Draft Scottish Rates of Income Tax (Consequential Amendments) Order 2024

Tulip Siddiq Excerpts

Monday 2nd December 2024 General Committees

[The Economic Secretary to the Treasury (Tulip Siddiq)]

I beg to move,

That the Committee has considered the draft Scottish Rates of Income Tax (Consequential Amendments) Order 2024.

It is a pleasure to serve under you as Chair, Sir Roger. The draft order enables the calculation of deficiency relief to take account of the introduction of the Scottish advanced rate of income tax. Deficiency relief reduces the tax that some individuals are required to pay when certain life insurance policies come to an end. It applies in unusual circumstances in which the policyholder would otherwise be taxed on more than the actual economic gain they made on the policy. That might include when a tax charge arose on an earlier withdrawal.

On 22 February this year, the Scottish Parliament introduced the new Scottish advanced rate income tax band. That means that, from 6 April 2024, the former Scottish higher rate income tax band was split into the Scottish higher rate and the Scottish advanced rate income tax bands. The current deficiency relief rules do not take account of the new tax band. This reduces the amount of deficiency relief available to a small number of Scottish taxpayers from 6 April 2024.

The order applies from 6 April 2024, and ensures that the new Scottish advanced rate of income tax can be included in the calculation of deficiency relief. At the same time, the Government are taking the opportunity to simplify the wording of the legislation. The order ensures that the calculation of deficiency relief takes account of the new Scottish advanced rate of income tax.

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[Tulip Siddiq]

I thank the hon. Gentleman for his co-operation and for commenting on the lateness of some of the people behind me—I am sure that the Whip will have taken notice of that, but not me, because that is not my job.

Only Scottish taxpayers who are entitled to deficiency relief and who pay tax at the Scottish advanced rate of income tax will be affected. The measure only affects Scottish taxpayers who claim deficiency relief and whose tax is taxable at the Scottish advanced rate of income tax. I cannot give the hon. Gentleman an absolute number, but the criteria apply to people whose income is taxable at the Scottish advanced rate of income tax, as he referenced.

The hon. Gentleman will be pleased to know that guidance is available. The “Insurance Policyholder Taxation Manual” from His Majesty’s Revenue and Customs contains guidance on deficiency relief. It will be updated to reflect these changes, so people can refer to that, and it is available on gov.uk.

I will answer a question about the order applying retrospectively, because I think the hon. Gentleman alluded to that. The Scottish advanced rate of income tax applies from 6 April 2024, but applying these provisions from the state ensures that no taxpayers are adversely affected. I hope that those answers are satisfactory—[Interruption.] I am being handed another piece of paper, which I will read. Oh, the number affected is fewer than 10, and the Exchequer impact is less than £5 million per annum. I hope that satisfies him.

This order ensures that the calculation of deficiency relief takes account of the new Scottish advanced rate of income tax. I am glad that the Opposition will not oppose it and are in agreement. I commend the changes to the Committee.

Question put and agreed to.