Finance Act 2024
(2ZA) Subsection (2) does not apply to an application in the case of an undertaking given under section 8ZF or 8ZG, and in such a case on the hearing of the application an officer of Revenue and Customs— (a) must appear and call the attention of the court to any matters which appear to the officer to be relevant; (b) may give evidence or call witnesses.
;
- (5) In section 12A (Northern Irish disqualification orders), in the words before paragraph (a), after “2002” insert “or made by the High Court of Northern Ireland under section 8ZF or 8ZG”.
- (6) In section 12B (Northern Irish disqualification undertakings), in the words before paragraph (a), after “undertaking” insert “under section 8ZF or 8ZG so far as they extend to Northern Ireland or”.
- (7) In section 12C (determining unfitness etc: matters to be taken into account)—
- (a) in subsection (1)—
- (i) in paragraph (b), after “8” insert “, 8ZG”, and
- (ii) in paragraph (c), after “6” insert “or 8ZF”;
- (b) after subsection (3) insert—
(3A) This section also applies where an officer of Revenue and Customs must determine— (a) whether a person's conduct as a director of one or more companies or overseas companies makes the person unfit to be concerned in the management of a company; (b) whether to exercise any discretion the officer has to accept a disqualification undertaking under section 8ZF or 8ZG.
;
- (c) in subsection (4), after “Secretary of State” insert “or the officer (as the case may be)”.
- (8) In section 16(4) (application for disqualification order: parties), after paragraph (b) insert—
(ba) an officer of Revenue and Customs;
.
- (9) In section 17 (application for leave under an order or undertaking)—
- (a) after subsection (3ZB) insert—
(3ZC) Where a person is subject to a disqualification undertaking accepted at any time under section 8ZF or 8ZG, any application for leave for the purposes of section 1A(1)(a) must be made to any court to which, if an officer of Revenue and Customs had applied for a disqualification order under the section in question at that time, the application could have been made.
;
- (b) after subsection (5) insert—
(5A) Subsection (5) does not apply to an application for leave— (a) for the purposes of section 1(1)(a) if the application for the disqualification order was made by an officer of Revenue and Customs, or (b) for the purposes of section 1A(1)(a) if the disqualification undertaking was accepted by an officer of Revenue and Customs. (5B) In such a case, on the hearing of the application an officer of Revenue and Customs— (a) must appear and call the attention of the court to any matters which appear to the officer to be relevant; (b) may give evidence or call witnesses.
- (10) In section 18(2A) (disqualification undertakings to be included in register), after paragraph (a) insert—
(aa) disqualification undertakings accepted by an officer of Revenue and Customs under section 8ZF or 8ZG;
.
- (11) In section 20 (admissibility in evidence of statements)—
- (a) in subsection (1), after “1986” insert “or under the 1989 Order”;
- (b) in subsection (3)—
- (i) omit the “or” at the end of paragraph (c);
- (ii) at the end of paragraph (d), insert
; or (e) an offence under Article 10 of the Perjury (Northern Ireland) Order 1979 (S.I. 1979/1714 (N.I. 19)) (false statements made otherwise than on oath).
;
- (c) after subsection (4) insert—
(5) In subsection (1), “the 1989 Order” means the Insolvency (Northern Ireland) Order 1989 (S.I. 1989/2405 (N.I. 19)).
- (12) In section 21 (interaction with Insolvency Act 1986)—
- (a) in the heading, after “1986” insert “etc”;
- (b) after subsection (4) insert—
(5) Sections 8ZF and 8ZG and the other provisions of this Act so far as relating to applications and orders made, and undertakings accepted, under those provisions in Northern Ireland, are deemed included in Parts 2 to 7 of the Insolvency (Northern Ireland) Order 1989 (S.I. 1989/2405 (N.I. 19)) for the purposes of the following Articles of that Order— - Article 359 (power to make insolvency rules); - Article 361 (fees orders).
- (13) In section 22 (interpretation), after subsection (2A) insert—
(2B) So far as this Act extends to Northern Ireland, subsections (2) and (2A) do not apply and instead— - “company” means— a company registered under the Companies Act 2006 in Northern Ireland, or a company that may be wound up under Part 6 of the Insolvency (Northern Ireland) Order 1989 (S.I. 1989/2405 (N.I. 19)) (unregistered companies), and - “overseas company” means a company which is incorporated or formed outside Northern Ireland.
- (14) In section 22H (application of Act to protected cell companies)—
- (a) in subsection (1)(a), at the beginning, insert “so far as this section extends to England and Wales and Scotland,”,
- (b) after subsection (1)(a) insert—
(aa) so far as this section extends to Northern Ireland, “protected cell company” means a protected cell company incorporated under Part 4 of the Risk Transformation Regulations 2017 which has its registered office in Northern Ireland;
- (c) in subsection (4)(j), at the beginning insert “so far as this section extends to England and Wales and Scotland,”;
- (d) after subsection (4)(j), insert—
(k) so far as this section extends to Northern Ireland, references to an overseas company include references to a protected cell company incorporated under the Risk Transformation Regulations 2017 which has its registered office in England and Wales (or Wales) or Scotland.
- (15) In section 24 (extent), after subsection (2) insert—
(3) For provision extending this Act (other than sections 13 to 15) to Northern Ireland so far as relating to applications and orders made, and undertakings accepted, under section 8ZF or 8ZG, see paragraph 4 of Schedule 13 to the Finance Act 2024.
3
In the Company Directors Disqualification (Northern Ireland) Order 2002 (S.I. 2002/3150 (N.I. 4)), in the heading of Article 17, for “in Great Britain” substitute “under the Company Directors Disqualification Act 1986”.
Extent
4
- (1) The amendments made by paragraph 1 extend to England and Wales, Scotland and Northern Ireland.
- (2) The amendments made by paragraph 2 extend to—
- (a) England and Wales and Scotland, and
- (b) Northern Ireland, so far as relating to applications and orders made, and undertakings accepted, under sections 8ZF or 8ZG of CDDA 1986 (inserted by paragraph 1).
- (3) The other provisions of CDDA 1986, except for sections 13 to 15 (consequences of contravention), extend to Northern Ireland (as well as England and Wales and Scotland) so far as relating to applications and orders made, and undertakings accepted, under section 8ZF or 8ZG.
Practice and procedure
5
- (1) The procedural rules for applications under section 8 of CDDA 1986 apply to HMRC disqualification applications as they apply to applications by the Secretary of State, subject to any necessary modifications.
- (2) The procedural rules for applications under Article 11 of the Company Directors Disqualification (Northern Ireland) Order 2002 (S.I. 2002/3150 (N.I. 4)) apply to HMRC disqualification applications as they apply to applications by the Department for the Economy in Northern Ireland, subject to any necessary modifications.
- (3) Sub-paragraphs (1) and (2) apply only if, and to the extent that, there are not otherwise procedural rules for HMRC disqualification applications.
- (4) In this paragraph—
- (a) the “procedural rules” for applications of a particular kind are the rules, regulations or practice directions for the time being governing the practice and procedure (including fees) in respect of applications of that kind, and
- (b) an “HMRC disqualification application” is an application by an officer of Revenue and Customs under section 8ZF or 8ZG of CDDA 1986.
Interpretation
6
In this Schedule, “CDDA 1986” means the Company Directors Disqualification Act 1986.
Permanent full expensing etc for expenditure on plant or machinery
New regime for research and development carried out by companies
Films, television programmes and video games produced by companies
Theatrical productions made by companies
Orchestral concerts produced by companies
Museum and gallery exhibitions produced by companies
Sections 3 to 6: administration of reliefs
Miscellaneous amendments relating to REITs
Theatrical productions made by companies
Increase in capital allowances limit for ship leasing
Extension of EIS relief and VCT relief to shares issued before 6 April 2035
Relief for payments of compensation by government etc to companies
Enterprise management incentives: time limits
Provision in connection with abolition of the lifetime allowance charge
Provision relating to the cash basis
PAYE regulations: special types of payer or payee
Carer’s allowance supplement: correction of statutory reference
Growth market exemption: qualifying UK multilateral trading facilities etc
Capital-raising arrangements etc
New investment exemption
Ensuring consistency of Parts 3 and 4 of F(No.2)A 2023 with OECD rules etc
Rates of tobacco products duty
Rates of vehicle excise duty
Rates of air passenger duty
Rebate on heavy oil and certain bioblends used for heating
Vehicle excise duty exemption for foreign vehicles
Interpretation of VAT and excise law
Rates of landfill tax
Rate of aggregates levy
Rate of plastic packaging tax
Increase in maximum terms of imprisonment for tax offences
Disqualification of directors etc promoting tax avoidance schemes
Promoters of tax avoidance: failure to comply with stop notice etc
Construction industry scheme: gross payment status
Additional information to be contained in returns under TMA 1970 etc
Commencement of rules imposing penalties for failure to make returns etc
Abbreviations used in Act
Short title
FA 1998
Films Act 1985
FA 1998
FA 2007
CTA 2009
CTA 2010
Films Act 1985
ICTA
FA 1998
FA 2007
CTA 2009
FA 2009
CTA 2010
FA 2016
General commencement
Closure of existing regimes to new productions
Opting into new regime during transitional period
Productions not moving into new regime
Continuity between regimes: taxation as separate trade
Continuity between regimes: calculation of expenditure credit
Continuity between regimes: British certification
Continuity between regimes: UK expenditure (films and television programmes)
Transition of video games from European expenditure condition to UK expenditure condition
Transfer of terminal losses between productions in existing and new regimes
Introduction
Meaning of “theatrical production”
Meaning of “core expenditure”
Provision to emphasise that capital expenditure does not generally qualify for relief
UK expenditure threshold to replace EEA expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of R&D exclusion
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 5
Transitional provision in relation to paragraph 6
Introduction
Time of election for orchestral concerts to be treated as a series
Meaning of “core expenditure”
Provision to emphasise that capital expenditure does not generally qualify for relief
UK expenditure threshold to replace EEA expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of exclusion for other reliefs
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 5
Transitional provision in relation to paragraph 6
Introduction
Museum and gallery exhibitions not to be wholly remote
Meaning of “core expenditure”
UK expenditure threshold to replace European expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of exclusion for R&D relief and other creative sector reliefs
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 4
Transitional provision in relation to paragraph 5
Power to recover overpayments
Time limit for claims
Supporting information
Amendment of CTA 2010
CoACS to be institutional investors
Non-close condition
Certain institutional investors required to meet GDO or non-close condition
Paragraph 4: transitional provision
Insurance companies may be included in group UK REIT
Property financing costs
Single property rule
Disposal of rights or interests in UK property rich funds
Holders of excessive rights
Corporate interest restriction and disposal of interests in UK property rich companies
Introduction
Qualifying companies to include companies managing qualifying ships
Daily profits of managed ships
Tonnage tax activities include activities in managing ships
Effect of temporarily ceasing to manage or operate qualifying ships
Training requirement
Disapplication of 75% limit for ship managers
Commencement
Amendments of Part 4 of FA 2004 (pension schemes etc)
Amendments of Part 9 of ITEPA 2003
Amendments of the Registered Pension Schemes (Authorised Payments) Regulations 2009
Amendments of Part 4 of FA 2004
Amendments of Chapter 4 of Part 9 of ITEPA 2003
Amendments of the Pension Schemes (Application of UK Provisions to Relevant Non-UK Schemes) Regulations 2006
Amendments of Schedule 29 to FA 2004
Amendments of Schedule 34 to FA 2004
Amendments of Part 2 of Schedule 36 to FA 2004
Amendments of Part 3 of Schedule 36 to FA 2004
Amendment of Part 4 of Schedule 36 to FA 2004
Amendments of Schedule 18 to FA 2011
Amendments of Schedule 22 to FA 2013
Amendments of Schedule 6 to FA 2014
Amendments of Schedule 4 to FA 2016
Amendments of the Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006
Amendments of the Taxation of Pension Schemes (Transitional Provisions) Order 2006
Amendments of the Registered Pension Schemes (Lifetime Allowance Transitional Protection) Regulations 2011
Amendments of the Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Notification) Regulations 2013
Amendments of the Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Individual Protection 2014 Notification) Regulations 2014
Amendments of Part 4 of FA 2004
Amendments of the Registered Pension Schemes (Provision of Information) Regulations 2006
Amendments of the Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006
Commencement
Availability of individual’s lump sum allowance
Availability of individual’s lump sum and death benefit allowance
Transitional tax-free amount certificates
Provision of information by scheme administrators to members
Paragraphs 125 to 128: interpretation
Statements for certain members who would not otherwise receive one in the tax year 2024-25
Lump sum death benefits paid on or after 6 April 2024 that crystallised before that date
References in scheme rules to lifetime allowance excess lump sums
Power to make further transitional provision
Power to make further provision in connection with the abolition of lifetime allowance charge
Introduction of cash basis default
Removal of turnover restrictions etc
Removal of interest payments restriction
Removal of loss restrictions
Other amendments of Chapter 3 of Part 2
Amendments of other provisions
TMA 1970
TCGA 1992
CAA 2001
ITA 2007
Consequential repeals
Commencement
Transitional provision
Introduction
Stamp duty
Stamp duty reserve tax
Commencement
Transitional provision: depositary receipts: exception from SDRT for replacement securities
Transitional provision: clearance services: exception from SDRT for replacement securities
Transitional provision: bearer instruments
Transitional provision: warrants to purchase Government stock etc
Partnerships
Qualifying non-profit subsidiaries
Charging permanent establishments of intermediate/partially-owned parent members
De-merged groups
Adjustment for changes in accounting policies and prior period errors
Pension expense
Tax credits
Adjustments for companies in distress
Adjustments where life assurance business carried on
Exclusion of certain insurance reserve movement expense
Permanent establishment income and expense attribution
Election to spread certain capital gains
Transparent entities etc
Covered taxes
Tax equity partnerships
Reallocation of tax expense
Controlled foreign company tax regimes
Blended CFC regimes
Qualifying foreign tax credits (substitute loss carry forward assets)
Substance based income exclusion: inter-jurisdictional employees and assets
Substance based income exclusion: inclusion of payroll costs and assets voluntary
Substance based income exclusion: impairment losses
Substance based income exclusion: dual use assets
Substance based income exclusion: leases
Substance based income exclusion: power to make further provision
Transfer of assets or liabilities to a member of a multinational group
Investment entity tax transparency election
Meaning of country-by-country report
Joint ventures
Insurance investment entities
Location of entities
Currency
Application of Pillar Two rules to members of a group
Qualifying domestic top-up tax not treated as accruing
Consistency with Pillar Two rules
Overpaid tax
Intragroup transfers before entry into regime
Transitional safe harbour
Transitional reporting election
Qualifying domestic top-up tax safe harbour
Securitisation entities
Investment entities
Treatment of qualifying refundable tax credits
Effect of becoming subject to Pillar Two rules
Dividends from protected cell companies
Consistency with Pillar Two rules
Dividends from protected cell companies
Chapter 3 of Part 3 (effective tax rate)
Chapter 4 of Part 3 (calculation of adjusted profits)
Chapter 5 of Part 3 (covered tax balance)
Chapter 6 of Part 3 (calculation of top-up amounts)
Chapter 7 of Part 3 (allocating top-up amounts)
Chapter 8 of Part 3 (further adjustments)
Chapter 9 of Part 3 (special provision for investment entities etc)
Chapter 10 of Part 3 (definitions etc)
Part 4 (domestic top-up tax)
Schedules 14 to 17
Disqualification for promoting tax avoidance
Minor and consequential amendments
Extent
Practice and procedure
Interpretation
Editorial notes
Sch. 9 para. 127A and cross-heading inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(12)
Sch. 9 para. 130A and cross-heading inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(21)
Sch. 9 para. 132A and cross-heading inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(24)
Sch. 9 para. 125(2) omitted (with effect in accordance with reg. 1(3) of the amending S.I.) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(4)
Sch. 9 para. 125(1)(c) and word inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(3)(b)
Sch. 9 para. 125(3A) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(6)
Word in Sch. 9 para. 125(1)(a) omitted (with effect in accordance with reg. 1(3) of the amending S.I.) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(3)(a)
Word in Sch. 9 para. 125(3) substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(5)
Words in Sch. 9 para. 125(4) substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(7)
Sch. 9 para. 126(3A) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(10)
Word in Sch. 9 para. 126(1)(a) omitted (with effect in accordance with reg. 1(3) of the amending S.I.) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(9)(a)
Word in Sch. 9 para. 126(1)(b) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(9)(b)
Sch. 9 para. 126(1)(c) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(9)(c)
Words in Sch. 9 para. 126(4) substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(11)
Sch. 9 para. 128(6)(a)(zi) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(13)
Word in Sch. 9 para. 129(1)(a) omitted (with effect in accordance with reg. 1(3) of the amending S.I.) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(15)(a)
Sch. 9 para. 129(1)(c)(d) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(15)(b)
Words in Sch. 9 para. 129(5) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(17)(a)
Word in Sch. 9 para. 129(5) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(17)(b)
Sch. 9 para. 130(3) substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(19)
Words in Sch. 9 para. 130(4) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(20)
Sch. 9 para. 132 substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(22)
Sch. 9 para. 132 renumbered as Sch. 9 para. 132(1) (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(23)(a)
Sch. 9 para. 132(2)-(5) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(23)(c)
Words in Sch. 9 para. 132(1) inserted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2024 (S.I. 2024/356), reg. 4(23)(b)
S. 11 in force at 3.9.2024 by S.I. 2024/897, reg. 2
Sch. 1 para. 6: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch 1 para. 16: 1.4.2024 appointed for the purposes of Sch. 1 para. 16 by S.I. 2024/286, reg. 2
Sch. 1 para. 10: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 15: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 13: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 11: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 5: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 14: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 2: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 8: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 9(1)-(15): amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 12: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 3: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 4: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 1 para. 7: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by 2024 c. 3, Sch. 1 para. 16; S.I. 2024/286, reg. 2
Sch. 9 para. 128 modified (18.11.2024 for the tax year 2024-25 and subsequent tax years) by S.I. 2010/1187, reg. 21 (as inserted by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 27(23))
Sch. 9 para. 127 applied (with modifications) (18.11.2024 for the tax year 2024-25 and subsequent tax years) by S.I. 2010/1187, reg. 20 (as inserted by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 27(23))
Sch. 9 para. 128(6A) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(d)
Sch. 9 para. 128(6B) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(e)
Words in Sch. 9 para. 128(2) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(a)
Words in Sch. 9 para. 128(3)(a) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(b)
Words in Sch. 9 para. 128(5)(a) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(b)
Words in Sch. 9 para. 128(6)(a)(ii) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(6)(c)
Sch. 9 para. 127B and cross-heading inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(5)
Sch. 9 para. 126(4A) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(2)(b)
Sch. 9 para. 126(6A) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(2)(d)
Words in Sch. 9 para. 126(4)(a)(ii) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(2)(a)
Word in Sch. 9 para. 126(5) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(2)(c)(i)
Words in Sch. 9 para. 126(5) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(2)(c)(ii)
Words in Sch. 9 para. 127(1)(a) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(a)(i)
Words in Sch. 9 para. 127(1)(b) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(a)(ii)
Sch. 9 para. 127(2)(d)(e) substituted for Sch. 9 para. 127(2)(d) (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(b)(ii)
Sch. 9 para. 127(2)(b) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(b)(i)
Words in Sch. 9 para. 127(3) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(c)(i)
Words in Sch. 9 para. 127(3) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(c)(ii)
Words in Sch. 9 para. 127(4)(b) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(d)(i)
Words in Sch. 9 para. 127(4)(c) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(d)(ii)
Words in Sch. 9 para. 127(4)(d) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(d)(ii)
Words in Sch. 9 para. 127(5) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(e)(i)
Words in Sch. 9 para. 127(5) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(e)(ii)
Words in Sch. 9 para. 127(6) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(3)(f)
Sch. 9 para. 127A(4) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(4)(c)
Word in Sch. 9 para. 127A(2) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(4)(a)
Word in Sch. 9 para. 127A(3)(b) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(4)(b)
Sch. 9 para. 129(4A)-(4C) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(b)
Words in Sch. 9 para. 129(2)(a) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(a)(ii)
Word in Sch. 9 para. 129(2)(a) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(a)(iii)
Sch. 9 para. 129(2)(za) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(a)(i)
Sch. 9 para. 129(2)(c) omitted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(a)(iv)
Words in Sch. 9 para. 129(5) substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(c)(i)
Words in Sch. 9 para. 129(5) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(7)(c)(ii)
Words in Sch. 9 para. 130(4) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(8)
Sch. 9 para. 130A substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(9)
Sch. 9 para. 131 substituted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(10)
Words in Sch. 9 para. 132(2) omitted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by virtue of The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(11)(a)(i)
Words in Sch. 9 para. 132(2) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(11)(a)(ii)
Word in Sch. 9 para. 132(4) inserted (18.11.2024 for the tax year 2024-25 and subsequent tax years) by The Pensions (Abolition of Lifetime Allowance Charge etc) (No. 2) Regulations 2024 (S.I. 2024/1012), regs. 1(2)(3), 17(11)(b)
Sch. 1 para. 21(4) substituted (retrospectively) by Finance Act 2025 (c. 8), s. 30(1)(2)
Permanent full expensing etc for expenditure on plant or machinery
New regime for research and development carried out by companies
Films, television programmes and video games produced by companies
Orchestral concerts produced by companies
Museum and gallery exhibitions produced by companies
Sections 3 to 6: administration of reliefs
Miscellaneous amendments relating to REITs
Managers of ships
Increase in capital allowances limit for ship leasing
Extension of EIS relief and VCT relief to shares issued before 6 April 2035
Relief for payments of compensation by government etc to companies
Enterprise management incentives: time limits
Provision in connection with abolition of the lifetime allowance charge
MPs’ pension scheme etc: rectification of discrimination
Provision relating to the cash basis
PAYE regulations: special types of payer or payee
Carer’s allowance supplement: correction of statutory reference
Growth market exemption: qualifying UK multilateral trading facilities etc
Capital-raising arrangements etc
New investment exemption
Ensuring consistency of Parts 3 and 4 of F(No.2)A 2023 with OECD rules etc
Rates of tobacco products duty
Rates of vehicle excise duty
Rates of air passenger duty
Rebate on heavy oil and certain bioblends used for heating
Vehicle excise duty exemption for foreign vehicles
Interpretation of VAT and excise law
Rates of landfill tax
Rate of aggregates levy
Rate of plastic packaging tax
Increase in maximum terms of imprisonment for tax offences
Disqualification of directors etc promoting tax avoidance schemes
Promoters of tax avoidance: failure to comply with stop notice etc
Construction industry scheme: gross payment status
Additional information to be contained in returns under TMA 1970 etc
Commencement of rules imposing penalties for failure to make returns etc
Abbreviations used in Act
Short title
FA 1998
FA 2007
CTA 2009
CTA 2010
TIOPA 2010
FA 2013
General commencement of Parts 1 and 2
Assignments and nominations
Avoidance of overlaps and gaps in entitlement during transition
Transitional provision relating to claim notifications
Transitional provision relating to the R&D intensity condition
Higher rate of payable credit for R&D-intensive SMEs from 1 April 2023
Films Act 1985
FA 1998
FA 2007
CTA 2009
CTA 2010
Films Act 1985
ICTA
FA 1998
FA 2007
CTA 2009
FA 2009
CTA 2010
FA 2016
General commencement
Closure of existing regimes to new productions
Opting into new regime during transitional period
Productions not moving into new regime
Continuity between regimes: taxation as separate trade
Continuity between regimes: calculation of expenditure credit
Continuity between regimes: British certification
Continuity between regimes: UK expenditure (films and television programmes)
Transition of video games from European expenditure condition to UK expenditure condition
Transfer of terminal losses between productions in existing and new regimes
Introduction
Meaning of “theatrical production”
Meaning of “core expenditure”
Provision to emphasise that capital expenditure does not generally qualify for relief
UK expenditure threshold to replace EEA expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of R&D exclusion
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 5
Transitional provision in relation to paragraph 6
Introduction
Time of election for orchestral concerts to be treated as a series
Meaning of “core expenditure”
Provision to emphasise that capital expenditure does not generally qualify for relief
UK expenditure threshold to replace EEA expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of exclusion for other reliefs
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 5
Transitional provision in relation to paragraph 6
Introduction
Museum and gallery exhibitions not to be wholly remote
Meaning of “core expenditure”
UK expenditure threshold to replace European expenditure threshold
EEA expenditure not to qualify for relief
Profit element of non-arm's-length payments to connected parties not to qualify for relief
Amendment of exclusion for R&D relief and other creative sector reliefs
Restriction where tax liabilities outstanding: meaning of “payment period”
Relief not to be available for companies in insolvency
Transitional provision in relation to paragraph 4
Transitional provision in relation to paragraph 5
Power to recover overpayments
Time limit for claims
Supporting information
Amendment of CTA 2010
CoACS to be institutional investors
Non-close condition
Certain institutional investors required to meet GDO or non-close condition
Paragraph 4: transitional provision
Insurance companies may be included in group UK REIT
Property financing costs
Single property rule
Disposal of rights or interests in UK property rich funds
Holders of excessive rights
Corporate interest restriction and disposal of interests in UK property rich companies
Introduction
Qualifying companies to include companies managing qualifying ships
Daily profits of managed ships
Tonnage tax activities include activities in managing ships
Effect of temporarily ceasing to manage or operate qualifying ships
Training requirement
Disapplication of 75% limit for ship managers
Commencement
Amendments of Part 4 of FA 2004 (pension schemes etc)
Amendments of Part 9 of ITEPA 2003
Amendments of the Registered Pension Schemes (Authorised Payments) Regulations 2009
Amendments of Part 4 of FA 2004
Amendments of Chapter 4 of Part 9 of ITEPA 2003
Amendments of the Pension Schemes (Application of UK Provisions to Relevant Non-UK Schemes) Regulations 2006
Amendments of Schedule 29 to FA 2004
Amendments of Schedule 34 to FA 2004
Amendments of Part 2 of Schedule 36 to FA 2004
Amendments of Part 3 of Schedule 36 to FA 2004
Amendment of Part 4 of Schedule 36 to FA 2004
Amendments of Schedule 18 to FA 2011
Amendments of Schedule 22 to FA 2013
Amendments of Schedule 6 to FA 2014
Amendments of Schedule 4 to FA 2016
Amendments of the Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006
Amendments of the Taxation of Pension Schemes (Transitional Provisions) Order 2006
Amendments of the Registered Pension Schemes (Lifetime Allowance Transitional Protection) Regulations 2011
Amendments of the Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Notification) Regulations 2013
Amendments of the Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Individual Protection 2014 Notification) Regulations 2014
Amendments of Part 4 of FA 2004
Amendments of the Registered Pension Schemes (Provision of Information) Regulations 2006
Amendments of the Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006
Commencement
127A
- (1) This paragraph applies where—
- (a) one or more benefit crystallisation events within the meaning of Part 4 of FA 2004 occurred in relation to an individual before 6 April 2024, and
- (b) a transfer of the kind mentioned in section 244IA(1)(a) of FA 2004 is made in relation to the individual on or after that date.
- (2) Where the individual’s adjusted lifetime allowance previously-used amount is equal to or greater than the individual’s lifetime allowance, none of the individual’s overseas transfer allowance is available on the making of the transfer.
- (3) Otherwise, the amount of the individual’s overseas transfer allowance that is available on the making of the transfer is—
- (a) the amount of that allowance that is available in accordance with section 244IC of FA 2004 on the making of the transfer, less
- (b) the individual’s adjusted lifetime allowance previously-used amount,
or, if that produces a negative result, nil.
- (4) In this paragraph “adjusted lifetime allowance previously-used amount” means—
$$A-B$where—A is the lifetime allowance previously-used amount;B is the aggregate of any amounts included in A that are attributable to the occurrence, before 6 April 2024, of benefit crystallisation event 1.$
130A
- (1) The amendments made by or under this Schedule, and the amendments made by section 14, are to be disregarded for the purposes of determining—
- (a) the extent (if any) to which a transitional lump sum is a lump sum of a description permitted to be paid by the lump sum rule in section 166(1) of FA 2004, and
- (b) the tax treatment under Part 9 of ITEPA 2003 of a transitional lump sum.
- (2) In this paragraph “transitional lump sum” means a lump sum to which a member of a registered pension scheme becomes entitled before 6 April 2024 and which is paid on or after that date.
- (3) In sub-paragraph (2) “member” has the same meaning as in Part 4 of FA 2004.
132A
- (1) This paragraph applies where any provision of or made under this Schedule re-enacts (with or without modification) a provision of the pensions tax code that is repealed by or under this Schedule.
- (2) The repeal and re-enactment does not affect the continuity of the law.
- (3) Anything done (including any subordinate legislation made) or having effect as if done, under or for the purposes of the repealed provision that could have been done under or for the purposes of the corresponding provision of the pensions tax code, if in force or effective immediately before the commencement of that corresponding provision, has effect thereafter as if done under or for the purposes of that corresponding provision.
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