Finance Act 2024

• (4) Any reference (express or implied) in any enactment, instrument or document to a provision of the pensions tax code shall be construed (so far as the context permits) as including, as respects times, circumstances or purposes in relation to which the corresponding repealed provision had effect, a reference to that corresponding provision.

• (5) Any reference (express or implied) in any enactment, instrument or document to a repealed provision shall be construed (so far as the context permits) as respects times, circumstances or purposes in relation to which the corresponding provision of the pensions tax code has effect, as being or (according to the context) including a reference to that corresponding provision.

• (6) This paragraph has effect subject to any specific transitional provision or saving contained in or made under this Schedule.

• (7) In this paragraph a reference to an enactment being repealed includes its being substituted or revoked.

• (8) In this paragraph “pensions tax code” means—

• (a) Part 4 of FA 2004 (pension schemes) and subordinate legislation made under it, and

• (b) Part 9 of ITEPA 2003 (pension income) and subordinate legislation made under it.

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

Chapter 2 of Part 3 (qualifying multinational groups and their members)

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

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

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

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

Consistency with Pillar Two rules

Chapter 2 of Part 3 (qualifying multinational groups and their members)

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

127B

• (1) Sub-paragraph (2) applies where—

• (a) a certification administrator issues a transitional tax-free amount certificate, and

• (b) there are one or more other certification administrators in relation to the individual to whom the certificate relates.

• (2) The relevant person must send a copy of the certificate to each certification administrator within sub-paragraph (1)(b).

• (3) Sub-paragraph (2) must be complied with—

• (a) before the end of the period of 90 days beginning with the day on which the relevant person receives the certificate, and

• (b) before the first day following that on which the relevant person receives the certificate on which a relevant benefit crystallisation event occurs in relation to the individual.

• (4) In the case of an obligation under sub-paragraph (2) relating to a pension scheme of which the individual is a member as a result of a block transfer, references in sub-paragraph (3) to the day on which the relevant person receives the certificate are to the later of that day and the day on which the relevant person receives notice of the block transfer.

• (5) Sub-paragraph (6) applies where—

• (a) a certification administrator cancels a transitional tax-free amount certificate, and

• (b) there are one or more other certification administrators in relation to the individual to whom the certificate relates.

• (6) The relevant person must send a copy of the notice to each certification administrator within sub-paragraph (5)(b).

• (7) Sub-paragraph (6) must be complied with—

• (a) before the end of the period of 90 days beginning with the day on which the relevant person receives notice of the cancellation, and

• (b) before the first day following that on which the relevant person receives notice of the cancellation on which a relevant benefit crystallisation event occurs in relation to the individual.

• (8) In the case of an obligation under sub-paragraph (6) relating to a pension scheme of which the individual is a member as a result of a block transfer, references in sub-paragraph (7) to the day on which the relevant person receives notice of the cancellation are to the later of that day and the day on which the relevant person receives notice of the block transfer.

• (9) In this paragraph—

• “block transfer”: a transfer is “a block transfer” in relation to a member of a pension scheme if it involves the transfer, in a single transaction, of all the sums and assets held for the purposes of, or representing accrued rights under, the arrangements under the scheme which relate to the member and at least one other member of the scheme;

• “relevant benefit crystallisation event” has the same meaning as in section 637S of ITEPA 2003 (availability of individual’s lump sum and death benefit allowance);

• “relevant person”, in relation to a transitional tax-free amount certificate, means—the individual to whom the certificate relates, orif the individual is deceased, the individual’s personal representatives.