Finance Act 2026

1. Introductory Text

2. Part 1 Income tax, capital gains tax and corporate taxes

   1. Income tax charge, rates and allowances

      1. 1. Income tax charge for tax year 2026-27

      2. 2. Main rates of income tax for tax year 2026-27

      3. 3. Default and savings rates of income tax for tax year 2026-27

      4. 4. Increase in dividend ordinary and upper rates

      5. 5. Savings rates of income tax for tax year 2027-28

      6. 6. New rates of income tax on property income

      7. 7. Property rates of income tax for tax year 2027-28

      8. 8. Scottish and Welsh property rates set by Scottish Parliament and Senedd

      9. 9. Freezing starting rate limit for savings for tax years 2026-27 to 2030-31

      10. 10. Basic rate limit and personal allowance for tax years 2028-29 to 2030-31

   2. Corporation tax charge and rates

      1. 11. Charge and main rate for financial year 2027

      2. 12. Standard small profits rate and fraction for financial year 2027

   3. Employee reliefs

      1. 13. Enterprise management incentives: thresholds and period for exercise

      2. 14. Enterprise investment scheme: increase in amounts and asset requirements

      3. 15. Venture capital trusts: rate of relief and amounts and asset requirements

      4. 16. CSOP schemes and EMI: PISCES shares

   4. Employment income relating to cars etc

      1. 17. Employee car and van ownership schemes

      2. 18. Car or van made available on arm’s length terms

      3. 19. CO₂ emissions figure for certain cars with an electric range figure

   5. Other employment income

      1. 20. Employment income: miscellaneous exemptions

      2. 21. Disallowing deduction from earnings for additional household expenses

      3. 22. Payment for cancelled shifts etc.

      4. 23. Location of duties of employment where duties not performed

      5. 24. Umbrella companies

      6. 25. Loan charge settlement scheme

      7. 26. Loan charge settlement scheme: inheritance tax

      8. 27. Loan charge settlement scheme: supplementary

   6. Capital allowances and other reliefs for businesses

      1. 28. Main rate of writing-down allowances for expenditure on plant or machinery

      2. 29. First-year allowance for main rate expenditure on plant or machinery

      3. 30. Expenditure on zero-emission cars and electric vehicle charging points

      4. 31. Payments for surrender of expenditure credits

      5. 32. Transition from video games tax relief

      6. 33. Special credit for visual effects

      7. 34. R&D undertaken abroad: Chapter 2 relief only

   7. Chargeable gains

      1. 35. Restriction of relief on disposals to employee-ownership trusts

      2. 36. Anti-avoidance: collective investment scheme reconstructions

      3. 37. Anti-avoidance: company reconstructions

      4. 38. Anti-avoidance: reconstructions involving transfer of business

      5. 39. Incorporation relief: requirement to claim

      6. 40. Non-residents: cell companies

      7. 41. Non-residents: double taxation relief relating to collective investment vehicles

   8. Non-UK residents etc

      1. 42. Abolition of notional tax credit on distributions received by non-UK residents

      2. 43. Non-resident, and previously non-domiciled individuals

      3. 44. Trust protections etc: minor amendments and transitional protection

      4. 45. PAYE for treaty non-residents etc.

   9. Other international matters

      1. 46. Unassessed transfer pricing profits

      2. 47. Transfer pricing reform

      3. 48. International controlled transactions

      4. 49. Permanent establishments

      5. 50. Pillar two

      6. 51. Controlled foreign companies: interest on reversal of state aid recovery

      7. 52. Offshore income gains

      8. 53. Offshore income gains: savings

   10. Charities

       1. 54. Legacies to charities to be within scope of tax

       2. 55. Approved charitable investments: purpose test

       3. 56. Tainted charity donations: replacement of purpose test with outcome test

   11. Miscellaneous

       1. 57. Winter fuel payment charge

       2. 58. Carried interest

       3. 59. Pensions: abolition of the lifetime allowance charge

       4. 60. Collective money purchase schemes and Master Trust schemes

       5. 61. Corporate interest restriction: reporting companies

       6. 62. Corporate interest restriction: capital expenditure and tax-EBITDA calculation

       7. 63. Avoidance schemes involving certain non-derecognition liabilities

       8. 64. Energy (oil and gas) profits levy: decommissioning relief agreements

3. Part 2 Inheritance tax

   1. Agricultural property relief and business property relief

      1. 65. Agricultural property relief and business property relief etc

   2. Pension interests

      1. 66. Tax to be charged on certain pension interests

      2. 67. Liability for tax on pension interests

      3. 68. Withholding of benefits and payment of tax by pension scheme administrator

      4. 69. Connected amendments to IHTA 1984

      5. 70. Connected amendments to income tax rules

      6. 71. Commencement of sections 66 to 70

   3. Freeze of nil rate band etc

      1. 72. Rate bands etc for tax year 2030-31

   4. Provision relating to new regime in FA 2025

      1. 73. Relevant property: disapplication of exemptions from exit charges

      2. 74. Relevant property: cap on charges for pre-30 October 2024 excluded property

      3. 75. Foreign diplomats etc: periods of UK residence to be disregarded

      4. 76. Minor corrections

   5. Infected blood compensation payments

      1. 77. Power to make provision about infected blood compensation payments

   6. Gifts to charities and registered clubs

      1. 78. Scope of exemption for gifts to charities and registered clubs

      2. 79. Section 78: transitional protection for existing interests in possession

4. Part 3 Other existing taxes

   1. Value added tax and insurance premium tax

      1. 80. Zero-rating of leases of vehicles to recipients of disability benefits

      2. 81. Insurance premium tax relief limited to adapted vehicles

      3. 82. Private hire vehicles or taxis

      4. 83. Certain charitable donations not to be treated as supplies of goods

      5. 84. Refunds of VAT to combined county authorities

   2. Stamp duty reserve tax

      1. 85. UK listing relief

   3. Gambling duties

      1. 86. Rate of remote gaming duty

      2. 87. General betting duty on remote bets

      3. 88. Abolition of bingo duty

   4. Alcohol duty

      1. 89. Rates of duty

   5. Tobacco products duty

      1. 90. Rates of duty effective from 6pm on 26 November 2025

      2. 91. Rates of duty effective from 1 October 2026

   6. Taxes relating to vehicles

      1. 92. Vehicle excise duty for light passenger or light goods vehicles etc

      2. 93. Vehicle excise duty for rigid goods vehicles without trailers and tractive units

      3. 94. Vehicle excise duty for rigid goods vehicles with trailers

      4. 95. Vehicle excise duty for vehicles with exceptional loads etc

      5. 96. Vehicle excise duty for haulage vehicles other than showman’s vehicles

      6. 97. Vehicle excise duty: expensive car supplement

      7. 98. Rates of HGV road user levy

      8. 99. Rates of air passenger duty

   7. Environmental taxes

      1. 100. Rates of climate change levy

      2. 101. Rates of landfill tax

      3. 102. Rate of aggregates levy

      4. 103. Aggregates levy: amendments relating to disapplication of levy to Scotland

      5. 104. Rate of plastic packaging tax

      6. 105. Chemical recycling: mass balance approach

      7. 106. Pre-consumer plastic

      8. 107. Sections 105 and 106: commencement

   8. Soft drinks industry levy

      1. 108. Rates of levy

   9. Customs duties

      1. 109. Amendment of customs tariff power

      2. 110. Dumping and subsidisation investigations

      3. 111. Safeguarding investigations

      4. 112. Customs facilities at approved wharves and other places

   10. Economic crime (anti-money laundering) levy

       1. 113. Increases to rates of levy

   11. Annual tax on enveloped dwellings

       1. 114. Removal of time limit to claim relief under section 106(3) of FA 2013

5. Part 4 Vaping products duty

   1. Charge

      1. 115. Excise duty: charge

      2. 116. Vaping products

      3. 117. Production of vaping products

      4. 118. Excise duty point and payment

   2. Administration

      1. 119. Administration

   3. Duty stamps

      1. 120. Stamping of vaping products

      2. 121. Issue and management of duty stamps

      3. 122. Approved stamp holders

      4. 123. United Kingdom representatives

   4. Forfeiture

      1. 124. Forfeiture

   5. Civil penalties and enforcement

      1. 125. Dealing in unstamped vaping products

      2. 126. Loss and misuse of duty stamps

      3. 127. Failure to comply with this Part etc

      4. 128. Forfeiture: civil penalties

   6. Offences

      1. 129. Dealing in duty stamps

      2. 130. Dealing in unstamped vaping products

      3. 131. Sales ban following conviction for unlawful use of premises

      4. 132. Offences: penalties

      5. 133. Forfeiture: offences

   7. General provision

      1. 134. Publication of information

      2. 135. Information sharing

      3. 136. Investigation and enforcement

      4. 137. Regulations: further provision

      5. 138. Regulations: procedure

      6. 139. Amendments of other enactments

      7. 140. Interpretation

      8. 141. Commencement and transitional provision

6. Part 5 Carbon border adjustment mechanism

   1. Introduction

      1. 142. Introduction to CBAM

   2. The charge

      1. 143. Charge to CBAM

      2. 144. Importation

      3. 145. Goods processed under a special customs procedure

      4. 146. Person liable: the importer

      5. 147. Exemptions

      6. 148. Embodied emissions

      7. 149. Rate

      8. 150. Carbon price relief

   3. Administration and enforcement

      1. 151. Administration and enforcement

      2. 152. Criminal offences

   4. General

      1. 153. Supplementary amendments

      2. 154. Emissions: meaning etc

      3. 155. Interpretation

      4. 156. Power to make provision for linked emissions trading schemes

      5. 157. Regulations and notices

      6. 158. Commencement and transitory provision

7. Part 6 Avoidance

   1. Chapter 1 Prohibition of promotion of certain tax avoidance arrangements

      1. Prohibition

         1. 159. Prohibition of promotion of certain tax avoidance arrangements

         2. 160. Meaning of promotion

         3. 161. Procedure

      2. Sanctions

         1. 162. Civil penalties

         2. 163. Criminal offence

         3. 164. Criminal liability of responsible persons

      3. General

         1. 165. Interpretation and commencement

   2. Chapter 2 Promoter action notices

      1. Promoter action notices

         1. 166. Certification of promoters

         2. 167. Promoter action notices

         3. 168. Preliminary notices

         4. 169. Disclosure of information by HMRC

         5. 170. Appeal against a decision to issue a promoter action notice

      2. Sanctions

         1. 171. Civil penalties

         2. 172. Publication

         3. 173. Reporting to regulators etc

         4. 174. Extension of time periods

         5. 175. Reasonable excuse

      3. General

         1. 176. Interpretation

   3. Chapter 3 Anti-avoidance information notices

      1. Key definitions

         1. 177. Connected persons

         2. 178. Anti-avoidance enactments

      2. Notices by type

         1. 179. Information notices: connected persons

         2. 180. Information notices: third parties

         3. 181. Information notices: unidentified connected persons

         4. 182. Information notices: identification

         5. 183. Information notices: financial institutions

      3. Content, requirements and withdrawal of notices

         1. 184. Content and requirements of notices

         2. 185. Restriction on disclosure of notices

         3. 186. Excepted information

         4. 187. Tribunal approval of notices

         5. 188. Withdrawal of notices

      4. Criminal sanctions

         1. 189. Offence of failing to comply with a notice

         2. 190. Offence of concealing information

         3. 191. Criminal liability of responsible persons

         4. 192. Criminal liability of responsible persons: no prosecution of recipient

         5. 193. Imprisonment or a fine

      5. Civil sanctions

         1. 194. Penalty for failing to comply with a notice

         2. 195. Penalty for concealing information

         3. 196. Penalty for inaccurate information

         4. 197. Penalty for disclosing a notice

         5. 198. Penalty based on monies received

         6. 199. Increased daily default penalty

      6. Sanctions: general

         1. 200. Extension of time periods

         2. 201. Reasonable excuse

         3. 202. Double jeopardy

         4. 203. Assessment etc of penalties: application of Schedule 36 to FA 2008

      7. Appeals

         1. 204. Appeals against notices

         2. 205. Appeals against penalties

      8. Miscellaneous and interpretation

         1. 206. Interpretation

         2. 207. Application of provisions of TMA 1970

         3. 208. Repeals

   4. Chapter 4 Miscellaneous

      1. Legal professionals

         1. 209. Declaration in relation to privileged material

         2. 210. Penalties for an incorrect declaration

         3. 211. Penalties: procedure, appeals etc

         4. 212. Publication following an incorrect declaration

         5. 213. Time limits for publication

         6. 214. Amendments to existing legislation: removal of privilege exemption

         7. 215. Commencement

      2. Disclosure of tax avoidance schemes: consequences for failure to comply

         1. 216. Penalties for non-disclosure of tax avoidance schemes

         2. 217. Removal of time limits on publication by HMRC

         3. 218. Consequential amendments

         4. 219. Commencement

      3. Construction industry scheme: amendments

         1. 220. Construction industry scheme: amendments

         2. 221. Construction industry scheme regulations: amendments

         3. 222. Commencement

8. Part 7 Tax advisers

   1. Chapter 1 Registration

      1. Prohibition against unregistered tax advisers interacting with HMRC

         1. 223. Prohibition against unregistered tax advisers interacting with HMRC

         2. 224. Meaning of “tax adviser” and “client”

      2. Application process

         1. 225. Application for registration

         2. 226. Meaning of “relevant individual” and “officer”

         3. 227. Registration conditions

         4. 228. Registration conditions: interpretation

         5. 229. Registration conditions: offences

         6. 230. Registration of tax advisers etc

      3. Monitoring of registration conditions and suspension of registration

         1. 231. Monitoring of registration conditions

         2. 232. Suspension of registration

      4. Compliance notice

         1. 233. Compliance notice

      5. Financial penalties

         1. 234. Financial penalties for prohibited interaction with HMRC

         2. 235. Financial penalties for prohibited interaction with HMRC: liability of relevant individuals

      6. Ineligibility orders

         1. 236. Tax advisers: ineligibility orders

         2. 237. Relevant individuals: ineligibility orders

      7. Requirement for tax adviser to notify clients of suspension or ineligibility orders

         1. 238. Requirement for tax adviser to notify clients of suspension or ineligibility orders

      8. Reasonable excuse

         1. 239. Reasonable excuse

      9. Extension of period for making representations

         1. 240. Extension of period for making representations

      10. Assessment of financial penalties etc

          1. 241. Assessment of financial penalties

          2. 242. Time limits and treatment of financial penalties

          3. 243. Double jeopardy

      11. Reviews and appeals

          1. 244. Reviews and appeals

      12. Disclosure of information

          1. 245. Disclosure of information

      13. Power to publish information

          1. 246. Power to publish information

      14. Power to amend Schedule 20 (exceptions)

          1. 247. Power to amend Schedule 20 (exceptions)

      15. Interpretation

          1. 248. Interpretation of Chapter

      16. Commencement

          1. 249. Commencement

   2. Chapter 2 Conduct etc

      1. Conduct of tax advisers

         1. 250. Conduct of tax advisers

      2. Power to publish information about tax advisers etc

         1. 251. Power to publish information

         2. 252. Power to publish information: change of circumstances

         3. 253. Power to publish information: interpretation and commencement

9. Part 8 Miscellaneous and final

   1. Fiscal mandate assessments by the OBR

      1. 254. Fiscal mandate assessments prepared by the Office for Budget Responsibility

   2. Provision of data by third parties

      1. 255. Data-gathering

   3. Making tax digital

      1. 256. Persons on whom digital reporting requirements may be imposed

      2. 257. Exemptions from digital reporting requirements

      3. 258. Returns to be delivered by electronic communications etc.

      4. 259. Penalties: amendments consequential on section 258 etc

      5. 260. Powers relating to electronic communications: directions

      6. 261. Power to require digital contact details

   4. Penalties

      1. 262. Penalty points and late submission penalties (power to cancel etc)

      2. 263. Assessments of late payment penalties etc.

      3. 264. Penalties for failure to pay tax due on further appeal

      4. 265. Failure to deliver company tax returns

   5. Advance tax clearances

      1. 266. Clearances

      2. 267. Binding effect

      3. 268. Extension

      4. 269. Modification

      5. 270. Information

      6. 271. Misrepresentation

      7. 272. Commissioners notice

      8. 273. Powers

      9. 274. Interpretation

   6. Cryptoasset reporting framework

      1. 275. Cryptoasset reporting: users and controlling persons resident in the UK

      2. 276. International cryptoasset reporting framework: connected matters

   7. Miscellaneous

      1. 277. Stamp duty: piloting of digital service etc

      2. 278. Oversight of HMRC tax enforcement functions in Northern Ireland

      3. 279. Repeal of obsolete provision in FA 1925 concerning Dominion Governments

      4. 280. Repeal of other obsolete provisions and correction of wrong cross-references

   8. Final

      1. 281. Interpretation

      2. 282. Short title

10. Schedules

    1. Schedule 1

       Property and savings rates of income tax: consequential amendments

       1. Part 1 Amendments of ITA 2007

          1. 1. ITA 2007 is amended as follows.

          2. 2. In section 6(3) (other rates of income tax)—

          3. 3. In section 6B (the Welsh basic, higher and additional amounts)—...

          4. 4. In section 9 (the trust and dividend trust rate)—

          5. 5. In section 9A (overview of sections 10 to 15), in...

          6. 6. In section 10 (income charged at the basic, higher and...

          7. 7. In section 11 (income charged at the default basic rate:...

          8. 8. In section 11B (income charged at the Welsh basic, higher...

          9. 9. In section 11C (income charged at the default basic, higher...

          10. 10. After section 11CA, as inserted by section 6(3) of this...

          11. 11. In section 11D (income charged at the savings basic, higher...

          12. 12. After that section insert— Income charged at the savings basic...

          13. 13. In section 12B (individual’s entitlement to a savings allowance), in...

          14. 14. In section 14 (income charged at the dividend ordinary rate:...

          15. 15. In section 15 (income charged at the trust rate and...

          16. 16. In section 16 (savings and dividend income to be treated...

          17. 17. In section 18 (meaning of “savings income”), in subsection (4)(b)—...

          18. 18. In section 31 (total income: supplementary), in subsection (2), after...

          19. 19. In section 55B (transferable tax allowance for married couples and...

          20. 20. In section 55C (transferable tax allowance for married couples and...

          21. 21. In section 399B(3) (which provides for relief for finance costs...

          22. 22. In section 462 (overview of Part 9), in subsection (3)...

          23. 23. In section 463 (general provision about settlements etc)—

          24. 24. In section 479 (trustees’ accumulated or discretionary income to be...

          25. 25. In section 481 (other amounts to be charged at special...

          26. 26. In section 483 (sums paid by personal representatives to trustees),...

          27. 27. In section 486 (how allowable expenses are to be set...

          28. 28. In section 503 (how beneficiary’s income is reduced), in subsection...

          29. 29. In section 874 (duty to deduct from certain payments of...

          30. 30. In section 889 (payments in respect of building society securities),...

          31. 31. In section 919 (manufactured interest on UK securities: payments by...

          32. 32. In section 939 (duty to retain bonds where issue treated...

          33. 33. In section 974 (Real Estate Investment Trusts: regulations under section...

          34. 34. In section 975A (statements about certain payments of interest), in...

          35. 35. In section 989 (definitions), at the appropriate places insert— “property...

          36. 36. In Schedule 4 (index of defined expressions), at the appropriate...

       2. Part 2 Amendments of other tax legislation

          1. 37. TMA 1970

          2. 38. TCGA 1992

          3. 39. ITTOIA 2005

          4. 40. In sections 274AA(5) and 274C(2) (which provide for relief for...

          5. 41. In section 465A (gains from life insurance contracts: amounts for...

          6. 42. In section 466 (gains from life insurance contracts: personal representatives...

          7. 43. In section 467 (gains from life insurance contracts: trustees as...

          8. 44. In section 530 (gains from life insurance contracts: income tax...

          9. 45. In section 533 (meaning of “comparable EEA tax charge”), in...

          10. 46. In section 535 (gains from life insurance contracts: top slicing...

          11. 47. In section 536 (gains from life insurance contracts: top slicing...

          12. 48. In section 537 (gains from life insurance contracts: top slicing...

          13. 49. In section 539 (gains from life insurance contracts: relief for...

          14. 50. In section 669 (reduction in residuary income: inheritance tax on...

          15. 51. In section 680 (beneficiaries’ income etc: income treated as bearing...

          16. 52. After section 680B insert— Income treated as property income (1) This section applies to estate income relating to a...

          17. 53. CTA 2010

          18. 54. FA 2012

       3. Part 3 Amendment of Scotland Act 1998

          1. 55. Scotland Act 1998

    2. Schedule 2

       Scottish and Welsh property income rates

       1. Part 1 Scotland

          1. 1. In section 80C of the Scotland Act 1998 (power to...

       2. Part 2 Wales

          1. 2. Amendments of ITA 2007

          2. 3. Amendments of Government of Wales Act 2006

          3. 4. (1) Section 116D (power to set Welsh rates for Welsh...

          4. 5. (1) Section 116I (supplemental powers to modify enactments) is amended...

          5. 6. In section 116K (report by the Comptroller and Auditor General),...

    3. Schedule 3

       Non-resident, and previously non-domiciled individuals

       1. Part 1 Relief for new residents on foreign income and gains

          1. 1. Reliefs only deductible against income or gains to which they relate

          2. 2. QAHCs

          3. 3. Children under 10

          4. 4. Residence of personal representatives

          5. 5. Foreign gains treated as accruing when remitted to UK

          6. 6. Capital gains tax: amendments connected with end of remittance basis

          7. 7. Definitions

       2. Part 2 Temporary repatriation facility

          1. 8. Introduction

          2. 9. Deemed income under section 732 of ITA 2007

          3. 10. Value of amounts of qualifying overseas capital

          4. 11. Designation where tax paid from other sources

          5. 12. Income tax or capital gains tax reduction where TRF charge paid on same amount

          6. 13. Capital payment derived from foreign income or gains

          7. 14. Amounts derived from designated qualifying overseas capital

          8. 15. Effect on section 65(5)(b) IHTA charge etc

          9. 16. Amendment of returns

          10. 17. Transfers from mixed funds

          11. 18. Commencement of this Part

       3. Part 3 Temporary non-residence

          1. 19. (1) Section 401C of ITTOIA 2005 is amended as follows....

          2. 20. (1) Section 408A of ITTOIA 2005 is amended as follows....

          3. 21. (1) Section 413A of ITTOIA 2005 is amended as follows....

          4. 22. (1) Section 812A of ITA 2007 is amended as follows....

          5. 23. (1) The amendments made by paragraphs 19(2), 20(2), (3) and...

    4. Schedule 4

       PAYE for treaty non-residents etc

       1. Part 1 Treaty non-residents

          1. 1. Introduction

          2. 2. Notifications in respect of treaty non-resident employees

          3. 3. Consequential amendments

          4. 4. (1) Section 690E (direction by HMRC in relation to qualifying...

       2. Part 2 Other amendments of ITEPA 2003

          1. 5. ITEPA 2003 is amended as follows.

          2. 6. (1) Section 690 (internationally mobile employees) is amended as follows....

          3. 7. (1) Section 690A (employer notification for internationally mobile employees) is...

          4. 8. (1) In section 690D (employer notification for qualifying new residents)—...

          5. 9. (1) In section 690B (direction by HMRC in relation to...

          6. 10. In section 690C (employees who were internationally mobile etc. before...

    5. Schedule 5

       Unassessed transfer pricing profits

       1. 1. Assessment of transfer pricing profits that should have been included in a return

       2. 2. Consequential amendments

       3. 3. (1) In section 206(3) of FA 2013 (taxes to which...

    6. Schedule 6

       Transfer pricing

       1. Part 1 Amendments of Part 4 of TIOPA 2010

          1. 1. Introduction

          2. 2. Transfer pricing notice where participation condition not otherwise met

          3. 3. Intangible fixed assets

          4. 4. Guarantees

          5. 5. Position of guarantor of affected person's liabilities under a security issued by the person

          6. 6. (1) Section 191 (when sections 192 to 194 apply) is...

          7. 7. (1) Section 192 is amended as follows.

          8. 8. In section 192A (provision for cases within Part 6A), in...

          9. 9. In section 193 (interaction between claims under sections 184 and...

          10. 10. (1) Section 194 (claims under section 192(1)) is amended as...

          11. 11. Other references to securities

          12. 12. Commencement of paragraphs 4 to 11

          13. 13. Financing cases

          14. 14. Agreements for common management etc

          15. 15. Participation condition: anti avoidance

          16. 16. UK to UK exemption

          17. 17. Losses

          18. 18. Interpretation in accordance with OECD principles

          19. 19. Compensating adjustments

          20. 20. Removal of requirement for Commissioners’ sanction

       2. Part 2 Other amendments

          1. Chapter 1 Loan relationships etc

             1. 21. Loan relationships where provision falls within Part 4 of TIOPA 2010

             2. 22. Disallowed debits allowed where corresponding credit previously taken into account

             3. 23. Credits and debits treated as relating to capital expenditure

          2. Chapter 2 Intangible fixed assets

             1. 24. Proceeds of realisation

             2. 25. Transfers of intangible fixed assets

             3. 26. Grant of licence or other right treated as at market value

             4. 27. Deemed market value acquisition: adjustment where nil accounting value

             5. 28. Commencement of Chapter

          3. Chapter 3 Exchange gains and losses etc

             1. 29. Treatment of exchange gains and losses under Part 4 of TIOPA 2010

             2. 30. Amendments of CTA 2009

             3. 31. Designated currency elections

       3. Part 3 Commencement

          1. 32. (1) The amendments made by this Schedule have effect in...

    7. Schedule 7

       Permanent establishments

       1. Part 1 Amendments to CTA 2009

          1. 1. Introduction

          2. 2. References to Model Tax Convention

          3. 3. Attribution of profits

          4. 4. In section 20 (profits attributable to permanent establishment: introduction), for...

          5. 5. (1) Section 21 (the separate enterprise principle) is amended as...

          6. 6. Omit— (a) section 22 (transactions treated as being at arm’s...

          7. 7. In section 24 (application to insurance companies)—

          8. 8. Omit— (a) section 25 (non-UK resident banks: introduction);

          9. 9. Exclusion of income tax charge

       2. Part 2 Amendments to CTA 2010

          1. 10. Introduction

          2. 11. General interpretation

          3. 12. Dependent agents

          4. 13. Independent agents

          5. 14. Meaning of “closely related”

          6. 15. Independent investment manager conditions not sole means of showing independent status

          7. 16. Removal of the 20% rule

          8. 17. New definition of “investment transaction”

          9. 18. Removal of disregard of certain chargeable profits attributable to permanent establishment represented by investment manager

          10. 19. Lloyd’s agents

          11. 20. Omit section 1151 (Lloyd’s agents).

          12. 21. Northern Ireland regional establishments

       3. Part 3 Amendments to ITA 2007

          1. 22. Introduction

          2. 23. Investment managers (removal of the 20% rule)

          3. 24. Meaning of investment transaction

          4. 25. Lloyd’s agents

          5. 26. In section 835E (branch or agency treated as UK representative),...

          6. 27. Omit section 835K (Lloyd’s agents).

       4. Part 4 Amendments to TCGA 1992

          1. 28. (1) TCGA 1992 is amended as follows.

       5. Part 5 Consequential amendments

          1. 29. FA 2011

       6. Part 6 Commencement

          1. 30. The amendments made by this Schedule have effect in relation...

    8. Schedule 8

       Pillar Two

       1. 1. Introduction

       2. 2. Application of the income inclusion rule to cases involving permanent establishments

       3. 3. (1) Section 237 (intermediate and partially-owned parent members) is amended...

       4. 4. Elective qualifying domestic top-up taxes

       5. 5. In Schedule 16A (qualifying domestic top-up tax safe harbour election),...

       6. 6. Other provision about permanent establishments

       7. 7. In section 159 (permanent establishment income and expense attribution), at...

       8. 8. (1) Section 232 (permanent establishments) is amended as follows.

       9. 9. After section 232 insert— Legal main entity distinct from main...

       10. 10. Intragroup accounting discrepancies

       11. 11. Tax-transparent investment entities: double counting

       12. 12. Adjustments for ultimate parent that is a flow-through entity

       13. 13. Qualifying current tax expense

       14. 14. In section 176 (amounts to be reflected in qualifying current...

       15. 15. (1) Section 182 (total deferred tax adjustment amount) is amended...

       16. 16. Intragroup transactions

       17. 17. In section 182 (total deferred tax adjustment amount), in subsection...

       18. 18. Tax equity partnerships: calculation of excess return for clawback

       19. 19. Cross-border allocation of deferred tax assets and liabilities

       20. 20. Deferred tax assets and liabilities: exclusions

       21. 21. (1) Schedule 16 (transitional provision) is amended as follows.

       22. 22. (1) Schedule 16A (safe harbours) is amended as follows.

       23. 23. Post-filing adjustments of covered taxes

       24. 24. Securitisation companies

       25. 25. In Part 1 of Schedule 16A (qualifying domestic top-up tax...

       26. 26. Location of stateless entities

       27. 27. In Schedule 16A, in paragraph 7, at the end insert—...

       28. 28. Qualifying undertaxed profits tax

       29. 29. In section 256 (qualifying domestic top-up tax), omit subsection (5)....

       30. 30. (1) Section 257 (qualifying undertaxed profits tax) is amended as...

       31. 31. In Schedule 16A (safe harbours), in paragraph 2 (accredited qualifying...

       32. 32. (1) For the purposes of Part 3 of F(No.2)A 2023,...

       33. 33. Definition of “ownership interest”

       34. 34. REITs: domestic top-up tax

       35. 35. Domestic top-up tax: exchange rates

       36. 36. Domestic top-up tax: covered tax to include group relief payments

       37. 37. In subsection (8)— (a) after paragraph (a) insert—

       38. 38. Domestic top-up tax: allocation of CFC mobile income

       39. 39. Simplified calculations for non-material members

       40. 40. Minor amendments

       41. 41. In section 132 (effective tax rate), in subsection (1), in...

       42. 42. In section 144 (adjustments for asymmetric foreign currency income and...

       43. 43. In section 197A (operating leases), in subsections (2) and (3),...

       44. 44. In section 210 (transfer of assets or liabilities from a...

       45. 45. In section 247 (timing of transfers of interests), in subsection...

       46. 46. (1) Section 267 (DTT excluded entities) is amended as follows....

       47. 47. In section 272 (determining top-up amounts of entity that is...

       48. 48. In section 273 (domestic top-up tax: determining top-up amounts of...

       49. 49. In Schedule 14 (administration of multinational top-up tax)—

       50. 50. In Schedule 15 (elections) in each of paragraphs 1(1) and...

       51. 51. In Schedule 16 (multinational top-up tax: transitional provision), after paragraph...

       52. 52. (1) In FA 1989, in section 178 (setting of rates...

       53. 53. Commencement

    9. Schedule 9

       Tainted charity donations

       1. 1. Income tax

       2. 2. In section 809ZH (overview), in subsection (2), for “section 257A”...

       3. 3. In section 809ZI (relievable charity donations), in subsection (3)(b), for...

       4. 4. (1) Section 809ZJ (tainted donations) is amended as follows.

       5. 5. Omit section 809ZK (circumstances in which financial advantage deemed to...

       6. 6. (1) Section 809ZL (certain financial advantages to be ignored) is...

       7. 7. (1) Section 809ZM (removal of income tax relief in respect...

       8. 8. After section 809ZM insert— Clawback of income tax relief where...

       9. 9. (1) Section 809ZN (income tax charge where gift aid is...

       10. 10. (1) Section 809ZO (income tax charge where payment of trust...

       11. 11. Corporation tax on income

       12. 12. In section 939A (overview), in subsection (2), for “section 257A”...

       13. 13. In section 939B (relievable charity donations), in subsection (3)(b), for...

       14. 14. (1) Section 939C (tainted donations) is amended as follows.

       15. 15. Omit section 939D (circumstances in which financial advantage deemed to...

       16. 16. (1) Section 939E (certain financial advantages to be ignored) is...

       17. 17. (1) Section 939F (removal of corporation tax relief in respect...

       18. 18. After section 939F (but beneath the same italic heading) insert—...

       19. 19. Capital gains tax and corporation tax on chargeable gains

       20. 20. Consequential amendments

       21. 21. In ITEPA 2003, in section 713 (donations to charity: payroll...

       22. 22. In ITTOIA 2005, in section 108 (gifts of trading stock...

       23. 23. (1) ITA 2007 is amended as follows.

       24. 24. In CTA 2009, in section 105 (gifts of trading stock...

       25. 25. In CTA 2010, in Schedule 4 (index of defined expressions),...

    10. Schedule 10

        Winter fuel payment charge

        1. 1. The winter fuel payment charge

        2. 2. Consequential amendments

        3. 3. (1) ITEPA 2003 is amended as follows.

        4. 4. (1) ITA 2007 is amended as follows.

        5. 5. Commencement

    11. Schedule 11

        Tax treatment of carried interest

        1. Part 1 Carried interest: interpretation of key terms

           1. 1. Before Schedule 1 to ITTOIA 2005 insert— Schedule A1 Carried...

        2. Part 2 Consequential and connected amendments

           1. 2. TCGA 1992

           2. 3. ITA 2007

    12. Schedule 12

        Reform of reliefs for business property and agricultural property

        1. Part 1 Business property relief and agricultural property relief

           1. 1. Introduction

           2. 2. Business property

           3. 3. Agricultural property

           4. 4. 100% relief allowance

           5. 5. 100% trust relief allowance

           6. 6. Indexation of relief allowances

           7. 7. 100% relief allowance where relief prevented by section 113A(2) or 124A(2)

           8. 8. Application of section 131 relief

           9. 9. Rate between ten-year anniversaries

           10. 10. Property moving between settlements

           11. 11. Scottish agricultural leases

           12. 12. Certain shares no longer eligible for 100% relief

           13. 13. Instalments and interest

           14. 14. Certificates of discharge

           15. 15. Temporary relaxation of ownership and occupation conditions

           16. 16. Application of section 124E in cases where the deceased dies before 6 April 2026

           17. 17. Commencement

        2. Part 2 Inheritance tax on overseas property with value attributable to UK agricultural property

           1. 18. Amendment of Schedule A1

           2. 19. Consequential amendments

           3. 20. Commencement

    13. Schedule 13

        Abolition of bingo duty: consequential and transitional provision

        1. 1. Consequential provision

        2. 2. In FA 1982— (a) in section 8, in subsection (1),...

        3. 3. In FA 1983, in section 5, omit subsection (1).

        4. 4. In FA 1986— (a) in section 6—

        5. 5. In F(No.2)A 1992, omit section 7.

        6. 6. In FA 1994, in section 12(2)(c) omit “Schedule 3 to...

        7. 7. In VATA 1994, in section 23A— (a) in subsection (2),...

        8. 8. In FA 1997— (a) in section 10 (gaming duty)—

        9. 9. In FA 2003, omit section 9.

        10. 10. In FA 2006, in section 11, omit subsection (3).

        11. 11. In FA 2007, omit— (a) paragraph 4 of Schedule 1;...

        12. 12. In FA 2008, in Schedule 41, in the Table in...

        13. 13. In FA 2009, omit— (a) section 20;

        14. 14. In the Borders, Citizenship and Immigration Act 2009, in section...

        15. 15. In FA 2010, omit section 19.

        16. 16. In FA 2012, in Schedule 24, in paragraph 3—

        17. 17. In FA 2014— (a) omit sections 122 and 123 (and...

        18. 18. In FA 2016, in paragraph 4(2) of Schedule 18, omit...

        19. 19. In F(No.2)A 2017, in paragraph 2(1) of Schedule 17, omit...

        20. 20. In FA 2024, in the Table in section 32(1), omit...

        21. 21. Transitional and saving provision

    14. Schedule 14

        Aggregates levy: amendments relating to disapplication of levy to Scotland

        1. 1. Amendments of Part 2 of FA 2001

        2. 2. Section 17 (exemption etc of quantity of aggregate) is amended...

        3. 3. In subsection (2), after paragraph (c) insert—

        4. 4. After subsection (3) insert— (3A) In subsection (2)(ca) the reference...

        5. 5. In subsection (7), at the appropriate place insert— “relevant Scottish...

        6. 6. Section 19 (commercial exploitation) is amended as follows.

        7. 7. In subsection (1)— (a) in paragraph (a), after “site” insert...

        8. 8. In subsection (5)— (a) the words from “the aggregate” to...

        9. 9. After subsection (5) insert— (5A) The Treasury may by regulations...

        10. 10. At the end insert— (8) A statutory instrument containing regulations...

        11. 11. In section 20 (originating sites), in subsection (1)(a), for “United...

        12. 12. In section 48 (interpretation of Part), in subsection (1), at...

        13. 13. Amendments of Aggregates Levy (General) Regulations 2002

        14. 14. In regulation 13 (which relates to tax credits)—

        15. 15. In consequence of the amendment made by paragraph 14(b), in...

        16. 16. Repeals: the levy register etc

        17. 17. Omit— (a) section 44 of FA 2001 (destination of receipts),...

        18. 18. Commencement

        19. 19. Paragraphs 16 and 17 come into force on the day...

    15. Schedule 15

        Vaping products duty: amendments of other enactments

        1. 1. Penalties

        2. 2. Reviews and appeals

        3. 3. Other amendments

        4. 4. In section 1 of the Excise Duties (Surcharges or Rebates)...

        5. 5. In paragraph 11 of Schedule 5 to the Consumer Rights...

        6. 6. In paragraph 2(1) of Schedule 17 to F(No.2)A 2017 (disclosure...

        7. 7. In section 49 of TCTA 2018 in the definition of...

    16. Schedule 16

        CBAM Goods

        1. 1. The goods specified by this Schedule are goods within a...

        2. 2. (1) In this Schedule “commodity code” means a code assigned...

    17. Schedule 17

        Administration of CBAM

        1. Part 1 Introduction

           1. 1. (1) The Commissioners are responsible for the collection and management...

        2. Part 2 Registration

           1. 2. Duty to register with HMRC

           2. 3. Deregistration

           3. 4. Notification of changed or incorrect information

           4. 5. Value of CBAM goods

        3. Part 3 Payment, accounting periods and returns

           1. 6. Payment and accounting periods

           2. 7. Returns

           3. 8. (1) A person who has made a return under paragraph...

           4. 9. Power to change accounting periods and deadlines

        4. Part 4 Determination and evidence of emissions and carbon price relief

           1. 10. (1) The Commissioners may by regulations make provision about how...

           2. 11. (1) The Treasury may by notice set default values that...

           3. 12. (1) The Commissioners may by regulations make provision about how...

        5. Part 5 Measurement of weight

           1. 13. (1) The Commissioners may by regulations make provision about the...

        6. Part 6 Records

           1. 14. General requirements

           2. 15. Directions

        7. Part 7 Artificial separation of business activities

           1. 16. (1) This paragraph applies for the purpose of preventing the...

        8. Part 8 Death, incapacity and insolvency

           1. 17. (1) This paragraph applies where a registered person, who is...

           2. 18. (1) This paragraph applies where a registered person is subject...

        9. Part 9 Recovery

           1. 19. Recovery as a debt due

           2. 20. Assessments of amounts of CBAM

           3. 21. (1) Sub-paragraph (2) applies where— (a) an officer of Revenue...

           4. 22. Supplementary assessments

           5. 23. Further provision about assessments under paragraphs 20 and 22

           6. 24. Time limits for assessments

        10. Part 10 Repayments

            1. 25. Repayments of overpaid tax

            2. 26. Supplementary provision about repayment etc

            3. 27. (1) This paragraph applies where— (a) an amount has been...

            4. 28. Reimbursement arrangements

            5. 29. Assessment for excessive repayment

            6. 30. Supplementary assessments

            7. 31. Further provision about assessments under paragraphs 29 and 30

            8. 32. Time limit for assessments

        11. Part 11 Penalties

            1. 33. Penalties payable in connection with this Schedule

            2. 34. (1) Schedule 41 to FA 2008 (penalties: failure to notify...

            3. 35. In Schedule 24 to FA 2021 (penalties for failure to...

            4. 36. (1) In the table in paragraph 1 of Schedule 24...

            5. 37. In Schedule 26 to FA 2021 (penalties for failure to...

            6. 38. (1) A person (P) is liable to a penalty if...

            7. 39. A person (P) is liable to a penalty of £500...

            8. 40. (1) But a penalty is not payable under paragraph 38...

            9. 41. Penalties under paragraphs 38 or 39: administration and supplementary provision

            10. 42. (1) Where a person is liable to a penalty, an...

            11. 43. (1) Sub-paragraph (2) applies where— (a) an officer of Revenue...

            12. 44. (1) Where an assessment is made under paragraph 42(1) or...

            13. 45. (1) An officer of Revenue and Customs assessing a penalty...

            14. 46. (1) An assessment under paragraph 42(1) or (3) may not...

            15. 47. Penalties under paragraphs 38 and 39: power to amend in light of inflation

        12. Part 12 Reviews and appeals

            1. 48. Appealable decisions

            2. 49. Offer of a review to a person notified of a decision

            3. 50. Right of other persons to require review

            4. 51. Duty to review

            5. 52. Extension of time to accept or require review

            6. 53. Review out of time

            7. 54. The review

            8. 55. The review: penalties under Schedule 24 to FA 2021

            9. 56. (1) If the conclusions of a review include conclusions reached...

            10. 57. Bringing of appeals

            11. 58. Further provision about appeals

            12. 59. Determination on appeal

        13. Part 13 Service

            1. 60. (1) Anything that may or must be given, notified or...

        14. Part 14 Interpretation

            1. 61. In this Schedule, “the tribunal” means the First-tier Tribunal or,...

    18. Schedule 18

        Offences relating to CBAM

        1. Part 1 Fraudulent evasion

           1. 1. (1) A person commits an offence if the person is...

        2. Part 2 Misstatement

           1. 2. (1) A person commits an offence if, for purposes connected...

        3. Part 3 Proceedings

           1. 3. Sections 145 to 155 of CEMA 1979 (proceedings for offences,...

    19. Schedule 19

        Supplementary amendments relating to CBAM

        1. 1. Provisional collection of CBAM

        2. 2. Information and inspection powers

        3. 3. Serial tax avoidance

        4. 4. Disclosure of tax avoidance schemes

    20. Schedule 20

        Registration of tax advisers: exceptions

        1. 1. (1) A tax adviser does not contravene section 223(1) (prohibited...

    21. Schedule 21

        Registration of tax advisers: reviews and appeals

        1. 1. Appealable decisions

        2. 2. Offer of review

        3. 3. Time to accept offer of review

        4. 4. Review out of time

        5. 5. No review after appeal to the tribunal

        6. 6. Review

        7. 7. Bringing of appeals

        8. 8. Powers of tribunal

        9. 9. Temporary relief from suspension of registration pending review or appeal: amount of tax etc overdue

        10. 10. Temporary relief from suspension of registration pending review or appeal: other cases

    22. Schedule 22

        Conduct of tax advisers

        1. Part 1 Amendments to Schedule 38 to FA 2012

           1. 1. Schedule 38 to FA 2012 (tax agents: dishonest conduct) is...

           2. 2. For the Schedule heading substitute “Tax advisers: sanctionable conduct”.

           3. 3. In paragraph 1 (overview)— (a) in paragraph (a)—

           4. 4. (1) For paragraph 2 and the italic heading before it...

           5. 5. (1) In the italic heading before paragraph 3, for “Dishonest”...

           6. 6. Omit Part 2 (establishing dishonest conduct).

           7. 7. In the Part 3 heading, for “agent’s” substitute “adviser’s”.

           8. 8. In paragraph 7 (circumstances in which power is exercisable)—

           9. 9. In paragraph 8(2)(a) (file access notice), for “agent” substitute “adviser”....

           10. 10. In paragraph 9 (relevant documents)— (a) in sub-paragraph (1)—

           11. 11. In paragraph 10 (content of file access notice)—

           12. 12. In paragraph 13 (approval of file access notice by tribunal)—...

           13. 13. In paragraph 20 (appeal against file access notice)—

           14. 14. After paragraph 23 insert— Increased daily default penalty (1) This paragraph applies if— (a) a penalty under paragraph...

           15. 15. After paragraph 25 insert— Penalties for inaccurate documents (1) If a person, in purported compliance with a file...

           16. 16. After Part 3 insert— Part 3A Conduct notices Giving of...

           17. 17. In the Part 4 heading, for “dishonest” substitute “sanctionable”.

           18. 18. For paragraph 26 and the italic heading before it (penalty...

           19. 19. In paragraph 27 (special reduction)— (a) in sub-paragraph (1)—

           20. 20. In paragraph 28 (power to publish details)—

           21. 21. In paragraph 29 (assessment of penalties)— (a) in sub-paragraph (2),...

           22. 22. In paragraph 30 (deadline for assessment)— (a) in sub-paragraph (3)(a),...

           23. 23. In paragraph 31 (appeal against penalty)— (a) in sub-paragraph (1)(a),...

           24. 24. In paragraph 35 (power to change amount of penalties)—

           25. 25. In paragraph 37(1) (meaning of “tax”), after paragraph (la) insert—...

           26. 26. In paragraph 38— (a) in the definition of “client”—

           27. 27. Omit paragraph 39 (clients).

           28. 28. In paragraph 40 (loss of tax revenue), for “dishonest” substitute...

        2. Part 2 Consequential amendments

           1. 29. TMA 1970

           2. 30. Social Security Administration Act 1992

           3. 31. Social Security Administration (Northern Ireland) Act 1992

           4. 32. The Education (Student Loans) (Repayment) Regulations (Northern Ireland) 2009

           5. 33. The Education (Student Loans) (Repayment) Regulations 2009

           6. 34. FA 2012

           7. 35. The Social Security (Contributions) (Amendment and Application of Schedule 38 to the Finance Act 2012) Regulations 2013

           8. 36. The Small Charitable Donations Regulations 2013

           9. 37. FA 2014

    23. Schedule 23

        Data-gathering

        1. Part 1 Power to require provision of data to HMRC on an ongoing basis

           1. 1. Provision of data to HMRC on an ongoing basis

           2. 2. Data within possession or power

           3. 3. Due diligence and record-keeping

           4. 4. Provision of data to persons other than HMRC

           5. 5. Notification to HMRC

           6. 6. Compliance

        2. Part 2 Penalties and appeals

           1. 7. Penalties for failure to provide data to HMRC on an ongoing basis etc

           2. 8. Penalties for failure to apply due diligence procedures

           3. 9. Penalties for failure to keep or preserve records

           4. 10. Penalties for failure to provide data to other persons

           5. 11. Penalties for failure to notify

           6. 12. Penalties for failure to provide information

           7. 13. Penalties for inaccurate or incomplete data

           8. 14. Reasonable excuse

           9. 15. Duplication of liability to penalties

           10. 16. Double jeopardy

           11. 17. Failure to comply with time limit

           12. 18. Assessment of penalties

           13. 19. Time limits and treatment of penalties

           14. 20. Appeals

        3. Part 3 General

           1. 21. Power to change amount of penalties

           2. 22. Regulations

           3. 23. Application of provisions of TMA 1970

           4. 24. Crown application

           5. 25. Interpretation