secure agreements under the Agricultural Holdings Act 1986 or on agreements under the Agricultural Tenancies Act 1995 for 10 years or more.
Amendment 90, page 449, line 36, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 103, page 449, line 36, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 91, page 450, line 25, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 104, page 450, line 25, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”.
See Amendment 102.
Amendment 67, page 450, line 27, leave out “30 October 2024” and insert “1 March 2027”.
This amendment, along with Amendments 68 to 87 would remove the transition period in respect of the changes to agricultural property and business property relief and delay the implementation date so that the changes would take effect for transfers made after 1 March 2027.
Amendment 95, page 450, line 27, leave out “30 October 2024” and insert “6 April 2026”.
This amendment, with Amendments 96 to 100, would remove the transition period in respect of the changes to agricultural property and business property relief so that the changes take effect for transfers made from 6 April 2026.
Amendment 68, page 451, line 6, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 96, page 451, line 6, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 92, page 451, line 22, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 105, page 451, line 22, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 93, page 453, line 15, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 106, page 453, line 15, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”.
See Amendment 102.
Amendment 94, page 453, line 17, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 107, page 453, line 17, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 69, page 453, line 23, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 97, page 453, line 23, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 108, page 454, line 40, at end insert
“(But see subsection (2A).)
(2A) If the Treasury estimates that the value of agricultural land has increased by more than the percentage increase in the consumer prices index during the same period, then it must instead make an order by statutory instrument amending each relief allowance amount relating to agricultural property by the percentage increase in the value of agricultural land.”
Government amendments 54 and 55.
Government amendments 62 to 64.
Amendment 88, page 458, line 31, at end insert—
“(1A) In Section 227, leave out subsection (3)(a) and insert—
“(a) if the chargeable transfer was made on death and to the extent that it qualified for relief under Chapters I or II of part V of this Act, eighteen months after the end of the month in which the death occurred, or
(b) if the chargeable transfer was made on death and to the extent that it did not qualify for relief under Chapters I or II of part V of this Act, six months after the end of the month in which the death occurred, and””
This amendment would defer the period for the payment of inheritance tax on assets qualifying for payment by instalments by 12 additional months.
Amendment 70, page 460, line 8, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 71, page 460, line 9, leave out sub-paragraphs (2) and (3).
See explanatory statement for Amendment 67.
Amendment 98, page 460, line 9, leave out sub-paragraphs (2) to (4).
See explanatory statement for Amendment 95.
Government amendments 65 and 66.
Amendment 72, page 460, line 23, leave out “sub-paragraph (3) will not apply” and insert
“the transfer will prove to be an exempt transfer”.
See explanatory statement for Amendment 67.
Amendment 73, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 99, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 74, page 460, line 34, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 100, page 460, line 34, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 75, page 460, line 37, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 76, page 460, line 39, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 77, page 460, line 41, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 78, page 461, line 2, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 79, page 461, line 9, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 80, page 461, line 14, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 81, page 461, line 22, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 82, page 461, line 26, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 83, page 461, line 37, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 84, page 461, line 42, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 85, page 463, line 19, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 86, page 463, line 26, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 87, page 463, line 32, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Dan Tomlinson
I am glad to return to the Commons to debate the Finance Bill on Report. Although I am sure that it would have been of interest to Members on both sides of the House, I am also glad that we have not just had a set of two 45-minute debates on the Ways and Means motions. The opportunity was there, but I am glad that Members did not take it in full. We now have ample time for this important Report stage.
I thank Members on both sides of the House for their contributions in Committee. I thank in particular the shadow Exchequer Secretary to the Treasury, the hon. Member for North West Norfolk (James Wild), for his scrutiny and challenge, and for the invitation to his wonderful constituency, which I hope to take up one day. As yet, no other Opposition Front Bencher has offered me such an enticing prospect as a visit to their constituency, but I look forward to those invitations.
Before I turn to individual amendments, I wish to reflect briefly on the Budget that was delivered in November by my right hon. Friend the Chancellor of the Exchequer. That Budget took fair and necessary decisions to deliver on the Government’s promise of change, to support cuts in the cost of living, to enable NHS waiting lists to continue falling, and to ensure that our national debt fell as a share of GDP and that borrowing falls over the course of this Parliament. As the Chancellor said in this place yesterday and on Monday, Government borrowing—public sector net borrowing—has fallen from 5.2% to 4.3% of GDP, which is a fall of 1 percentage point. That is very significant and means that our borrowing is coming down, as part of our plan to bring stability back to the public finances.
Dan Tomlinson
I thank the hon. Gentleman for his intervention and for his engagement in the Public Bill Committee. The loan charge is an important issue. I focused on it after receipt of Ray McCann’s independent review into the loan charge, which was commissioned by my predecessor. The scope of that review and the decisions made by the Government are such that only those who are directly affected by the loan charge will have the opportunity to take up the new settlement that was recommended by McCann, to which the Government have added a £5,000 further deduction. The Government’s position was that, because the loan charge was an exceptional decision made by the previous Government, it was right that the changes proposed by McCann would apply only to that group. There will be those who engaged in the use of disguised remuneration schemes from before 2010, and with them, as with all taxpayers, this Government are very clear that individuals do have a responsibility to pay their tax.
Amendments 54 and 55, and 62 to 66, are minor amendments to the definitions of business property qualifying for relief. They ensure that the replacement property provisions relating to reorganisation or amalgamation of unquoted shares reflect the new legislation, and that unquoted securities, such as loan notes, continue to qualify for relief only where they are part of a controlling interest in a company.
Amendments 15 to 47 to clauses 63 to 67 make a series of minor technical changes to ensure that the provisions on inheritance tax and pensions operate as intended. These ensure that excluded and exempt benefits are not subject to inheritance tax, nor to the new withholding and payment notices.
I am sure that Members from all parts of the House have enjoyed that run-through of those minor and technical amendments. I can provide them with the good news that that run-through has now concluded. I sincerely hope and expect that the proposed amendments will ensure that the legislation that was set out, and that has been discussed and scrutinised, works as intended, and that HMRC—the organisation that I am proud to be the Minister with responsibility for—has the powers to responsibly collect tax and revenue, which funds the vital public services on which our country relies.
I therefore commend new clauses 5, 6 and 7 and Government amendments 12 to 66 to the House, and I look forward to hon. Members’ contributions.
Charlie Maynard (Witney) (LD)
The Bill, and the Budget it derives from, demonstrates clearly that the Chancellor has implemented stealth tax grabs that will hit some of the lowest paid the hardest, through extending a freeze on income tax thresholds and the national insurance contributions increases which suppress employment and wages. It is full of short-sighted harmful decisions that the Liberal Democrats cannot support. Our amendments aim to highlight and reduce some of its more harmful impacts.
I will focus on four particular areas, the first of which is the impact of frozen income tax thresholds. New clauses 15 to 17 would secure additional information and analysis about their impact. As the worrying figures from the OBR suggest, continuing to freeze income tax thresholds will drag an extra 1 million pensioners into paying income tax for the first time by 2030-31, unless the Government act.