Oral Answers to Questions

Nigel Huddleston Excerpts

Tuesday 29th October 2024 Commons Chamber

[Mr Speaker]

I call the shadow Minister.

[Nigel Huddleston (Droitwich and Evesham) (Con)]

We on the Conservative Benches are deeply concerned about all those who will lose their winter fuel payments under Labour. Some pensioners will keep the winter fuel payment if they claim pension credit, but we know that some will not apply or will have difficulty applying. Can the Minister confirm how many people the Treasury assumes are eligible for pension credit but will not claim it, therefore losing their winter fuel payment, and what is the Treasury doing to close that gap?

[Emma Reynolds]

As the hon. Gentleman will understand, the estimates of how many people might be eligible for pension credit are an imperfect science—they are based on a survey. Means-testing what is a very complex benefit, as all means-tested benefits are, requires an assessment of not only people’s income but their savings; it is about pensioner household units, too, so it is a complex set of procedures. All I can say is that I am glad we are targeting support at those most in need, something that was outlined in the 2017 Conservative party manifesto, which stated:

“we will means-test Winter Fuel Payments, focusing assistance on the least well-off pensioners, who are most at risk of fuel poverty.”

Business Property Relief and Agricultural Property Relief

Nigel Huddleston Excerpts

Thursday 17th October 2024 Westminster Hall

[Nigel Huddleston (Droitwich and Evesham) (Con)]

It is a pleasure to serve under your chairmanship, Dr Huq. I congratulate my hon. Friend the Member for Gordon and Buchan (Harriet Cross) on securing this important debate. I thank all hon. Members for their thoughtful contributions: I was particularly entertained to hear everybody’s friend the hon. Member for Strangford (Jim Shannon) say that he does not give anybody a hard time. I warn the Minister that he can expect persistent, relentless and vigorous but polite nudging; it may not be defined as a hard time, but it certainly sometimes feels like that. It is very polite, I have to say.

A few other points were raised today, but I will not delve into all the issues. Under different circumstances, I would be happy to have a debate with the hon. Member for Hexham (Joe Morris) about international trade. Having negotiated some of the trade deals, I can reassure him that the NFU and others had a very strong voice and that we listened to them very carefully. Their opinions, views and points were very often made. We tried to put safeguards in place; that has not always been acknowledged, but that is a debate for another day. The Liberal Democrat spokesperson, the hon. Member for Woking (Mr Forster), raised a bunch of other issues—again, a debate for another day.

Just two weeks before the Government deliver the Budget, I am aware that the Minister will be unwilling—and, to be fair, unable—to comment in detail on the issues that have been raised today. Nevertheless, I think it important that he and the Treasury team hear and reflect on the concerns and fears that Members have expressed on behalf of their constituents and other stakeholders who could be considerably affected by any changes to inheritance tax relief and particularly to business property relief and agricultural property relief.

My party supports wealth creation, which is important and which helps to pay for our public services, but we also understand the importance of ensuring that wealthy individuals make a fair contribution and pay tax appropriately. Earlier this year, the Minister and I had a debate about the broader issues of inheritance tax in which we recognised that we do not have a wealth tax in this country, but that there are taxes on wealth. Inheritance tax is an important such tax: it brought in something like £7.6 billion last year.

We have a progressive tax system. The top 1% of income taxpayers pay 28% of all income tax, so they contribute a huge amount. The vast majority of estates do not pay inheritance tax: only about 5% do so, because there are so many exemptions and reliefs. It is important to recognise those reliefs as legitimate. There is abuse in the tax system—there are loopholes that need closing, and HM Revenue and Customs, the Treasury and others spend a lot of time closing them—but let us not forget that the reliefs are there for a reason. Business property relief and agricultural property relief are perfectly legitimate reliefs. Without them, many businesses, including farms, would cease to exist or would be broken up on the passing of their owner. The reliefs form a critical part of overall business planning and especially of succession planning.

Many businesses, particularly small businesses, have expressed anxiety about the prospect of changes to or the abolition of business property relief. Currently, business relief is applied at either 50% or 100% on qualifying businesses when working out how much inheritance tax should be paid. That allows businesses and business assets or shares to be passed on to the next generation without the need to jeopardise the viability or even existence of vital businesses. Without that relief, many more family-owned businesses would have to be sold or broken up to pay a big inheritance tax bill. Prior to the election, many businesses and business bodies, including the Federation of Small Businesses, believed that they had heard and received commitments and assurances on inheritance tax and BPR from the Labour party. Many small businesses in my constituency and across the country seek the reiteration of those assurances.

BPR also plays an important part in attracting and retaining certain investments, for example in the alternative investment market. According to some analysts, the removal of BPR from the alternative investment market could result in a loss of between £14 billion and £21 billion in value to UK shareholders and would permanently damage the AIM. Given the importance of inheritance tax relief to the AIM, they are also looking for the Government to confirm its continuation. Uncertainty and speculation around its continuation may already be jeopardising investment.

Many hon. Members’ speeches have focused on agricultural property relief, because it is vital to the continuation of our rural way of life and our countryside. The NFU, the Country Land and Business Association and others are concerned about the renewed uncertainty and the impact on farming, including on tenant farmers. Some fear that APR may be removed and that some form of BPR may be kept, but even that could deter landowners from letting their land to tenants; the right hon. Member for Orkney and Shetland (Mr Carmichael) spoke about some of the further considerations and concerns for tenant farmers in particular.

As many colleagues have said, many farms would simply not survive the imposition of inheritance tax. Families who have farmed the land for generations could be forced to give up their businesses, their farms and their homes, which could jeopardise the sustainability of the rural economy, as well as undermining efforts towards greater self-sufficiency in food production and compromising environmental goals broadly agreed by both the former Government and the current Government.

The Secretary of State for Environment, Food and Rural Affairs confirmed last year, when he was the shadow Secretary of State, that the Labour party had no plans to change inheritance tax, including APR, if Labour won the election. Sadly, speculation has since arisen, and I do not believe that further assurances have been given by the Secretary of State or the Treasury. If the Minister can provide any certainty or even an indication to provide additional confidence, I and many of my constituents will welcome it, as will many other hon. Members’ constituents, many farmers, many investors and many business owners across the country.

Labour did not mention APR or BPR in its manifesto, nor did it make statements about them during the election campaign, but it clearly stated that it would not increase taxes on working people. As we have heard today, farmers and family business owners are very clearly working people; my hon. Friend the Member for Chester South and Eddisbury (Aphra Brandreth) made that point very well.

Given all the comments we have heard from the Labour party, I hope the Minister agrees that it is perfectly reasonable to assume that there are no plans, and should be no plans, to change the inheritance tax relief system, especially because those reliefs play such an important part in investment decisions and business planning. I therefore look forward to the Minister’s speech providing at least some of the reassurances that we seek today.

VAT: Independent Schools

Nigel Huddleston Excerpts

Tuesday 8th October 2024 Commons Chamber

[Nigel Huddleston (Droitwich and Evesham) (Con)]

It is an honour to follow Citizen Smith over there.

In the large number of contributions today, we have seen the importance of this issue and the alarm felt by many Members and their constituents about the Government’s proposal. I am sorry to say that we have also had a lot of 1970s politics of envy today. We believe in evidence-based decision making, and as many Members have pointed out, it is becoming increasingly clear that Labour’s planned education taxes—removing VAT and business rate exemptions from independent schools— will not do what is claimed.

I will move on to the details in a moment, but may I first congratulate those who have delivered their maiden speeches today? I thank them all for making gracious comments about their predecessors. I learned something about each of them today. The hon. Member for North East Derbyshire (Louise Jones) spoke eloquently and lovingly about her beautiful constituency, as did my hon. Friend the Member for Isle of Wight East (Joe Robertson), who brought back many holiday memories for me. The hon. Member for Glasgow East (John Grady) gave us all good advice on naming children in Glasgow. The hon. Member for Tipton and Wednesbury (Antonia Bance) may or may not be aware that we share something in common, as we were both student union sabbatical officers, although in my case a few years earlier. The hon. Member for Horsham (John Milne) gave perhaps the most eclectic speech today, mentioning Daleks, potholes and Ann Widdecombe all in one speech.

I am afraid that I will not be so gracious about some other comments we have heard today from Government Members, who still do not seem to realise that they are now in government and their job is to talk the country up. They have constantly talked down not only the country, but the education system. Let me remind them that when we left office, education standards were going up and per pupil funding was at record levels. In contrast, when Labour was in office, we were falling in the league tables. What a brass neck Labour Members have, when we look at Labour’s record in Wales. We have been backing our brilliant teachers, and I would hope that they would do the same.

The motivations behind this policy are clearly questionable. The impact assessment is non-existent and the savings illusory. There are so many potential unintended consequences and uncertainties around these policies that, at the very least, the Government need to postpone implementation, although it would be better to scrap the plans altogether. They are also moving away from a long-held principle that we used to agree on across the House that educational services are not taxed at all. It is a terrible thing that they are now bringing in.

We have five key categories of concern: the impact on state schools; the impact on Government finances; the timing of the proposals; the consideration of exemptions; and the impact on SEND and EHCPs. I will not repeat all my comments from the debate we had earlier, but it is so clear that this policy will not only have a detrimental impact on the independent schools sector, but negatively impact the state sector, because the imposition of a 20% VAT hike overnight will mean that some families will no longer be able to afford the fees. Inevitably that will mean children leaving the private sector and moving to the state system, putting an additional burden on many local state schools, some of which do not have the capacity. As I said this morning, it is not fearmongering or scaremongering; it is happening already and we are already seeing it in schools. According to some forecasts, instead of the predicted £1.5 billion saving, this policy could cost the taxpayer money.

How extraordinary to choose this policy area to try to eke out some cash when so many other options are available, if the Government were brave enough. Out of total Government spending of more than £1.2 trillion, is this really the policy that they want to prioritise?

On the topic of overall Government finances, we have not yet heard clearly whether the Department for Education will get more funding from the Treasury if the number of state school pupils exceeds expectations. Will they be expected to pay it out of existing budgets? Have the Government set aside capital for additional school spaces if it is needed?

Regarding the timing of the proposals, many Members have mentioned that it is beyond belief that the Government are bringing in this policy in the middle of the school year, when schools are simply not ready for it. It is not fair on the independent sector to expect schools to get their heads around new legislation, register for VAT and implement new systems and processes in literally a matter of weeks and before Christmas. That will not happen. We have also not heard whether the Government will create exemptions or special considerations for all these areas: military families, students on music and dance schemes, children attending small schools, language schools or religious schools, those paying low fees or on bursaries, and children in exam years who may have to move to another school that does not offer their curriculum.

What are the Government doing about pupils with special educational needs and those with an EHCP or in the process of gaining one? If, as many predict, there is a displacement of children with SEND and EHCPs into the state sector, is there the capacity for that? Is there adequate additional funding support planned for local authorities to deal with that predicted increase in demand?

I wish to make a couple of other brief points before concluding. As a Conservative, I believe in choice, and I will not criticise choices made by parents about their children’s education. I have no qualms, however, about criticising hypocrisy. The irony that I stand here as a proud product of a state comprehensive education defending independent schools while the Exchequer Secretary to the Treasury who spoke earlier, a product of a private education, is pursuing a policy that could undermine independent schools is not lost on me or others. Many Government Members attended independent schools or sent or are sending their own children to them, and yet they are determined to increase the costs on others, depriving many families of the choice they themselves had.

I am glad to see the Secretary of State for Education now in her place after being conspicuously absent. Perhaps she will take the opportunity to apologise for the tweet. Parents who send their children to independent schools pay twice for their children’s education and deserve better than to be treated with contempt by their Government’s Education Secretary. The divisive tweet that she put out last weekend was shockingly ill-judged and ill-informed, sneering and smirking about embossed paper and swimming pools. Does she really not understand or recognise that not every independent school is like Eton or Harrow? It betrays an incredible lack of awareness and poor knowledge of the facilities and financial status of many independent schools. It demonstrated that the policy is being promoted not on evidence but on envy and spite—ill-informed and misplaced envy at that.

[Simon Hoare]

I agree entirely with what my hon. Friend has said. Will he add to the indictment of the Secretary of State the fact that she failed signally to realise that she is the Secretary of State for all pupils, whether they are in the independent or the state sector? The divisive language that she used was a very rude signal of two digits to those families who take a decision that she does not like.

[Nigel Huddleston]

My hon. Friend puts it well. I do not have to add to his comments.

This is a rushed and ill-judged policy that will not raise the money the Government assumed it would, undermine the viability of many independent schools, put immense pressure on the state school system and put in jeopardy the education prospects of thousands of students, including many with special needs. We implore Ministers to reconsider.

Independent Schools: VAT and Business Rates Exemptions

Nigel Huddleston Excerpts

Tuesday 8th October 2024 Westminster Hall

[Nigel Huddleston (Droitwich and Evesham) (Con)]

It is a pleasure to serve under your chairmanship today, Dame Caroline. May I first congratulate my hon. Friend and constituency neighbour, the Member for Bromsgrove (Bradley Thomas) on securing this important debate? I thank all those who have participated today; we have heard some very insightful contributions. I am also glad to have the shadow Secretary of State for Education, my right hon. Friend the Member for East Hampshire (Damian Hinds), sitting beside me today.

We can see from the large number of contributions, particularly from Opposition Members, how important this issue is to Members and their constituents, many of whom are greatly distressed by the Government’s proposals. We believe they are flawed in both design and execution, or at least planned execution, which is perhaps why so few Members from the Government party are here to defend them today. The policy will move away from a long-held principle that educational services are not taxed in this country, or in most developed economies. We have five broad categories of concern: the impact on state schools, the impact on overall Government finances, the timing of the proposals, consideration of exemptions, and the impact on SEND and EHCP provision. I shall turn to each of these briefly.

First, it is clear that the policy will have a detrimental impact not only on the independent sector, but on the state sector. The imposition of a 20% VAT tax hike overnight will clearly mean that some families will no longer be able to afford the fees. That is basic economics. In addition, the imposition of business rates will further disrupt the business model of independent schools and make less money available for bursaries and subsidies, which many parents rely on. Inevitably, that will mean children leaving the private sector and moving to the state system, putting an additional burden on many state schools, some of which do not have the capacity. It will also make fewer spaces available at good and outstanding local state schools where spaces would otherwise have been available, because more pupils would have taken the independent route. This is not a fear or scaremongering; this is reality. It is happening now.

According to the Independent Schools Council, more than 10,000 pupils have already been pulled from independent schools. One think-tank has estimated that far from bringing additional money into the Treasury, the policy could cost the taxpayer £1.6 billion, which brings me to my second point about the impact on overall Government finances.

Out of total Government spending of more than £1.2 trillion, is this policy really the top target of the new Government? It smacks of the politics of envy, not of careful deliberation and consideration of evidence. On the topic of overall Government finances, will the Department for Education get more funding from the Treasury if the number of state pupils exceeds expectations, or will they be expected to pay for it within existing budgets? Have the Government set aside capital for additional new school places if that is needed?

Regarding the timing of the proposals, it is unfathomable why the Government are considering introducing this policy in the middle of the school year. Why? It does not make any sense to cause so much mid-year disruption to so many schools, pupils and families.

[Sir Alec Shelbrooke]

This will clearly be open to legal challenge, which stands very little chance of being in the courts within the next three months. As it gets held up, will this policy not cause mass disruption by being introduced in the middle of the academic year?

[Nigel Huddleston]

My right hon. Friend raises another important point, and I believe some legal challenges are already in place. Regarding timing, is the Minister truly confident that the policy could be implemented within weeks? Is His Majesty’s Revenue and Customs adequately resourced and prepared for it? Is the legislation ready? Is the legislation and guidance sufficiently clear? Even if the answer to all of the above is yes, is it fair on independent schools to expect them to suddenly get their heads around new legislation, register for VAT, implement new systems and processes, and logistically carry out the execution of this policy, all before Christmas? The answer is clearly no. I implore the Minister at least to delay the implementation, and carefully consider some exemptions and special considerations, my fourth category of concerns, which have been raised by many hon. Members today.

The rushed policy appears not to have properly considered carve-outs for pupils from military families, students on the music and dance scheme, children attending small or small faith schools, those paying low fees or who are on bursaries, or children in exam years who may have to move to another school that does not offer their current subject, offers different syllabuses, or has different examination boards. I hope that when we finally see the impact assessment, we will see some consideration of those matters.

My fifth category of concern is what consideration has been given to pupils with special educational needs and those with an EHCP or who are in the process of getting an EHCP.

[Ben Coleman]

Given that the situation confronting the Government is entirely of the previous Government’s making, will the hon. Member apologise for the terrible state of the SEND system?

[Nigel Huddleston]

I applaud the hon. Gentleman for his bravery, given that 2,500 pupils attend independent schools in his constituency. I think they will have a different view from his.

[Ben Coleman]

Will he apologise?

[Dame Caroline Dinenage (in the Chair)]

Order.

[Nigel Huddleston]

As for provision, as my right hon. Friend will articulate this afternoon, more than 200,000 EHCPs were issued with SEND provision. We provided more support than the Labour Government ever did.

If, as many predict, there is displacement of children with SEND and EHCPs into the state sector, is there capacity? Is there adequate additional financial support for local authorities to deal with the predicted surge in demand? If the answer is no, or I do not know, to any of those questions, the Government must delay this policy.

Before I conclude, I ask the Minister to have the decency to recognise the apparent hypocrisy of so many Members on the Government Benches, including himself, who attended independent schools or send their children to one, yet are now determined to increase the costs on others, depriving many families of the choice that they benefited from.

I also ask him to apologise on behalf of the Secretary of State for Education for her appalling divisive tweet over the weekend, which betrays her lack of awareness of the realities of independent schools across the country. Headteachers, teachers and parents in both the state and independent sectors, unions, tax experts and think tanks are all appealing to the Government to think twice about this policy. I appeal to the Minister to listen and act accordingly.

Budget Responsibility Bill

Nigel Huddleston Excerpts

Committee of the whole House
Wednesday 4th September 2024 Commons Chamber

[Nigel Huddleston (Droitwich and Evesham) (Con)]

I beg to move amendment 9, page 1, line 14, at end insert—

“(c) or any changes to the government’s fiscal targets.”

This amendment requires the OBR to produce and publish a section 4(3) report at the time new fiscal rules are announced by the Treasury.

[The Chairman]

With this is will be convenient to take the following:

Amendment 2, page 1, line 25, at end insert—

“(2A) In any case where the Office has acted in accordance with subsection (2), it may notify the Independent Adviser on Ministers’ Interests of the circumstances in any case where it considers those circumstances may be relevant to—

(a) the Ministerial Code, or

(b) the functions of the Independent Adviser on Ministers’ Interests.”

This amendment enables the OBR to notify the Independent Adviser on Ministers’ Interests where the OBR considers that any instance where the Treasury had not requested a report under section 4A(1) in advance may give rise to consideration of compliance with the Ministerial Code.

Amendment 5, page 1, line 25, at end insert—

“(2A) Where the OBR prepares a report in accordance with subsection (1) or (2), it must take account of the impact of the measure or measures on—

(a) the UK’s compliance with, and

(b) the fiscal cost of meeting,

the UK’s net zero target as set in section 1(2) of the Climate Change Act 2008.”

This amendment requires the OBR to report on the impact of fiscally significant measures announced by Government on the UK’s statutory net zero target.

Amendment 1, page 2, line 4, at end insert “or

(b) the measure, or combination of measures, is likely to have an impact on—

(i) the cost of government borrowing,

(ii) interest rates, or

(iii) the rate of growth of gross domestic product.”

This amendment broadens the definition of fiscally significant measures to those which fall below the costing threshold, but have wider fiscal effects, by affecting either the cost of government borrowing, interest rates or rates of economic growth.

Amendment 6, page 2, line 4, at end insert

“or if the condition in subsection (3A) is met.”

See the statement for Amendment 7.

Amendment 7, page 2, line 6, at end insert—

“(3A) The condition in this subsection is that the measure, or combination of measures, forms part of category of measures with a cumulative impact on—

(a) public sector net debt,

(b) public sector contingent liabilities, or

(c) both,

that exceeds a specified percentage of the gross domestic product for a specified period.

“Specified” means specified in, or determined in accordance with, the Charter for Budget Responsibility”

The purpose of this amendment is to extend the definition of fiscally significant measures to include measures with a cumulative impact on public sector net debt or contingent liabilities when taken together with other measures in the same category, such as public projects with private sector partners.

Amendment 3, page 2, line 16, leave out “28” and insert “56”.

See the statement for Amendment 4.

Amendment 4, page 2, line 17, at end insert—

“(6A) After the publication of a draft under subsection (6), the Treasury must consult—

(a) the Office for Budget Responsibility,

(b) the Treasury Committee of the House of Commons, and

(c) such other persons as the Treasury considers appropriate.

(6B) When a modified Charter so as to include provision by virtue of this section is laid before Parliament, the Treasury must also lay before Parliament a report on the outcome of consultation under subsection (6A).”

The purpose of this amendment is to impose a requirement on the Treasury to undertake a full consultation and publish the outcome of that consultation prior to revision of the Charter for the purposes of the Bill.

Clause 1 stand part.

Clause 2 stand part.

Amendment 10, Title, after “measures” insert

“and of any changes to the government’s fiscal targets”.

This amendment is consequential to Amendment 9. It would amend the long title of the Bill.

[Nigel Huddleston]

Thank you very much, Madam Chair. May I first take the opportunity to congratulate you on your election? I promise to try not to try your patience over the coming weeks, years and so on, but we will see how things go.

I wish primarily to speak today to amendment 9 and, of course, consequential amendment 10, which effectively seek to ensure that the fiscal lock proposed in the Bill should also include any changes to the fiscal rules and would require the Office for Budget Responsibility to produce a report on their effect on public finances. The Office for Budget Responsibility was of course constructed by a Conservative Chancellor following the poor forecasting record of the previous Labour Government. Between 2000 and 2010, the then Labour Government’s forecasts for economic growth were out by an average of £13 billion, and their forecasts for the budget deficit three years ahead were out by an average of £40 billion. Their forecasts therefore lacked credibility, and to re-establish confidence and credibility the OBR was created by the Conservative Government.

Labour lacked economic credibility in the past, and I am afraid it still lacks it now. The facts simply do not stand up the false claim that the Government have inherited the worst economic circumstances since the second world war; they transparently have not. Contrary to the rewriting of history that the current Labour Government are attempting, when we took over from Labour back in 2010, inflation was 3.4%. When they took over from us, it was 2.2%. The annual deficit is half what we inherited in 2010, unemployment is about half what it was in 2010, and we handed Labour the fastest economic growth in the G7. The dominant political and economic narrative since the second world war is in fact, as has been widely commented on, that every single Labour Government end up with unemployment higher at the end of their time in power than when they took over from the Conservatives preceding them.

The British public should not be taken for fools. Just because Labour keeps claiming something, that does not mean that it suddenly becomes true, which is why clarity over plans and rules is so important. The fiscal rules are of course restrictions on fiscal policy set by the Government to constrain their own decisions on spending and taxes. The fiscal rules set by the previous Government said that the debt to GDP ratio should be falling within a five-year horizon, and that the ratio of the annual budget deficit to GDP should be below 3% by the end of the same period. Labour’s manifesto for the election proposed the following fiscal rules: balancing the current budget, so that day-to-day costs are met by revenues, and that debt must be falling as a share of the economy by the fifth year of the forecast. On the surface, therefore, the debt rules appear to be broadly the same under the new Government. The Government have even said that they have an “ironclad” commitment to reduce Government debt. It is therefore critical what definition of debt is used for the fiscal rules. Clearly, any changes to the fiscal rules are financially significant decisions because they affect how much the Government can borrow and spend.

On Second Reading, the Exchequer Secretary to the Treasury said:

“Our fiscal rules are non-negotiable.”—[Official Report, 30 July 2024; Vol. 752, c. 1263.]

Great, but why then has the Chancellor repeatedly failed to rule out that she will change the definition of debt in her fiscal rules to allow, presumably, for massive borrowing? The Government cannot run from the scrutiny that they should be subjected to if they are considering making such a change. We believe that our amendment requiring an OBR report on changes to the fiscal rules is entirely consistent with the Government’s stated policy intent, and should therefore be fairly uncontentious. After all, on Second Reading, the Chief Secretary to the Treasury said that

“the announcement of a fiscally significant measure should always be accompanied by an independent assessment of its economic and fiscal implications, in order to support transparency and accountability.”—[Official Report, 30 July 2024; Vol. 752, c. 1211.]

We agree, and not accepting our amendment would be contrary to those goals, because clearly changing the fiscal rules would be a fiscally significant measure in anybody’s book. Furthermore, the Chief Secretary said that

“fiscal discipline and sound money is the bedrock of our plans.”—[Official Report, 30 July 2024; Vol. 752, c. 1213.]

Well, changing the fiscal rules would be changing the foundations and that bedrock.

Transparency and clarity are important in relation to the public finances, because Ministers should never forget that it is not their money that they are spending; it is the public’s money. The public have a right to know how their money is being spent, and government is about making difficult choices with limited resources. With Government spending being above £1.2 trillion per year, the British public recognise that the Government clearly have choices. It is not an endless supply of money, but it is a very, very large amount. In the last few weeks, the new Labour Government chose to spend the public’s money on pay settlements for their union friends rather than on supporting pensioners. Those settlements are estimated to cost about £10 billion. They also chose to spend £8.3 billion on a public energy company and £7.3 billion on a national wealth fund, so far from inheriting a £22-billion black hole, they have actually just spent £25 billion creating one within their first few weeks of coming to power.

[Andrew Griffith (Arundel and South Downs) (Con)]

My hon. Friend is making a fantastic speech on the importance of being responsible with our public finances. Much of the Bill is concerned with responsibility and transparency. Does he know whether the Government published an impact assessment when they took away the winter fuel allowance?

[Nigel Huddleston]

I thank my hon. Friend for that point. My understanding is that the Government have not published an impact assessment, as would normally be the case for something with such a significant impact. I think that speaks to the whole narrative that we are hearing from the Government: claiming one thing when the facts speak differently. As I said, far from inheriting a £22 billion black hole, they have actually spent, or committed to spending, an additional £25 billion. That is a choice that they made, so the claim that the Labour Government are having to take the winter fuel allowance away from millions of pensioners as a response to unexpected financial constraints simply does not stack up against the facts, or indeed the words of the Chancellor herself, who on 25 March 2014—yes, a decade ago—said:

“We are the party who have said that we will cut the winter fuel allowance for the richest pensioners and means-test that benefit to save money”.—[Official Report, 25 March 2014; Vol. 578, c. 174.]

That is a direct quote in Hansard from the current Chancellor, so no, the Government’s restriction of winter fuel payments is not a response to financial circumstance; it is a long-established, clearly stated Labour policy intent—a deliberate policy choice, but a policy that they conveniently forgot to tell the public about in the run-up to the last election.

I hope, however, that the Government can be straight with the public on this point about the fiscal rules, accept the amendment that we are proposing, and provide assurance to all Members and the outside world that there is no sleight of hand here. We want the Bill to work as they say it is intended to, and to include financially significant decisions, such as on the levels of Government borrowing and the fiscal rules. I would therefore appreciate it if the Chief Secretary to the Treasury confirmed in his wind-up that the Government do not intend to change the definition of debt in their fiscal rules or practise some accounting trick to hide the level of Government borrowing, and that they do indeed wish to be clear and transparent about the public finances. If Labour Members vote against our amendment, it will merely prove that they are planning to change their fiscal rules in the Budget to borrow more money, increase debt, and run away from independent OBR scrutiny—the very opposite of the stated intent of the Bill.

[Madam Deputy Speaker (Ms Ghani)]

I call Dr Jeevun Sandher to make his maiden speech.

--- Later in debate ---

[The Second Deputy Chairman of Ways and Means (Caroline Nokes)]

I call shadow Minister Nigel Huddleston.

[Nigel Huddleston]

I will not detain the House long by repeating the arguments that I made in my opening comments, but I am disappointed by the Minister’s response, and in particular by his refusal to accept our amendments. It is alarming that he is refusing to do so because, as I outlined, I believe they are consistent with the goals of the Bill overall, and I think the credibility of the Bill will be seriously undermined if it does not include the fiscal rules. I like the Minister a lot. We go back a way and have always had civil conversations, but if he does not believe or consider the level, type and definition of debt to be “fiscally significant”, then with the greatest respect perhaps the Treasury is not the right home for him. They are transparently fiscally significant, and an important part of the consideration we are talking about today.

[Darren Jones]

I thank the hon. Gentleman for giving way, and for inviting me to suggest whether I should try to find a job in another Department. I just point out that, having arrived at the Treasury, I have seen the impact of fiscally significant levels of debt after 14 years of the Conservative Government. Has he got anything to say to the House on that matter?

[Nigel Huddleston]

Yes, I have indeed. As I outlined in my original statement, the arguments the right hon. Member is making do not stack up with the facts. The economic circumstances that Labour inherited are better in many areas than those we inherited from them back in 2010. The economy is the fastest growing in the G7. On unemployment, every Labour Government since the second world war has increased it while in power, for us to then clear up and reduce it when we take over. Inflation was lower when Labour took power then when we inherited it, and annual debt was higher when we took over in 2010.

Labour Members keep saying all those things, but the challenge is that it does not stack up with the facts. They make arguments about the level of debt, as I outlined earlier, but they have already announced £10 billion for inflation-busting salary increasing for their union mates, £8 billion on energy provisions, and £7 billion on the national wealth fund. That is £25 billion of additional money that they have spent. If there is a black hole in the finances, it is clearly one of their own making by the announcements they have made since coming into government. That £25 billion is a huge amount of money, but I will finish discussing those points, because we had this debate earlier.

[Darren Jones]

rose—

[Nigel Huddleston]

I will not give way at the moment, because I want to move on to some more positive things.

[The Comptroller of His Majesty’s Household (Chris Elmore)]

There is loads of time.

[Nigel Huddleston]

We have Third Reading as well, so let us enjoy ourselves. Just because the Government keep repeating the narrative does not make it true. I am sure they will continue to do so, but the £25 billion of additional spending that I have just outlined is a choice they have made. The arguments they are having to make—that they are having to cut payments to pensioners in response to the circumstances they have inherited—are not true because, as I outlined in my opening speech, it is a deliberate, long-stated policy choice articulated by the current Chancellor a decade ago. It is not a response to circumstances, but deliberate Labour policy.

On a more positive note, I congratulate all those who have made their maiden speeches today: the hon. Members for Loughborough (Dr Sandher), for Portsmouth North (Amanda Martin), for Swindon North (Will Stone), for Chelmsford (Marie Goldman), for Southend East and Rochford (Mr Alaba), for Woking (Mr Forster), for Rother Valley (Jake Richards), for Wokingham (Clive Jones), for Dudley (Sonia Kumar), for Rochester and Strood (Lauren Edwards), for Plymouth Moor View (Fred Thomas), and for Northampton North (Lucy Rigby). They have made incredible contributions. The breadth of experience that they bring to this Parliament is astounding, and I am largely talking here about Government Members. I say it with a great degree of respect, because in many circumstances—in fact, in nearly every single circumstance—they have replaced good friends of mine who contributed significantly to this House. They all have big shoes to fill, but what they have said today was impressive. In particular, those who spoke without notes are a lesson to us all.

What a beautiful tour we had around the United Kingdom. Everyone who spoke today spoke eloquently about their constituencies and their constituents and showcased their rich heritage and rich history. It was incredibly impressive. I am sure their constituents will be proud of what they have said. With that, I will finish my comments, but the debate will continue.

Question put, That the amendment be made.

Oral Answers to Questions

Nigel Huddleston Excerpts

Tuesday 3rd September 2024 Commons Chamber

[Mr Speaker]

Don’t worry. I now call the shadow Minister.

[Nigel Huddleston (Droitwich and Evesham) (Con)]

I congratulate the Chancellor and the entire Treasury team on their appointments. We have always had civil, albeit occasionally robust, interactions, and I am sure that will continue, but it is now our job to hold them to account for the important decisions they make at the Treasury. During the election, Labour promised on more than 50 occasions not to increase taxes on working people. Does it now recognise that working people have pensions too, and can the Chancellor give those people, who are saving for the future, peace of mind by confirming that the Government will not increase taxes on pensions in the upcoming Budget?

Finance (No.2) Bill

Nigel Huddleston Excerpts

3rd reading
Thursday 23rd May 2024 Commons Chamber

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

I beg to move, That the Bill now be read the Third time.

May I take the opportunity to thank you, Madam Deputy Speaker, and the other Madam Deputy Speaker for your professionalism, kindness and robustness in this place? You will be sorely missed, and I express my appreciation to all those who have announced that they will be standing down at this election and thank them for their service in this House. I think I speak for everybody when I say that everybody who comes into this place does so with very positive motivations, because they want to make the world a better place for their children and grandchildren. That may sound trite, but it is a motivation we all share. We may disagree on the route to achieve that, but anybody who comes into this place does so with incredible professionalism, and we should all thank them for that service.

Moving on to the politics and policy of today, this Bill helps to deliver the priorities of the Prime Minister and the Government following the autumn statement and the spring Budget. The economy has vastly improved. It is growing again. Real wages are increasing and, as we found out this week, inflation is down to its lowest figure in nearly three years. The Finance Bill builds on that economic improvement by rewarding work, encouraging investment in our economy and boosting home ownership.

As the two recent fiscal events outlined, we have rewarded work by making national insurance tax cuts. Some 27 million employees will get an average tax cut of £900 a year, and 2 million self-employed people will get a tax cut averaging £700. That is the largest ever cut to employee and self-employed national insurance, and this Bill furthers the work done on rewarding work by increasing the high income child benefit charge threshold from £50,000 to £60,000. In addition, the rate of the charge will be halved, so that child benefit is not repaid in full until someone earns £80,000, taking 170,000 families out of paying this tax charge. Some 485,000 families will benefit by an average of £1,260 from these child benefit changes.

[Jim Shannon (Strangford) (DUP)]

I put on record my thanks to the Minister and the Government for that change. It is a policy that my party and I have pursued over a number of years. The Government took it on board and they are very kindly changing the law. I thank the Minister, but also the Government, because it is one of the things that we can put to our constituents, including my constituents in Strangford, and say, “Here is delivery of what you asked for. Here is what we did.”

[Nigel Huddleston]

I thank the hon. Gentleman for his gracious and pertinent intervention, as ever. I thank him and all those who have campaigned for this change, because we know it will make a difference to the budgets of many households across the country in what we recognise are still challenging times.

The Bill will drive investment in the economy through various measures, including additional support for our world-leading creative industries, and we are making tax reliefs for theatres, orchestras, museums and galleries permanent, at a rate of 45% for touring theatres, museums, galleries and touring productions, 40% for non-touring productions and 45% for orchestras. That will ensure that our creative industries have the support they need after the unprecedented economic shock of the pandemic.

We will further support the UK’s independent film sector through a new UK independent film tax credit, at a rate of 53% for films with lower budgets. That will support the production of UK independent films and the incubation of UK talent. Our creative sector is vital to our national life, and the Government are committed to supporting UK businesses in the sector.

This is also a Bill that will boost transactions in the housing market. It will cut the higher rate of capital gains tax on residential property from 28% to 24%, encouraging landlords and second home owners to sell their properties, which would in fact increase revenues because there would be more transactions. That will make more homes available to purchase for a variety of buyers, including, of course, first-time buyers.

We need to ensure that the property system is fit for purpose. The Government are clear that where policies are not meeting their objectives, we will take clear and decisive action. That is why we are abolishing multiple dwellings relief—a bulk purchase relief in the stamp duty land tax regime—from 1 June 2024. Abolition follows an external evaluation that found no strong evidence that the relief is meeting its original objective of supporting investment in the private rented sector. His Majesty’s Revenue and Customs has recorded many instances of abuse and attempted abuse.

We are amending the rules so that individuals buying a new lease over a leasehold residential property through a nominee or bare trustee will be able to claim first-time buyers’ relief on their stamp duty land tax bill. That change will ensure that, for example, victims of domestic abuse are not unfairly penalised if they wish to buy their first homes anonymously. It will ensure that those in difficult circumstances do not face additional barriers to purchasing homes.

The Bill will also make the tax system fairer by closing tax avoidance loopholes and making relevant changes to VAT.

I thank right hon. and hon. Members from across the House for their helpful and insightful contributions to the debates during the Bill’s quicker than expected passage. I thank the many stakeholders who have provided their views on the issues raised and provided evidence to the Public Bill Committee, as well as Treasury and HMRC officials and, of course, the House Clerks and officials who have supported us in getting the Bill to this point so quickly.

The Bill rewards work, encourages investment in our economy and boosts home ownership. It is part of the Government’s clear plan of action. For those reasons, I commend it to the House.

--- Later in debate ---

[Nigel Huddleston]

I thank those who contributed to the debate, and, of course, those who have contributed to debates on the Bill throughout its progress. I turn first to comments made by the hon. Member for Aberdeen North (Kirsty Blackman). I respect her views about scrutiny of Bills in this place. However, I hope that she recognises that finance Bills often contain many, many clauses, some of which have been developed over many years, been subject to multiple consultations, and had a huge amount of input. I appreciate that she acknowledged that a lot of written evidence, which is hugely valuable and very much appreciated, is also provided. The fact that she and her colleagues are pressing for a Division on the Bill this evening evidences that there is scrutiny, holding to account, and a diversity of opinion on these matters.

I disagree with many of the hon. Lady’s other comments. On who is better off, 27 million workers are better off because of the national insurance cut, and 2 million self-employed people are better off. If she does not believe that, I suggest that she looks at her payslips; she will see that national insurance is going down. That makes a meaningful difference. She may be sniffy about it, but £900 is a meaningful difference for an average worker—for many of my constituents, and constituents across the country. For those not in work, of course, we also increased benefits by 6.7%, and pensions by 8.5%. We Conservatives always make sure that all people in society are looked after.

The hon. Lady made comments about support with the cost of living. The Opposition consistently seem to have a collective sense of amnesia, and have completely forgotten the last five years and the global challenges that all economies faced, with the pandemic followed by the global cost of living crisis. This Government have had to intervene in a way that nobody anticipated. It meant that taxes had to be higher, but as soon as we get the opportunity—as soon as we have the choice—to bring them down, that is exactly what we will do, because we know how difficult this has been for people and want to put more money in their pockets as soon as we can. We have a plan, and it is working.

I always respect the opinions and views of my hon. Friend the Member for Waveney (Peter Aldous), and I am never alarmed or disturbed by his frequently holding me, and the Government, to account for policy decisions. I can give him some reassurance, though. The multiple dwellings relief is being abolished for very good reason: it is not working as intended. Of course, a considerable amount of money is involved. When we spend taxpayers’ money or allow a relief, we need to make sure that it has the intended impact. The relief was not working as intended, and was subject to considerable abuse, so we are abolishing it.

However, I can give my hon. Friend some assurance, particularly on certain issues that he mentioned. For example, large investors, including those in the build-to-rent sector who purchased six or more properties in a single transaction, can still continue to benefit from the non-residential rates of stamp duty land tax, which can be quite beneficial. We are engaged in discussions with stakeholders, including some of the bodies that he has mentioned, because we do not want there to be unintended consequences. We appreciate their input on this Bill, as always. I thank my hon. Friend for his fantastic interventions, as always. He is an amazing MP for his constituents, and I always appreciate his contributions.

I thank the hon. Member for Ealing North (James Murray) for his gracious comments. He is correct that what is written in Hansard and what the public see of our sometimes rather robust debates is not always a reflection of our generally positive relationships on a personal level. However, that does not mean we do not have robust disagreements on policy, and I am afraid that I will have to raise quite a few points of disagreement today.

Every single time I have appeared at the Dispatch Box, the hon. Gentleman has complained about the Government not calling a general election, and now that we have called a general election, he is still complaining. That really takes the biscuit. He continued with his familiar refrain; he never misses an opportunity to talk Britain down. I refer him to my earlier comments about our interventions during the pandemic and their immense £400 billion cost to the UK economy. I do not believe the Opposition opposed a single one of our interventions at the time, so it is a bit rich to complain about the obvious impact on taxation. If he had an alternative plan, I would have loved to have heard it then, and I would love to hear it now, but it is non-existent. The hon. Gentleman is hoping to alarm, disturb and depress the British public into voting Labour, which is not a particularly bright strategy. The British public deserve better, and we need to hear confidence and optimism, not pessimism, about the UK economy.

I will not repeat the comments I have made on many occasions about Labour’s ridiculous scaremongering on the national insurance cuts and the impact they could have on pensions. He knows that the cuts will not have a negative impact on pensions, for the obvious reason that I had hoped he would now understand. National insurance does not wholly pay for pensions, welfare or the NHS, so why on earth is Labour going around the country trying to scaremonger old people and people who rely on the NHS into believing otherwise? I do not know. It is not an admirable way to try to win an election.

The hon. Gentleman and his colleagues keep repeating the mantra of “a changed Labour party”. Maybe in some ways that is true. Labour has certainly gone from embracing the hard left of British politics to embracing the hard right. That unbelievable journey speaks volumes about Labour’s values: it has none. Or, as the old saying goes, “These are our values. If you don’t like them, don’t worry: we have others.” On policy, too, there is a constant string of flip-flops, U-turns and uncertainty, which I am sure we will see during the general election. We will be holding Labour to account.

For example, Labour has abolished its £28 billion green spending commitment, but it seems to have retained the policy. Is Labour abolishing tuition fees? Maybe not. Will it abolish the House of Lords? Maybe not. Will it return to free movement and the single market? Maybe not. Will it abolish universal credit? Maybe not. Will it increase income tax on top earners? Maybe not. Rent caps, the ultra low emission zone, bankers’ bonuses and zero-hours contracts—we have had constant flip-flops from the Opposition. Not even they know what their actual policy is. It completely lacks credibility. As I said, they cannot expect the British public to be taken for such a ride.

The British public know where they stand with the Conservatives, because we have a plan. They can see it in the recent autumn statement, the spring Budget and this Bill. No matter what stage of life they are at, they can be confident that the Conservatives are there to support them. With our childcare measures and the child benefit changes in this Bill, it is clear that when they bring children into this world, we are there for them. Through our national insurance cuts and our measures to support businesses, it is clear that we are there for those in work or running a business. If they have finished work and have retired, we have shown through the triple lock and other measures that we are always there for them.

We can have strong public services and a strong welfare system that helps the most vulnerable in society only if we also have a strong economy to generate the taxes to pay for them. A strong recovery is vital for both the public and the private sector. That means that we on this side of the House are unapologetically pro-business.

Despite the challenges of the past few years, we are now on a clear path to recovery: the economy is growing again; inflation is falling; real wages are increasing; and people who look at their pay packet will see that their national insurance taxes have been cut too. That is more money in people’s pockets because of the actions and decisions of this Government—we have a plan, whereas the Opposition do not. We cannot put that at risk, so stick with the Conservatives for a brighter future. I commend this Bill to the House.

Question put, That the Bill be now read the Third time.

Finance (No. 2) Bill

Nigel Huddleston Excerpts

Committee stage
Tuesday 21st May 2024 Public Bill Committees

[The Chair]

Copies of written evidence that the Committee receives will be made available in the Committee Room and will be circulated to Members by email.

Clause 5

Increase in thresholds to £60,000 and £80,000

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[Nigel Huddleston]

I thank my opposite numbers for their comments. I respectfully disagree with several of their points, and I will remind my opposite number, the hon. Member for Ealing North—as I do on almost every occasion—of the significant changes to the income tax threshold that the Conservative Government have brought in. It was £6,475 under Labour; it is now £12,570. That is a significant increase and it has taken many people out of paying income tax altogether, which is something we are very proud of.

The hon. Gentleman will be well aware that, as we have discussed on multiple occasions, the reason why taxes are higher than any of us would desire is the level of intervention required to support households and livelihoods during the pandemic and, more recently, the cost of living challenges since the invasion of Ukraine and the energy price shocks in particular. I would make a similar point to the hon. Member for Inverness, Nairn, Badenoch and Strathspey, who also made those points. I remind him that we have made interventions in cost of living support to the tune of about £100 billion. With respect, half a million people will benefit from the changes that we are introducing. HICBC is not a small amount. It is a meaningful amount of money for a large number of people, and it comes on top of the many other support measures that we have introduced.

I thank the hon. Member for Ealing North for pointing out the easements and the fact that there will be automatic backdating. Hopefully, that will be a relief and good news, and be positive for many families. Child benefit is normally backdated by three months, but because of the timing of the implementation, some could overlap two tax years. We are trying to make that simple and bring it into one tax year.

The hon. Gentleman mentioned the increase from £60,000 to £80,000 and the impact on marginal rates. The changes that were announced will reduce the total marginal effective tax rates, which includes income tax, employee national insurance contributions and HICBC, from about 64% to 53% for someone with, for example, two children. That is a good thing.

We recognise that high marginal rates introduce complexity to the tax system, but that needs to be weighed against other considerations when designing tax policy. The Government must ensure sure that they are committed to a fair tax system that supports strong public finances. Individuals will, as the hon. Gentleman pointed out, still be required to submit a self-assessment tax return to declare and pay their HICBC liability. However, the Government announced in July last year that we are taking steps to allow newly liable taxpayers to pay the HICBC through their tax code without the need to register for self-assessment. Further details on this improvement will be shared in due course.

The hon. Gentleman also mentioned the consultation on moving to a household basis. We will announce further details of the consultation in due course and, as with all tax policy, any changes would be considered as part of future fiscal events. The Chancellor announced that the Government will be consulting on moving the HICBC to a system based on household incomes, and that change will be delivered by April 2026. If the hon. Gentleman is patient, we will announce further details on that consultation in due course.

A point was made about communication. There have already been significant communications on the changes to HICBC. There has been a lot of online and offline activity from His Majesty’s Revenue and Customs, various Government Departments and others. The campaign to raise awareness also includes working with, for example, parenting platforms such as Bounty and Emma’s Diary, and issuing emails through third party partners, including childcare providers. The hon. Gentleman raised an important point about not just making the changes, but ensuring that everybody is aware of them, so that everybody who is intended to benefit is able to.

Question put and agreed to.

Clause 5 accordingly ordered to stand part of the Bill.

Clause 6

Reduction in higher CGT rate for residential property gains to 24%

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

[The Chair]

With this it will be convenient to debate clauses 7 to 11 stand part.

[Nigel Huddleston]

Clauses 6 to 11 are related to the property tax measures in the Bill. I hope that Members will forgive me, but this is a slightly longer speech, as I will talk through each clause. Indeed, it is the longest speech that I plan on giving today, although it is not too long—please do not have a heart attack; I will not be reading every one of these pieces of paper.

Clause 6 cuts the higher rate of capital gains tax, or CGT, charged on residential property gains from 28% to 24% from 6 April 2024. CGT is of course charged on the disposals of buy-to-lets and second homes. Main homes are exempt through private residence relief, which means for that the majority of residential property sales no CGT is paid at all. Where a disposal is liable to CGT, gains are taxed at a lower rate of 18% for any gains that fall within an individual’s basic rate band and at a higher rate for any gains above that.

The 28% higher rate was deterring some sales of residential properties, so the Government announced a 4 percentage point cut to the higher rate at spring Budget 2024. That will encourage more landlords and second home owners to sell their residential properties, making more homes available to the market for a variety of purchasers, including first-time buyers. The OBR forecasts that there will be around 60,000 more residential property transactions over the next five years owing to the cut. As more homes are bought and sold, the Exchequer is expected to raise an additional £690 million in revenue over that period. There will be no change to the lower rate of 18% for private residence relief.

Clause 7 concerns multiple dwellings relief, or MDR, which is a bulk purchase relief in the stamp duty land tax regime. The clause abolishes multiple dwellings relief from 1 June 2024. Multiple dwellings relief allows anyone purchasing two or more dwellings in a single transaction or in linked transactions to calculate their stamp duty based on the average value of the properties purchased, as opposed to their aggregate value. Multiple dwellings relief was introduced in 2011 with the intention of promoting investment in the private rented sector, but a recent external evaluation found no strong evidence that it has done so, meaning that the relief is not cost-effective and is therefore not acting as intended.

His Majesty’s Revenue and Customs has seen a high number of incorrect and abusive claims for the relief. Those have been driven by tax repayment agents, who often convince private individuals to make relief claims for the purchase of two dwellings when individuals have in fact only purchased one. One such example is somebody buying a large house with a separate indoor entertainment area, including a swimming pool and toilet, and that being counted as two properties when it is transparently one.

The changes made by clause 7 will abolish multiple dwellings relief for property transactions that complete on or after 1 June 2024. However, for contracts that were exchanged on or before 6 March 2024, relief will continue to apply regardless of when the contracts complete. The change will not impact those purchasing a single property. It will only increase the stamp duty payable by individuals or businesses purchasing two or more properties in a single transaction or as part of the same deal. Individuals or businesses purchasing six or more dwellings will continue to qualify for the non-residential rates of SDLT.

Clause 8 makes changes to ensure that first-time buyers’ relief from stamp duty land tax can be accessed by those purchasing new residential leases through a nominee or bare trustee, including victims of domestic abuse. A nominee is a person who holds the legal title of a property, while the beneficial ownership—the person who ultimately owns or controls the assets—is held by another person. A bare trust is a trust under which property is held by a person as trustee for another person who is fully entitled to all of the capital and income of the trust.

The measure also changes the definition of first-time buyers to ensure that individuals who use such arrangements cannot claim relief more than once. First-time buyers’ relief from SDLT is available where an individual who has not previously owned a dwelling purchases a home they intend to use as their only or main residence, but that is not currently available to individuals purchasing a new residential lease through a nominee or bare trustee.

The changes made by clause 8 will benefit certain first-time buyers of residential leasehold properties purchasing through a nominee or bare trustee, reducing the up-front cost of buying a home by allowing them to claim the relief they are entitled to. The changes bring those purchasers in line with purchases of residential freeholds and pre-existing leases using similar arrangements.

--- Later in debate ---

[The Chair]

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

[Nigel Huddleston]

If I may respond briefly, I will answer the perfectly reasonable questions raised by the hon. Member for Ealing North in relation to several points in multiple areas. Regarding the overall impact, and if I may reference the change of the capital gains tax rate from 28% to 24%, the OBR estimates that this costing will have a positive impact beyond the current forecasting period and generate a small long-term yield, too. Of course, beyond the forecasting period, it is difficult to estimate the exact amount.

On the points that the hon. Gentleman raised about MDR and other measures, it is interesting that although there are examples of abuse, it is also the case that only 32% of businesses buying property to let said that this relief had an important influence on their purchase decision at all and only 45% were aware of multiple dwellings relief before making a purchase decision. That feeds into the overall picture of MDR not fulfilling the original intent and purpose, which of course was to support investment in the private rented sector. Again, it is building the picture that the relief is no longer cost-effective. The Government are continuing to engage with stakeholders in the build-to-rent sector and other sectors to ensure that we understand their concerns and we will continue to listen to representations made to highlight any exception or unforeseen impacts that the abolition of MDR could have in the future.

I welcome the hon. Gentleman’s welcoming of many of the other measures. He asked whether they would be applied before the April deadline. They will not be applied retrospectively—for example, the updates on the registered social landlord exemption will not be applied retrospectively.

The hon. Gentleman mentioned the number of public bodies that have paid stamp duty at the 15% higher rate. The number of transactions—of those impacted previously —has been very small, and we therefore do not anticipate a huge impact.

Clauses 7 to 11 ordered to stand part of the Bill.

Clause 14

Additional relief for low-budget films with specified UK connection

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

[The Chair]

With this it will be convenient to discuss clause 15 stand part.

[Nigel Huddleston]

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

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

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

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

[James Murray]

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

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

[Nigel Huddleston]

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

Question put and agreed to.

Clause 14 accordingly ordered to stand part of the Bill.

Clause 15 ordered to stand part of the Bill.

Clause 16

Increase in theatre tax credit

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

[The Chair]

With this it will be convenient to discuss clauses 17 and 18 stand part.

[Nigel Huddleston]

We are powering through this— I have on my notes “tea break” by now, but it is not going to happen. That is no bad thing, and I appreciate the comments and input from hon. Members. I will repeat my thanks as well—a lot of work has gone into the measures that we are discussing today and many stakeholders have already contributed significant amounts, including through consultations.

One such area is what we are debating now: clauses 16 to 18 make changes to ensure that our world-leading theatres, orchestras and museums and galleries may continue to put on outstanding home-grown productions and attract inward investment. The orchestra, theatre, and museums and galleries exhibition tax reliefs have had rates of 45% for non-touring productions and 50% for touring productions and orchestral productions since October 2021, reflecting the unique challenges faced by those sectors during the covid-19 pandemic and the recovery period, which of course we are still in.

The rates were due to be reduced to 30% and 35% on 1 April 2025 and then return to their original levels of 20% and 25% on 1 April 2026. Clauses 16 and 17 change that so the tax reliefs will reduce to only 40% for non-touring productions and 45% for touring productions and orchestral productions on 1 April 2025, and will then remain at that level permanently. That was a key ask of the sector. Clause 18 removes the expiry date of the museums and galleries exhibition tax relief so that the relief similarly becomes permanent rather than ending on 1 April 2026.

The changes will benefit approximately 1,300 theatre companies, orchestra companies and museums and galleries that claim those tax reliefs on an annual basis. Our creative sector is vitally important to our national life and one of the fastest growing sectors in the UK economy. These clauses will bolster our theatres, orchestras and museums and galleries, ensuring that they remain among the best in the world. I commend the clauses to the Committee.

--- Later in debate ---

[Drew Hendry]

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

[Nigel Huddleston]

I do not have much more to add, other than to point out the strength of our creative industries in all four nations of the United Kingdom, which I am glad has been recognised across the Committee today. It is an incredible strength, and I am therefore pleased to hear today the very obvious cross-party agreement on continuing support for this vital sector.

Question put and agreed to.

Clause 16 accordingly ordered to stand part of the Bill.

Clauses 17 and 18 ordered to stand part of the Bill.

Clause 20

Collective investment schemes: co-ownership schemes

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

[The Exchequer Secretary to the Treasury (Gareth Davies)]

It is a great pleasure, as always, to see you in the Chair, Mrs Latham. Clause 20 begins the process of introducing legislation for a new type of investment fund—the reserved investor fund, which I will refer to from now on as the RIF. At Budget 2020, the Government announced a review of the UK’s funds regime, covering tax and relevant areas of regulation. The review had an overarching objective to make the UK a more attractive location to set up, manage and administer funds, as well as ensuring that UK investors can access a wide enough range of investment vehicles to suit their needs. In the years since, the Government have made a number of successful reforms. In order to build on these successes, the Government announced at spring Budget 2024 that we would be proceeding with the RIF.

The RIF will fill a gap in the UK’s existing fund offering by creating an onshore alternative to existing non-UK fund vehicles that are commonly used to hold UK real estate. Clause 20 provides a definition of the RIF and provides a power for the Treasury to make detailed tax rules through secondary legislation, consistent with the approach taken when introducing tax rules for other investment funds. A later statutory instrument will set out detailed tax rules for the RIF. The regulations will set out supplementary qualifying conditions for a RIF, entry and exit provisions, and rules that deal with breaches of one or more qualifying conditions.

The UK has a world-leading asset management sector. The RIF will play an important role in supporting that leadership by making the UK a more competitive destination for our fund management industry. Indeed, stakeholders from the financial services industry have already shown considerable support for the RIF. I therefore commend the clause to the Committee.

--- Later in debate ---

[Gareth Davies]

I am grateful for the comments from Opposition Members. I think we all agree that we want to tackle these issues in the most serious way possible, with the most force. I am comforted by the comments from the Financial Action Task Force, which previously said that the UK has one of the strongest regimes when it comes to tackling economic crime. The levy specifically seeks to fund the tackling of anti-money laundering rather than fraud or sanctions, which I will come on to in a second.

It is appropriate to stress that the levy is a targeted measure on the anti-money laundering regulated sector, therefore the proceeds go towards tackling anti-money laundering. That is in the context of the economic crime plan 2, which covers up to 2026 and is backed by £200 million from the levy plus £200 million of Government investment. We are taking broader action on fraud in the technology sector specifically, not least through the online fraud charter, the Online Safety Act 2023 and the telecommunications fraud sector charter.

The hon. Member for Inverness, Nairn, Badenoch and Strathspey mentioned sanctions evasion. We are cracking down on kleptocracy and sanctions evasion through the economic crime plan 2. The Office of Financial Sanctions Implementation actively monitors sanctions evasion every single day.

On corruption, the Foreign, Commonwealth and Development Office leads our efforts to support companies to tackle corruption and strengthen governance across the world. The Government are actively working with partners across the world to strengthen international standards, not least through the UN convention against corruption. In the UK, we also have the National Crime Agency’s international corruption unit. There is significant action to tackle fraud and corruption as well as sanctions evasion, but of course we can always do more and we are vigilant about that.

On the reporting and transparency of the levy, there was a reasonable question from the hon. Member for Hampstead and Kilburn and from the sector. There will be a report on the levy this year and it will be reviewed in 2027. We will engage with stakeholders leading up to that review.

Question put and agreed to.

Clause 21 accordingly ordered to stand part of the Bill.

Clause 22

Transfers of assets abroad

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

[Nigel Huddleston]

Clause 22 makes changes to ensure that individuals cannot use a company as a device to bypass anti-avoidance legislation, known as the transfer of assets abroad provisions. Those provisions are designed to prevent individuals from transferring ownership of income-generating assets, such as real estate or stocks, to an overseas individual or entity while still benefiting from the income that the assets generate. The provisions prevent the moving of assets into offshore structures outside the scope of UK taxation being a simple tax avoidance route for UK residents.

The clause has been introduced following a Supreme Court decision. Prior to the decision, HMRC considered that shareholders and directors who controlled a company could transfer an asset and were therefore in scope of the transfer of assets abroad provisions. However, the Supreme Court decision means that a shareholder cannot be determined as a transferor, which therefore opens up a loophole that can be exploited by shareholders transferring assets abroad via a close company to avoid UK tax. A close company is a company with five or fewer participators, usually shareholders or directors, who have ownership or control over the business.

The changes made by the clause will introduce a provision that deems an individual as the transferor where they are participators in a close company that transfers an asset to a person abroad in order to avoid UK tax. The amendment also applies to transfers by non-resident companies that would be treated as a close company if they were UK resident. The changes will have an impact on transactions only where the purpose of the transfer is to avoid tax and will not have an impact on transfers that are genuine commercial transactions. The changes will apply to income that arises after 6 April 2024, regardless of when the transfer took place.

In situations where multiple shareholders are involved in the transfer of an asset, any resulting tax charge will be apportioned between those individuals in proportion to their respective shareholdings. Further details will be provided in HMRC guidance. The measure is expected to affect a small number of individuals a year and will raise about £15 million in tax revenue over the forecast period.

This change was anticipated by external groups and demonstrates that the Government are quick to crack down on tax avoidance loopholes. This clause prevents tax avoidance by ensuring that individuals cannot bypass anti-avoidance legislation by using a company to transfer assets abroad while still benefiting from the income they generate. I therefore commend the clause to the Committee.

[Tulip Siddiq]

We believe that individuals or companies generating wealth in the UK should pay their fair share, so we are in complete support of the aims of this clause. However, we have heard concerns raised by the Chartered Institute of Taxation about the effectiveness of the Government’s proposals and I would be interested to hear the Minister’s views on those concerns.

First, the Chartered Institute of Taxation has argued that the clause adds complexity to the tax system, because it uses income tax legislation to tackle perceived corporate tax avoidance. Clause 22 extends provision within the Income Tax Act 2007 to cover avoidance of any tax through transfer made by a closely held company. Could the Minister explain the thinking behind the Government’s decision to tackle corporate tax avoidance in this way, rather than through the corporate tax regime? Does he agree with the Chartered Institute of Taxation that it could add unnecessary complication to the tax system?

Secondly, the Chartered Institute of Taxation made the case that the Government’s position that any participator in a company is deemed to be involved in a company’s decision to move assets abroad is unfair. For example, a company may have several minority shareholders who have no participation in the running of the company. What is the Minister’s assessment of the case made by the Chartered Institute of Taxation that only major shareholders, directors and shadow directors should be assumed to be involved for the purposes of this legislation?

Thirdly, the Chartered Institute of Taxation has warned that these changes could damage the UK’s international competitiveness, because the test as set out in the legislation leaves too much discretion to HMRC, which compounds uncertainty for businesses. For example, a UK holding company that provides a loan to an offshore subsidiary that in turn generates profits could be caught by the changes, despite that being a routine transaction. The Chartered Institute of Taxation argues that that could lead to an increased number of inquiries and appeals to the tax tribunals and could seriously undermine the UK’s attractiveness for international headquarters.

What does the Minister make of those concerns? What steps will HMRC take to ensure that involvement and objection defences under the clause are not ambiguous or uncertain, and to ensure that those charges do not prove to be increased excessively for taxpayers?

My final point is that the changes introduced by clause 22 appear to be retrospective, as no date is specified whereafter transactions are affected; the clause says only that income arising after April 2024 is caught by the regime. Can the Minister confirm whether that is the case? Will commercial transactions that were carried out many years ago, but from which income arises after April 2024, still be caught?

[Nigel Huddleston]

I thank the hon. Member for Hampstead and Kilburn for her comments. We very much appreciate the input that we have received from stakeholders and interested parties, including the Chartered Institute of Taxation. Some of those points are about broader issues around the TOAA regime, rather than specific to this legislation, but we do hear what they have to say.

I will respond to the hon. Lady’s points about the changes that apply to companies when the TOAA regime is primarily about individuals. The transfer of assets abroad legislation is an anti-avoidance provision aimed at preventing individuals from avoiding a tax charge by transferring an asset to a person overseas while still being able to enjoy the income of that asset in some way. It would be easy for an individual to sidestep the legislation by transferring such an asset to a company that they controlled before the company then made the transfer abroad. The legislative changes are aimed at preventing that situation and ensuring that the TOAA rules are applied as intended.

On the point about the legislation being broad, let us not forget that it is being brought in in response to the Supreme Court judgment; we are trying to make sure that it acts as intended throughout. The intention of the legislation is to put the situation involving transfers by companies back to how HMRC considered it operated before the Supreme Court decision. The transfer of assets abroad legislation aims to stop that tax avoidance.

It is also important to remember that the legislation does not bring a tax charge when the transfer is for genuine commercial reasons or when tax avoidance was not the purpose of the transfer. The new legislation gives individuals the opportunity to exclude themselves from the tax charge if certain conditions are met. We respectfully disagree with the CIOT on some of those conditions. We have outlined some of those, and HMRC will produce further guidance in due course.

On the retroactive criticism, the clause has retroactive effect because if it did not, it would have allowed individuals to abuse the loophole between the date of the Fisher judgment and the enactment of the legislation. Again, we do not believe that there will be a significant increase in complexity. The purpose behind the legislation is primarily to ensure that the regime acts as intended.

I will not go into the weeds on HMRC’s determination process—further guidance will be given—but HMRC will review the facts of a case to judge whether someone is directly or indirectly involved in the decision making of a company. It will accept evidence that shows whether someone is involved or not. However, any arrangements that are put in place purely to be used as evidence that an individual is not involved in the decision making of a company will be disregarded and a charge will be levied if the other conditions are met. As I said, HMRC will issue guidance on how it will approach the matter in due course. Decisions will be made based on the facts of each individual case.

I hope that I have given the hon. Member for Hampstead and Kilburn some assurance. We appreciate the concerns that have raised by key stakeholders, and further information and guidance will be forthcoming.

Question put and agreed to.

Clause 22 accordingly ordered to stand part of the Bill.

Clause 23

Minor VAT amendments

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

[Nigel Huddleston]

Clause 23 makes some minor, technical changes to VAT legislation relating to the DIY house builders’ scheme and VAT credit in the penalty reform regime, and allows for reform of the VAT terminal markets order. I will speak briefly about each measure in turn.

The DIY house builders’ scheme allows individuals building their own home, or converting a non-residential building to their own home, to recover VAT incurred on the cost. That puts individual house builders in the same position as property developers, who are able to sell new build residential property at a zero rate and recover the VAT they incur in the process of constructing new build properties. The scheme was simplified and made digital in December last year, which has significantly reduced the time taken for claims to be paid. Under the new process, only essential details are required on the claim form, eliminating the need for claimants to submit certain evidential documents up front. Based on the information provided on the claim form, HMRC can then request evidential documents to verify the claim.

Clause 23(1) will give HMRC a clear power under the DIY house builders’ scheme to require further evidential documentation, such as invoices, from the person who submitted a claim under the scheme. That will assist HMRC in verifying claims.

Clause 23(3) is a minor update to the existing powers that allow for reform of the VAT terminal markets order. The order reduces VAT administration burdens on commodities traded on specified markets, so the power will allow for simplifications to support businesses trading those commodities. The Government previously announced their intention to reform the order to reflect current market practices and to keep pace with market changes, such as trades in new products, including carbon credits. This clause takes that commitment forward.

Finally, subsections (4) and (5) make changes to ensure that VAT interest rules operate as intended. For most major taxes, the Finance Act 2009 requires HMRC to pay interest on amounts due from HMRC to taxpayers, and to charge interest on late payments to HMRC. Historically, that regime did not apply to VAT, which had its own interest rules. Harmonising the rules on interest was an important step in delivering the Government’s ambition to build a trusted, modern tax administration system. Changes made by the Finance Act 2021 brought VAT interest in line with taxes such as income tax from 1 January last year. In implementing the new interest rules for VAT, HMRC has discovered some minor defects in the legislation, which without correction would force it to act in a way that conflicts with policy intent.

Clause 23 will therefore make two changes to the interest rules. The first will address the situation in which interest ought to be repaid to HMRC because, following an assessment or amendment that reduces the amount of VAT credit, the repayment interest due is also reduced. It was always intended that HMRC could recover all these amounts through a simple automated process that does not add to burdens for taxpayers and HMRC alike. The IT system can already operate, but the legislation, mistakenly, does not always allow that automated recovery. The change will ensure that HMRC can do so in all cases instead of needing a different, onerous process for a minority of cases that the original legislation did not cover.

The second change will make sure that VAT-registered businesses are always protected by a provision that creates a fairer basis for the calculation of interest where they owed money to HMRC over the same time that HMRC owed money to them. The original legislation failed to extend that safeguard to all scenarios in which that could happen with VAT, undermining the fairness of the interest regime. To ensure that all VAT-registered businesses are treated equally, the changes will be given backdated effect to 1 January 2023, when the interest rules were introduced for VAT.

Clause 23 makes some small changes to ensure that policy works as intended and to further Government commitments on reforming the VAT terminal markets order. I commend it to the Committee.

[Tulip Siddiq]

The Opposition support the changes that will assist with compliance checks by making online applications equivalent to paper applications. Has the Minister considered adding the online application as a service to the agent services accounts so that an agent can prepare and submit the claim on behalf of their client?

We also support the provisions for modifying the application of VAT for terminal markets, as that will allow for further reforms such as bringing trades in carbon credits within the scope of the Value Added Tax (Terminal Markets) Order. We feel that is a vital and necessary step in developing this important market.

We support the changes to legislation that governs the interaction between late payment interest and repayment interest for VAT. Has the Minister given any thought to reinstating HMRC’s ability not to charge interest on VAT errors where the supplier did not charge VAT, with no loss to the Exchequer because the customer could claim in full?

[Drew Hendry]

On clause 23’s minor VAT amendments, there is very little to disagree with. VAT should be paid where it is due, and HMRC should pay interest where it should pay interest. That is to be welcomed.

However, on Second Reading I pointed out the paucity of thought and imagination that had gone into providing real help for people across the nations of the UK, and the kinds of thing that the Government could have done but have not. The clause title, “Minor VAT amendments”, just highlights the problem with the entire Bill. The Government could have taken some action to deal with the issues for people in hospitality by cutting VAT and doing something meaningful for tourism, but no: they have chosen to make these minor adjustments. They could have used VAT as a mechanism for helping our high streets to create economic zones that could boost life back into vital high streets and centres. Instead, they have taken to tinkering with the VAT rules.

My question to the Minister is why there is such a lack of ambition in his Government. Is it that this is a fag-end Government in a fag-end Parliament that has run out of ideas, or is it just that they do not care?

[Nigel Huddleston]

The hon. Member for Inverness, Nairn, Badenoch and Strathspey has been charming until this point, and now he goes back to this. I know him very well; I am sure he does not mean it. First, he knows as well as anybody in this House that everybody who comes into Parliament cares: they care about their constituents and they care about the country. We are motivated to come here because we want to make the country a better place for our children and grandchildren.

I know that the hon. Gentleman occasionally gets rather vocal on some of these points, but I politely request that he be a little bit careful with some of his comments. I would never criticise the motivation, incentives or purposes of any colleague in this place. I may fundamentally disagree with some of their policies, but I will not disagree with their motivations. In saying things like “People don’t care” or “The Government don’t care,” I am afraid he is straightforwardly wrong.

[Drew Hendry]

I am very fond of the Minister, as he knows. We often have these back and forths, and I often have to rise to my feet to correct what he has said. I did not make any assertion about any individual; I was talking about his Government. I was very explicit about that. I just want to make that clear.

[Nigel Huddleston]

Yet again, I appreciate the hon. Gentleman’s trying to clarify, but I am a member of the Government and therefore I am afraid that I do take offence, direct or indirect. But that is a side point to the matters under discussion.

The hon. Gentleman is making fair and valid points about the support that has been given, but I repeat that this Government, like every Government around the world, have had incredibly difficult circumstances to deal with. I do not think that there is any doubt whatever that the support measures that we have put in place to support lives and livelihoods have been incredible and stack up pretty well when compared internationally. That includes cost of living support, as I have mentioned.

I know that the hon. Gentleman is a huge supporter of the tourism, hospitality and leisure industry. We have spoken about that many times, and I know that it is particularly important to Scotland, where it is a disproportionately larger share of the economy than in England, for example, although it is important and large across every single constituency in the UK—and I do mean every single constituency. But the hon. Gentleman is being a little bit rich, because he knows as well as I do that there are other measures beyond VAT to support the hospitality and leisure industry. Of course, in England we have extended the 75% business rates reduction to the retail, hospitality and leisure sector, but that has not been done in Scotland, nor has it been done to its full extent in Wales.

[Drew Hendry]

I am grateful to the Minister for allowing a bit of back and forth on this. It is generous of him to do so. He fails to mention that in Scotland, 100,000 businesses are lifted out of business rates altogether through the small business bonus scheme. The record in Scotland shows that we are supporting businesses, and those businesses are very prevalent in the tourism sector.

[Nigel Huddleston]

I acknowledge the efforts made by the Scottish Government to support various sectors, but as I say, on that particular item, the hon. Gentleman will know as well as I do that it is a key ask of the industry in Scotland for the Scottish Government to follow suit with England and elsewhere.

The hon. Member for Hampstead and Kilburn raised several points. Some were slightly out of the scope of the specific measures under discussion, including IT systems and other considerations, but I take on board what she says, as does HMRC, because there is a constant need to review and assess the scope of IT systems and so on. We do so on a regular basis; I spend a lot of time talking to HMRC about this, so I can assure the hon. Lady that the points that she raised are constantly under consideration. I will probably leave it at that.

Question put and agreed to.

Clause 23 accordingly ordered to stand part of the Bill.

Clause 24

Collective money purchase arrangements

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

[Nigel Huddleston]

Clause 24 makes further provision for collective money purchase arrangements. CMP arrangements are a new type of pension that have the benefit of pooling individuals’ pension pots to provide better incomes in retirement while limiting the liability of employers.

These changes will enable the Government to authorise the transfer of benefits to a member’s beneficiaries, such as their dependants, in the unlikely event that a member dies while a CMP arrangement is being wound up. That will ensure that such transfers do not incur an unauthorised payment charge of 55%, and it will deliver the Government’s commitment to provide the correct tax outcome for CMP arrangements.

The Pension Schemes Act 2021 introduced legislation to allow collective money purchase schemes to operate in the United Kingdom. This measure authorises the transfer of survivor benefits in collective money purchase pension schemes. This will ensure that Royal Mail Group, the first provider of a collective money purchase pension scheme, can launch its scheme as planned.

It is a complicated title, but with a simple purpose. As a result of these changes, an employee of Royal Mail will be able to sign on to a CMP, with all the benefits, without the risk of transferring survivor benefits being put through as unauthorised transactions. I therefore commend the clause to the Committee.

[Tulip Siddiq]

This clause is so uncontroversial that we give it our full support. For the first time, I agree with everything the Minister has said, and the Committee will be happy to know that I have no further questions for him.

Question put and agreed to.

Clause 24 accordingly ordered to stand part of the Bill.

Clause 25

Interpretation

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

[Nigel Huddleston]

I will be very brief, because the clause is fairly straightforward. It provides for the use of abbreviations for a variety of Acts. For example, it provides for the use of “CTA 2009” as an abbreviation for the Corporation Tax Act 2009. I commend the clause to the Committee.

Question put and agreed to.

Clause 25 accordingly ordered to stand part of the Bill.

Clause 26

Short title

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

[Nigel Huddleston]

The clause provides for the Bill to be known as the Finance (No. 2) Act 2024 upon Royal Assent. I commend it to the Committee.

Question put and agreed to.

Clause 26 accordingly ordered to stand part of the Bill.

Question proposed, That the Chair do report the Bill to the House.

[Nigel Huddleston]

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

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

[James Murray]

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

Finance (No. 2) Bill (Except clauses 1 to 4, 12 and 13, and 19)

Nigel Huddleston Excerpts

Tuesday 21st May 2024 Public Bill Committees

[The Chair]

Copies of written evidence that the Committee receives will be made available in the Committee Room and will be circulated to Members by email.

Clause 5

Increase in thresholds to £60,000 and £80,000

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[Nigel Huddleston]

I thank my opposite numbers for their comments. I respectfully disagree with several of their points, and I will remind my opposite number, the hon. Member for Ealing North—as I do on almost every occasion—of the significant changes to the income tax threshold that the Conservative Government have brought in. It was £6,475 under Labour; it is now £12,570. That is a significant increase and it has taken many people out of paying income tax altogether, which is something we are very proud of.

The hon. Gentleman will be well aware that, as we have discussed on multiple occasions, the reason why taxes are higher than any of us would desire is the level of intervention required to support households and livelihoods during the pandemic and, more recently, the cost of living challenges since the invasion of Ukraine and the energy price shocks in particular. I would make a similar point to the hon. Member for Inverness, Nairn, Badenoch and Strathspey, who also made those points. I remind him that we have made interventions in cost of living support to the tune of about £100 billion. With respect, half a million people will benefit from the changes that we are introducing. HICBC is not a small amount. It is a meaningful amount of money for a large number of people, and it comes on top of the many other support measures that we have introduced.

I thank the hon. Member for Ealing North for pointing out the easements and the fact that there will be automatic backdating. Hopefully, that will be a relief and good news, and be positive for many families. Child benefit is normally backdated by three months, but because of the timing of the implementation, some could overlap two tax years. We are trying to make that simple and bring it into one tax year.

The hon. Gentleman mentioned the increase from £60,000 to £80,000 and the impact on marginal rates. The changes that were announced will reduce the total marginal effective tax rates, which includes income tax, employee national insurance contributions and HICBC, from about 64% to 53% for someone with, for example, two children. That is a good thing.

We recognise that high marginal rates introduce complexity to the tax system, but that needs to be weighed against other considerations when designing tax policy. The Government must ensure sure that they are committed to a fair tax system that supports strong public finances. Individuals will, as the hon. Gentleman pointed out, still be required to submit a self-assessment tax return to declare and pay their HICBC liability. However, the Government announced in July last year that we are taking steps to allow newly liable taxpayers to pay the HICBC through their tax code without the need to register for self-assessment. Further details on this improvement will be shared in due course.

The hon. Gentleman also mentioned the consultation on moving to a household basis. We will announce further details of the consultation in due course and, as with all tax policy, any changes would be considered as part of future fiscal events. The Chancellor announced that the Government will be consulting on moving the HICBC to a system based on household incomes, and that change will be delivered by April 2026. If the hon. Gentleman is patient, we will announce further details on that consultation in due course.

A point was made about communication. There have already been significant communications on the changes to HICBC. There has been a lot of online and offline activity from His Majesty’s Revenue and Customs, various Government Departments and others. The campaign to raise awareness also includes working with, for example, parenting platforms such as Bounty and Emma’s Diary, and issuing emails through third party partners, including childcare providers. The hon. Gentleman raised an important point about not just making the changes, but ensuring that everybody is aware of them, so that everybody who is intended to benefit is able to.

Question put and agreed to.

Clause 5 accordingly ordered to stand part of the Bill.

Clause 6

Reduction in higher CGT rate for residential property gains to 24%

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

[The Chair]

With this it will be convenient to debate clauses 7 to 11 stand part.

[Nigel Huddleston]

Clauses 6 to 11 are related to the property tax measures in the Bill. I hope that Members will forgive me, but this is a slightly longer speech, as I will talk through each clause. Indeed, it is the longest speech that I plan on giving today, although it is not too long—please do not have a heart attack; I will not be reading every one of these pieces of paper.

Clause 6 cuts the higher rate of capital gains tax, or CGT, charged on residential property gains from 28% to 24% from 6 April 2024. CGT is of course charged on the disposals of buy-to-lets and second homes. Main homes are exempt through private residence relief, which means for that the majority of residential property sales no CGT is paid at all. Where a disposal is liable to CGT, gains are taxed at a lower rate of 18% for any gains that fall within an individual’s basic rate band and at a higher rate for any gains above that.

The 28% higher rate was deterring some sales of residential properties, so the Government announced a 4 percentage point cut to the higher rate at spring Budget 2024. That will encourage more landlords and second home owners to sell their residential properties, making more homes available to the market for a variety of purchasers, including first-time buyers. The OBR forecasts that there will be around 60,000 more residential property transactions over the next five years owing to the cut. As more homes are bought and sold, the Exchequer is expected to raise an additional £690 million in revenue over that period. There will be no change to the lower rate of 18% for private residence relief.

Clause 7 concerns multiple dwellings relief, or MDR, which is a bulk purchase relief in the stamp duty land tax regime. The clause abolishes multiple dwellings relief from 1 June 2024. Multiple dwellings relief allows anyone purchasing two or more dwellings in a single transaction or in linked transactions to calculate their stamp duty based on the average value of the properties purchased, as opposed to their aggregate value. Multiple dwellings relief was introduced in 2011 with the intention of promoting investment in the private rented sector, but a recent external evaluation found no strong evidence that it has done so, meaning that the relief is not cost-effective and is therefore not acting as intended.

His Majesty’s Revenue and Customs has seen a high number of incorrect and abusive claims for the relief. Those have been driven by tax repayment agents, who often convince private individuals to make relief claims for the purchase of two dwellings when individuals have in fact only purchased one. One such example is somebody buying a large house with a separate indoor entertainment area, including a swimming pool and toilet, and that being counted as two properties when it is transparently one.

The changes made by clause 7 will abolish multiple dwellings relief for property transactions that complete on or after 1 June 2024. However, for contracts that were exchanged on or before 6 March 2024, relief will continue to apply regardless of when the contracts complete. The change will not impact those purchasing a single property. It will only increase the stamp duty payable by individuals or businesses purchasing two or more properties in a single transaction or as part of the same deal. Individuals or businesses purchasing six or more dwellings will continue to qualify for the non-residential rates of SDLT.

Clause 8 makes changes to ensure that first-time buyers’ relief from stamp duty land tax can be accessed by those purchasing new residential leases through a nominee or bare trustee, including victims of domestic abuse. A nominee is a person who holds the legal title of a property, while the beneficial ownership—the person who ultimately owns or controls the assets—is held by another person. A bare trust is a trust under which property is held by a person as trustee for another person who is fully entitled to all of the capital and income of the trust.

The measure also changes the definition of first-time buyers to ensure that individuals who use such arrangements cannot claim relief more than once. First-time buyers’ relief from SDLT is available where an individual who has not previously owned a dwelling purchases a home they intend to use as their only or main residence, but that is not currently available to individuals purchasing a new residential lease through a nominee or bare trustee.

The changes made by clause 8 will benefit certain first-time buyers of residential leasehold properties purchasing through a nominee or bare trustee, reducing the up-front cost of buying a home by allowing them to claim the relief they are entitled to. The changes bring those purchasers in line with purchases of residential freeholds and pre-existing leases using similar arrangements.

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[The Chair]

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

[Nigel Huddleston]

If I may respond briefly, I will answer the perfectly reasonable questions raised by the hon. Member for Ealing North in relation to several points in multiple areas. Regarding the overall impact, and if I may reference the change of the capital gains tax rate from 28% to 24%, the OBR estimates that this costing will have a positive impact beyond the current forecasting period and generate a small long-term yield, too. Of course, beyond the forecasting period, it is difficult to estimate the exact amount.

On the points that the hon. Gentleman raised about MDR and other measures, it is interesting that although there are examples of abuse, it is also the case that only 32% of businesses buying property to let said that this relief had an important influence on their purchase decision at all and only 45% were aware of multiple dwellings relief before making a purchase decision. That feeds into the overall picture of MDR not fulfilling the original intent and purpose, which of course was to support investment in the private rented sector. Again, it is building the picture that the relief is no longer cost-effective. The Government are continuing to engage with stakeholders in the build-to-rent sector and other sectors to ensure that we understand their concerns and we will continue to listen to representations made to highlight any exception or unforeseen impacts that the abolition of MDR could have in the future.

I welcome the hon. Gentleman’s welcoming of many of the other measures. He asked whether they would be applied before the April deadline. They will not be applied retrospectively—for example, the updates on the registered social landlord exemption will not be applied retrospectively.

The hon. Gentleman mentioned the number of public bodies that have paid stamp duty at the 15% higher rate. The number of transactions—of those impacted previously —has been very small, and we therefore do not anticipate a huge impact.

Clauses 7 to 11 ordered to stand part of the Bill.

Clause 14

Additional relief for low-budget films with specified UK connection

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

[The Chair]

With this it will be convenient to discuss clause 15 stand part.

[Nigel Huddleston]

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

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

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

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

[James Murray]

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

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

[Nigel Huddleston]

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

Question put and agreed to.

Clause 14 accordingly ordered to stand part of the Bill.

Clause 15 ordered to stand part of the Bill.

Clause 16

Increase in theatre tax credit

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

[The Chair]

With this it will be convenient to discuss clauses 17 and 18 stand part.

[Nigel Huddleston]

We are powering through this— I have on my notes “tea break” by now, but it is not going to happen. That is no bad thing, and I appreciate the comments and input from hon. Members. I will repeat my thanks as well—a lot of work has gone into the measures that we are discussing today and many stakeholders have already contributed significant amounts, including through consultations.

One such area is what we are debating now: clauses 16 to 18 make changes to ensure that our world-leading theatres, orchestras and museums and galleries may continue to put on outstanding home-grown productions and attract inward investment. The orchestra, theatre, and museums and galleries exhibition tax reliefs have had rates of 45% for non-touring productions and 50% for touring productions and orchestral productions since October 2021, reflecting the unique challenges faced by those sectors during the covid-19 pandemic and the recovery period, which of course we are still in.

The rates were due to be reduced to 30% and 35% on 1 April 2025 and then return to their original levels of 20% and 25% on 1 April 2026. Clauses 16 and 17 change that so the tax reliefs will reduce to only 40% for non-touring productions and 45% for touring productions and orchestral productions on 1 April 2025, and will then remain at that level permanently. That was a key ask of the sector. Clause 18 removes the expiry date of the museums and galleries exhibition tax relief so that the relief similarly becomes permanent rather than ending on 1 April 2026.

The changes will benefit approximately 1,300 theatre companies, orchestra companies and museums and galleries that claim those tax reliefs on an annual basis. Our creative sector is vitally important to our national life and one of the fastest growing sectors in the UK economy. These clauses will bolster our theatres, orchestras and museums and galleries, ensuring that they remain among the best in the world. I commend the clauses to the Committee.

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[Drew Hendry]

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

[Nigel Huddleston]

I do not have much more to add, other than to point out the strength of our creative industries in all four nations of the United Kingdom, which I am glad has been recognised across the Committee today. It is an incredible strength, and I am therefore pleased to hear today the very obvious cross-party agreement on continuing support for this vital sector.

Question put and agreed to.

Clause 16 accordingly ordered to stand part of the Bill.

Clauses 17 and 18 ordered to stand part of the Bill.

Clause 20

Collective investment schemes: co-ownership schemes

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

[The Exchequer Secretary to the Treasury (Gareth Davies)]

It is a great pleasure, as always, to see you in the Chair, Mrs Latham. Clause 20 begins the process of introducing legislation for a new type of investment fund—the reserved investor fund, which I will refer to from now on as the RIF. At Budget 2020, the Government announced a review of the UK’s funds regime, covering tax and relevant areas of regulation. The review had an overarching objective to make the UK a more attractive location to set up, manage and administer funds, as well as ensuring that UK investors can access a wide enough range of investment vehicles to suit their needs. In the years since, the Government have made a number of successful reforms. In order to build on these successes, the Government announced at spring Budget 2024 that we would be proceeding with the RIF.

The RIF will fill a gap in the UK’s existing fund offering by creating an onshore alternative to existing non-UK fund vehicles that are commonly used to hold UK real estate. Clause 20 provides a definition of the RIF and provides a power for the Treasury to make detailed tax rules through secondary legislation, consistent with the approach taken when introducing tax rules for other investment funds. A later statutory instrument will set out detailed tax rules for the RIF. The regulations will set out supplementary qualifying conditions for a RIF, entry and exit provisions, and rules that deal with breaches of one or more qualifying conditions.

The UK has a world-leading asset management sector. The RIF will play an important role in supporting that leadership by making the UK a more competitive destination for our fund management industry. Indeed, stakeholders from the financial services industry have already shown considerable support for the RIF. I therefore commend the clause to the Committee.

--- Later in debate ---

[Gareth Davies]

I am grateful for the comments from Opposition Members. I think we all agree that we want to tackle these issues in the most serious way possible, with the most force. I am comforted by the comments from the Financial Action Task Force, which previously said that the UK has one of the strongest regimes when it comes to tackling economic crime. The levy specifically seeks to fund the tackling of anti-money laundering rather than fraud or sanctions, which I will come on to in a second.

It is appropriate to stress that the levy is a targeted measure on the anti-money laundering regulated sector, therefore the proceeds go towards tackling anti-money laundering. That is in the context of the economic crime plan 2, which covers up to 2026 and is backed by £200 million from the levy plus £200 million of Government investment. We are taking broader action on fraud in the technology sector specifically, not least through the online fraud charter, the Online Safety Act 2023 and the telecommunications fraud sector charter.

The hon. Member for Inverness, Nairn, Badenoch and Strathspey mentioned sanctions evasion. We are cracking down on kleptocracy and sanctions evasion through the economic crime plan 2. The Office of Financial Sanctions Implementation actively monitors sanctions evasion every single day.

On corruption, the Foreign, Commonwealth and Development Office leads our efforts to support companies to tackle corruption and strengthen governance across the world. The Government are actively working with partners across the world to strengthen international standards, not least through the UN convention against corruption. In the UK, we also have the National Crime Agency’s international corruption unit. There is significant action to tackle fraud and corruption as well as sanctions evasion, but of course we can always do more and we are vigilant about that.

On the reporting and transparency of the levy, there was a reasonable question from the hon. Member for Hampstead and Kilburn and from the sector. There will be a report on the levy this year and it will be reviewed in 2027. We will engage with stakeholders leading up to that review.

Question put and agreed to.

Clause 21 accordingly ordered to stand part of the Bill.

Clause 22

Transfers of assets abroad

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

[Nigel Huddleston]

Clause 22 makes changes to ensure that individuals cannot use a company as a device to bypass anti-avoidance legislation, known as the transfer of assets abroad provisions. Those provisions are designed to prevent individuals from transferring ownership of income-generating assets, such as real estate or stocks, to an overseas individual or entity while still benefiting from the income that the assets generate. The provisions prevent the moving of assets into offshore structures outside the scope of UK taxation being a simple tax avoidance route for UK residents.

The clause has been introduced following a Supreme Court decision. Prior to the decision, HMRC considered that shareholders and directors who controlled a company could transfer an asset and were therefore in scope of the transfer of assets abroad provisions. However, the Supreme Court decision means that a shareholder cannot be determined as a transferor, which therefore opens up a loophole that can be exploited by shareholders transferring assets abroad via a close company to avoid UK tax. A close company is a company with five or fewer participators, usually shareholders or directors, who have ownership or control over the business.

The changes made by the clause will introduce a provision that deems an individual as the transferor where they are participators in a close company that transfers an asset to a person abroad in order to avoid UK tax. The amendment also applies to transfers by non-resident companies that would be treated as a close company if they were UK resident. The changes will have an impact on transactions only where the purpose of the transfer is to avoid tax and will not have an impact on transfers that are genuine commercial transactions. The changes will apply to income that arises after 6 April 2024, regardless of when the transfer took place.

In situations where multiple shareholders are involved in the transfer of an asset, any resulting tax charge will be apportioned between those individuals in proportion to their respective shareholdings. Further details will be provided in HMRC guidance. The measure is expected to affect a small number of individuals a year and will raise about £15 million in tax revenue over the forecast period.

This change was anticipated by external groups and demonstrates that the Government are quick to crack down on tax avoidance loopholes. This clause prevents tax avoidance by ensuring that individuals cannot bypass anti-avoidance legislation by using a company to transfer assets abroad while still benefiting from the income they generate. I therefore commend the clause to the Committee.

[Tulip Siddiq]

We believe that individuals or companies generating wealth in the UK should pay their fair share, so we are in complete support of the aims of this clause. However, we have heard concerns raised by the Chartered Institute of Taxation about the effectiveness of the Government’s proposals and I would be interested to hear the Minister’s views on those concerns.

First, the Chartered Institute of Taxation has argued that the clause adds complexity to the tax system, because it uses income tax legislation to tackle perceived corporate tax avoidance. Clause 22 extends provision within the Income Tax Act 2007 to cover avoidance of any tax through transfer made by a closely held company. Could the Minister explain the thinking behind the Government’s decision to tackle corporate tax avoidance in this way, rather than through the corporate tax regime? Does he agree with the Chartered Institute of Taxation that it could add unnecessary complication to the tax system?

Secondly, the Chartered Institute of Taxation made the case that the Government’s position that any participator in a company is deemed to be involved in a company’s decision to move assets abroad is unfair. For example, a company may have several minority shareholders who have no participation in the running of the company. What is the Minister’s assessment of the case made by the Chartered Institute of Taxation that only major shareholders, directors and shadow directors should be assumed to be involved for the purposes of this legislation?

Thirdly, the Chartered Institute of Taxation has warned that these changes could damage the UK’s international competitiveness, because the test as set out in the legislation leaves too much discretion to HMRC, which compounds uncertainty for businesses. For example, a UK holding company that provides a loan to an offshore subsidiary that in turn generates profits could be caught by the changes, despite that being a routine transaction. The Chartered Institute of Taxation argues that that could lead to an increased number of inquiries and appeals to the tax tribunals and could seriously undermine the UK’s attractiveness for international headquarters.

What does the Minister make of those concerns? What steps will HMRC take to ensure that involvement and objection defences under the clause are not ambiguous or uncertain, and to ensure that those charges do not prove to be increased excessively for taxpayers?

My final point is that the changes introduced by clause 22 appear to be retrospective, as no date is specified whereafter transactions are affected; the clause says only that income arising after April 2024 is caught by the regime. Can the Minister confirm whether that is the case? Will commercial transactions that were carried out many years ago, but from which income arises after April 2024, still be caught?

[Nigel Huddleston]

I thank the hon. Member for Hampstead and Kilburn for her comments. We very much appreciate the input that we have received from stakeholders and interested parties, including the Chartered Institute of Taxation. Some of those points are about broader issues around the TOAA regime, rather than specific to this legislation, but we do hear what they have to say.

I will respond to the hon. Lady’s points about the changes that apply to companies when the TOAA regime is primarily about individuals. The transfer of assets abroad legislation is an anti-avoidance provision aimed at preventing individuals from avoiding a tax charge by transferring an asset to a person overseas while still being able to enjoy the income of that asset in some way. It would be easy for an individual to sidestep the legislation by transferring such an asset to a company that they controlled before the company then made the transfer abroad. The legislative changes are aimed at preventing that situation and ensuring that the TOAA rules are applied as intended.

On the point about the legislation being broad, let us not forget that it is being brought in in response to the Supreme Court judgment; we are trying to make sure that it acts as intended throughout. The intention of the legislation is to put the situation involving transfers by companies back to how HMRC considered it operated before the Supreme Court decision. The transfer of assets abroad legislation aims to stop that tax avoidance.

It is also important to remember that the legislation does not bring a tax charge when the transfer is for genuine commercial reasons or when tax avoidance was not the purpose of the transfer. The new legislation gives individuals the opportunity to exclude themselves from the tax charge if certain conditions are met. We respectfully disagree with the CIOT on some of those conditions. We have outlined some of those, and HMRC will produce further guidance in due course.

On the retroactive criticism, the clause has retroactive effect because if it did not, it would have allowed individuals to abuse the loophole between the date of the Fisher judgment and the enactment of the legislation. Again, we do not believe that there will be a significant increase in complexity. The purpose behind the legislation is primarily to ensure that the regime acts as intended.

I will not go into the weeds on HMRC’s determination process—further guidance will be given—but HMRC will review the facts of a case to judge whether someone is directly or indirectly involved in the decision making of a company. It will accept evidence that shows whether someone is involved or not. However, any arrangements that are put in place purely to be used as evidence that an individual is not involved in the decision making of a company will be disregarded and a charge will be levied if the other conditions are met. As I said, HMRC will issue guidance on how it will approach the matter in due course. Decisions will be made based on the facts of each individual case.

I hope that I have given the hon. Member for Hampstead and Kilburn some assurance. We appreciate the concerns that have raised by key stakeholders, and further information and guidance will be forthcoming.

Question put and agreed to.

Clause 22 accordingly ordered to stand part of the Bill.

Clause 23

Minor VAT amendments

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

[Nigel Huddleston]

Clause 23 makes some minor, technical changes to VAT legislation relating to the DIY house builders’ scheme and VAT credit in the penalty reform regime, and allows for reform of the VAT terminal markets order. I will speak briefly about each measure in turn.

The DIY house builders’ scheme allows individuals building their own home, or converting a non-residential building to their own home, to recover VAT incurred on the cost. That puts individual house builders in the same position as property developers, who are able to sell new build residential property at a zero rate and recover the VAT they incur in the process of constructing new build properties. The scheme was simplified and made digital in December last year, which has significantly reduced the time taken for claims to be paid. Under the new process, only essential details are required on the claim form, eliminating the need for claimants to submit certain evidential documents up front. Based on the information provided on the claim form, HMRC can then request evidential documents to verify the claim.

Clause 23(1) will give HMRC a clear power under the DIY house builders’ scheme to require further evidential documentation, such as invoices, from the person who submitted a claim under the scheme. That will assist HMRC in verifying claims.

Clause 23(3) is a minor update to the existing powers that allow for reform of the VAT terminal markets order. The order reduces VAT administration burdens on commodities traded on specified markets, so the power will allow for simplifications to support businesses trading those commodities. The Government previously announced their intention to reform the order to reflect current market practices and to keep pace with market changes, such as trades in new products, including carbon credits. This clause takes that commitment forward.

Finally, subsections (4) and (5) make changes to ensure that VAT interest rules operate as intended. For most major taxes, the Finance Act 2009 requires HMRC to pay interest on amounts due from HMRC to taxpayers, and to charge interest on late payments to HMRC. Historically, that regime did not apply to VAT, which had its own interest rules. Harmonising the rules on interest was an important step in delivering the Government’s ambition to build a trusted, modern tax administration system. Changes made by the Finance Act 2021 brought VAT interest in line with taxes such as income tax from 1 January last year. In implementing the new interest rules for VAT, HMRC has discovered some minor defects in the legislation, which without correction would force it to act in a way that conflicts with policy intent.

Clause 23 will therefore make two changes to the interest rules. The first will address the situation in which interest ought to be repaid to HMRC because, following an assessment or amendment that reduces the amount of VAT credit, the repayment interest due is also reduced. It was always intended that HMRC could recover all these amounts through a simple automated process that does not add to burdens for taxpayers and HMRC alike. The IT system can already operate, but the legislation, mistakenly, does not always allow that automated recovery. The change will ensure that HMRC can do so in all cases instead of needing a different, onerous process for a minority of cases that the original legislation did not cover.

The second change will make sure that VAT-registered businesses are always protected by a provision that creates a fairer basis for the calculation of interest where they owed money to HMRC over the same time that HMRC owed money to them. The original legislation failed to extend that safeguard to all scenarios in which that could happen with VAT, undermining the fairness of the interest regime. To ensure that all VAT-registered businesses are treated equally, the changes will be given backdated effect to 1 January 2023, when the interest rules were introduced for VAT.

Clause 23 makes some small changes to ensure that policy works as intended and to further Government commitments on reforming the VAT terminal markets order. I commend it to the Committee.

[Tulip Siddiq]

The Opposition support the changes that will assist with compliance checks by making online applications equivalent to paper applications. Has the Minister considered adding the online application as a service to the agent services accounts so that an agent can prepare and submit the claim on behalf of their client?

We also support the provisions for modifying the application of VAT for terminal markets, as that will allow for further reforms such as bringing trades in carbon credits within the scope of the Value Added Tax (Terminal Markets) Order. We feel that is a vital and necessary step in developing this important market.

We support the changes to legislation that governs the interaction between late payment interest and repayment interest for VAT. Has the Minister given any thought to reinstating HMRC’s ability not to charge interest on VAT errors where the supplier did not charge VAT, with no loss to the Exchequer because the customer could claim in full?

[Drew Hendry]

On clause 23’s minor VAT amendments, there is very little to disagree with. VAT should be paid where it is due, and HMRC should pay interest where it should pay interest. That is to be welcomed.

However, on Second Reading I pointed out the paucity of thought and imagination that had gone into providing real help for people across the nations of the UK, and the kinds of thing that the Government could have done but have not. The clause title, “Minor VAT amendments”, just highlights the problem with the entire Bill. The Government could have taken some action to deal with the issues for people in hospitality by cutting VAT and doing something meaningful for tourism, but no: they have chosen to make these minor adjustments. They could have used VAT as a mechanism for helping our high streets to create economic zones that could boost life back into vital high streets and centres. Instead, they have taken to tinkering with the VAT rules.

My question to the Minister is why there is such a lack of ambition in his Government. Is it that this is a fag-end Government in a fag-end Parliament that has run out of ideas, or is it just that they do not care?

[Nigel Huddleston]

The hon. Member for Inverness, Nairn, Badenoch and Strathspey has been charming until this point, and now he goes back to this. I know him very well; I am sure he does not mean it. First, he knows as well as anybody in this House that everybody who comes into Parliament cares: they care about their constituents and they care about the country. We are motivated to come here because we want to make the country a better place for our children and grandchildren.

I know that the hon. Gentleman occasionally gets rather vocal on some of these points, but I politely request that he be a little bit careful with some of his comments. I would never criticise the motivation, incentives or purposes of any colleague in this place. I may fundamentally disagree with some of their policies, but I will not disagree with their motivations. In saying things like “People don’t care” or “The Government don’t care,” I am afraid he is straightforwardly wrong.

[Drew Hendry]

I am very fond of the Minister, as he knows. We often have these back and forths, and I often have to rise to my feet to correct what he has said. I did not make any assertion about any individual; I was talking about his Government. I was very explicit about that. I just want to make that clear.

[Nigel Huddleston]

Yet again, I appreciate the hon. Gentleman’s trying to clarify, but I am a member of the Government and therefore I am afraid that I do take offence, direct or indirect. But that is a side point to the matters under discussion.

The hon. Gentleman is making fair and valid points about the support that has been given, but I repeat that this Government, like every Government around the world, have had incredibly difficult circumstances to deal with. I do not think that there is any doubt whatever that the support measures that we have put in place to support lives and livelihoods have been incredible and stack up pretty well when compared internationally. That includes cost of living support, as I have mentioned.

I know that the hon. Gentleman is a huge supporter of the tourism, hospitality and leisure industry. We have spoken about that many times, and I know that it is particularly important to Scotland, where it is a disproportionately larger share of the economy than in England, for example, although it is important and large across every single constituency in the UK—and I do mean every single constituency. But the hon. Gentleman is being a little bit rich, because he knows as well as I do that there are other measures beyond VAT to support the hospitality and leisure industry. Of course, in England we have extended the 75% business rates reduction to the retail, hospitality and leisure sector, but that has not been done in Scotland, nor has it been done to its full extent in Wales.

[Drew Hendry]

I am grateful to the Minister for allowing a bit of back and forth on this. It is generous of him to do so. He fails to mention that in Scotland, 100,000 businesses are lifted out of business rates altogether through the small business bonus scheme. The record in Scotland shows that we are supporting businesses, and those businesses are very prevalent in the tourism sector.

[Nigel Huddleston]

I acknowledge the efforts made by the Scottish Government to support various sectors, but as I say, on that particular item, the hon. Gentleman will know as well as I do that it is a key ask of the industry in Scotland for the Scottish Government to follow suit with England and elsewhere.

The hon. Member for Hampstead and Kilburn raised several points. Some were slightly out of the scope of the specific measures under discussion, including IT systems and other considerations, but I take on board what she says, as does HMRC, because there is a constant need to review and assess the scope of IT systems and so on. We do so on a regular basis; I spend a lot of time talking to HMRC about this, so I can assure the hon. Lady that the points that she raised are constantly under consideration. I will probably leave it at that.

Question put and agreed to.

Clause 23 accordingly ordered to stand part of the Bill.

Clause 24

Collective money purchase arrangements

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

[Nigel Huddleston]

Clause 24 makes further provision for collective money purchase arrangements. CMP arrangements are a new type of pension that have the benefit of pooling individuals’ pension pots to provide better incomes in retirement while limiting the liability of employers.

These changes will enable the Government to authorise the transfer of benefits to a member’s beneficiaries, such as their dependants, in the unlikely event that a member dies while a CMP arrangement is being wound up. That will ensure that such transfers do not incur an unauthorised payment charge of 55%, and it will deliver the Government’s commitment to provide the correct tax outcome for CMP arrangements.

The Pension Schemes Act 2021 introduced legislation to allow collective money purchase schemes to operate in the United Kingdom. This measure authorises the transfer of survivor benefits in collective money purchase pension schemes. This will ensure that Royal Mail Group, the first provider of a collective money purchase pension scheme, can launch its scheme as planned.

It is a complicated title, but with a simple purpose. As a result of these changes, an employee of Royal Mail will be able to sign on to a CMP, with all the benefits, without the risk of transferring survivor benefits being put through as unauthorised transactions. I therefore commend the clause to the Committee.

[Tulip Siddiq]

This clause is so uncontroversial that we give it our full support. For the first time, I agree with everything the Minister has said, and the Committee will be happy to know that I have no further questions for him.

Question put and agreed to.

Clause 24 accordingly ordered to stand part of the Bill.

Clause 25

Interpretation

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

[Nigel Huddleston]

I will be very brief, because the clause is fairly straightforward. It provides for the use of abbreviations for a variety of Acts. For example, it provides for the use of “CTA 2009” as an abbreviation for the Corporation Tax Act 2009. I commend the clause to the Committee.

Question put and agreed to.

Clause 25 accordingly ordered to stand part of the Bill.

Clause 26

Short title

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

[Nigel Huddleston]

The clause provides for the Bill to be known as the Finance (No. 2) Act 2024 upon Royal Assent. I commend it to the Committee.

Question put and agreed to.

Clause 26 accordingly ordered to stand part of the Bill.

Question proposed, That the Chair do report the Bill to the House.

[Nigel Huddleston]

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

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

[James Murray]

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

HMRC

Nigel Huddleston Excerpts

Monday 13th May 2024 Written Statements

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

His Majesty’s Revenue and Customs plays a crucial role in collecting revenue to fund our vital public services. The Department’s strategy is to become a ‘digital first’ tax administration. This involves helping customers move to online services, with the aim of making services easier for customers, and of allowing HMRC to operate more efficiently.



Last year HMRC received over 3 million calls on just three things that can easily be done: resetting an online password, getting a tax code, and getting a national insurance number. Shifting customer contact such as this to online interactions is helping to, and will continue to help, reduce demand on phone lines and allow HMRC to prioritise calls for those who really need to speak to an adviser. This is a fine example of a tangible way to improve public sector productivity.



This digital first strategy is the correct long-term vision for tax administration. In support of this, the Chancellor invested over £136 million in the 2021 spending review to enable HMRC to enhance its digital services. HMRC received a £900 million cash increase over this Parliament, from £4.3 billion in 2019-20 to £5.2 billion in 2024-25.



However, the Government are clear that while HMRC continues to make this digital transition, customers deserve a reliable and responsive service on traditional contact methods, such as the phone lines. Therefore today the Government are providing HMRC with £51 million in new funding to bring HMRC’s phoneline service back up to the published target of 85% of calls to HMRC advisers being answered.



Today’s additional funding enables HMRC to meet the performance standards on its phone lines that its customers expect, while continuing the transition to a digital first model of tax administration. The Government are fully committed to providing HMRC with the resources it needs to meet the needs of all its customers, and will continue to do so.

[HCWS456]