Legalize / United Kingdom / Finance Act 2024 / History

Reform history

Finance Act 2024

6 versions · 2024-02-22

2025-03-20

Finance Act 2024

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2024-11-18

Finance Act 2024

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2024-09-03

Finance Act 2024

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Changes on 2024-09-03

@@ -12,7 +12,7 @@

- (1) In section 7 of F(No.2)A 2023 (temporary full expensing etc for expenditure on plant or machinery), in subsection (3), in the inserted section 45S of CAA 2001, in paragraph (a), omit “but before 1 April 2026”.

- (2) In consequence of the provision made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/1/1/2024-04-06)—

- (2) In consequence of the provision made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/1/1/2024-09-03)—

- (a) the amendments made by subsections (2) to (6) of section 7 of F(No.2)A 2023 are instead to operate as textual amendments of Part 2 of CAA 2001, and

@@ -24,7 +24,7 @@

##### 2

[Schedule 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/2024-04-06)—

[Schedule 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/2024-09-03)—

- (a) replaces the existing scheme for R&D expenditure credit,

@@ -38,31 +38,31 @@

##### 3

[Schedule 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/2024-04-06) replaces Parts 15 to 15B of CTA 2009 with a new regime for the taxation of companies producing films, television programmes and video games, including relief in the form of payable credits arising from expenditure on production activities.

[Schedule 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/2024-09-03) replaces Parts 15 to 15B of CTA 2009 with a new regime for the taxation of companies producing films, television programmes and video games, including relief in the form of payable credits arising from expenditure on production activities.

#### Theatrical productions made by companies

##### 4

[Schedule 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/2024-04-06) amends the regime for the taxation of companies producing theatrical productions in Part 15C of CTA 2009.

[Schedule 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/2024-09-03) amends the regime for the taxation of companies producing theatrical productions in Part 15C of CTA 2009.

#### Orchestral concerts produced by companies

##### 5

[Schedule 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/2024-04-06) amends the regime for the taxation of companies producing orchestral concerts in Part 15D of CTA 2009.

[Schedule 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/2024-09-03) amends the regime for the taxation of companies producing orchestral concerts in Part 15D of CTA 2009.

#### Museum and gallery exhibitions produced by companies

##### 6

[Schedule 5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/2024-04-06) amends the regime for the taxation of companies producing museum and gallery exhibitions in Part 15E of CTA 2009.

[Schedule 5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/2024-09-03) amends the regime for the taxation of companies producing museum and gallery exhibitions in Part 15E of CTA 2009.

#### Sections 3 to 6: administration of reliefs

##### 7

[Schedule 6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/6/2024-04-06) amends Schedule 18 to FA 1998 (company tax returns etc) in relation to the reliefs introduced or amended by sections [3](https://www.legislation.gov.uk/ukpga/2024/3/section/3/2024-04-06) to [6](https://www.legislation.gov.uk/ukpga/2024/3/section/6/2024-04-06).

[Schedule 6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/6/2024-09-03) amends Schedule 18 to FA 1998 (company tax returns etc) in relation to the reliefs introduced or amended by sections [3](https://www.legislation.gov.uk/ukpga/2024/3/section/3/2024-09-03) to [6](https://www.legislation.gov.uk/ukpga/2024/3/section/6/2024-09-03).

### Real Estate Investment Trusts

@@ -70,7 +70,7 @@

##### 8

[Schedule 7](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/2024-04-06) makes miscellaneous amendments to the corporation tax regime for Real Estate Investment Trusts.

[Schedule 7](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/2024-09-03) makes miscellaneous amendments to the corporation tax regime for Real Estate Investment Trusts.

### Tonnage tax

@@ -78,7 +78,7 @@

##### 9

[Schedule 8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/8/2024-04-06) amends Schedule 22 to FA 2000 to make provision to enable companies, and groups of companies, that manage qualifying ships to make a tonnage tax election (so that their profits for the purposes of corporation tax are calculated in accordance with the tonnage tax regime).

[Schedule 8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/8/2024-09-03) amends Schedule 22 to FA 2000 to make provision to enable companies, and groups of companies, that manage qualifying ships to make a tonnage tax election (so that their profits for the purposes of corporation tax are calculated in accordance with the tonnage tax regime).

#### Increase in capital allowances limit for ship leasing

@@ -237,29 +237,29 @@

##### 14

- (1) [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06) contains amendments in consequence of, or otherwise in connection with, the provision made by sections 18, 19 and 23 of F(No.2)A 2023 (which relate to the abolition of the lifetime allowance charge).

- (1) [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-09-03) contains amendments in consequence of, or otherwise in connection with, the provision made by sections 18, 19 and 23 of F(No.2)A 2023 (which relate to the abolition of the lifetime allowance charge).

- (2) In that Schedule—

- (a) Part [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/1/2024-04-06) contains repeals of the provisions of Part 4 of FA 2004 (pension schemes etc) that impose the lifetime allowance charge, and amendments relating to those repeals;

- (b) Part [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/2/2024-04-06) contains amendments of Part 4 of FA 2004, Part 9 of ITEPA 2003, and subordinate legislation, relating to the taxation of lump sums paid by registered pension schemes;

- (c) Part [3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/3/2024-04-06) contains amendments of Part 4 of FA 2004, Part 9 of ITEPA 2003, and subordinate legislation, relating to the taxation of lump sums paid by certain unregistered non-UK pension schemes and to the overseas transfer charge;

- (d) Part [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/4/2024-04-06) contains amendments of provisions that confer transitional protections in relation to the introduction of the lifetime allowance charge or reductions in the amount of the lifetime allowance;

- (e) Part [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/5/2024-04-06) contains amendments of Part 4 of FA 2004 and subordinate legislation relating to the provision of information;

- (f) Part [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/6/2024-04-06) contains provision about commencement and transitional matters, and powers to make further provision.

- (3) The following provisions of F(No.2)A 2023 (which are superseded by the amendments contained in Parts 1 and 2 of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06)) are repealed—

- (a) Part [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/1/2024-09-03) contains repeals of the provisions of Part 4 of FA 2004 (pension schemes etc) that impose the lifetime allowance charge, and amendments relating to those repeals;

- (b) Part [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/2/2024-09-03) contains amendments of Part 4 of FA 2004, Part 9 of ITEPA 2003, and subordinate legislation, relating to the taxation of lump sums paid by registered pension schemes;

- (c) Part [3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/3/2024-09-03) contains amendments of Part 4 of FA 2004, Part 9 of ITEPA 2003, and subordinate legislation, relating to the taxation of lump sums paid by certain unregistered non-UK pension schemes and to the overseas transfer charge;

- (d) Part [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/4/2024-09-03) contains amendments of provisions that confer transitional protections in relation to the introduction of the lifetime allowance charge or reductions in the amount of the lifetime allowance;

- (e) Part [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/5/2024-09-03) contains amendments of Part 4 of FA 2004 and subordinate legislation relating to the provision of information;

- (f) Part [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/6/2024-09-03) contains provision about commencement and transitional matters, and powers to make further provision.

- section 18 (abolition of lifetime allowance charge);

- section 19 (certain lump sums to be taxed at marginal rate).

- (4) The amendments contained in [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06) include repeals of provisions that are spent or are no longer of practical utility.

- (4) The amendments contained in [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-09-03) include repeals of provisions that are spent or are no longer of practical utility.

#### MPs’ pension scheme etc: rectification of discrimination

@@ -355,7 +355,7 @@

##### 16

[Schedule 10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/2024-04-06) contains provision about the calculation of the profits of a trade, profession or vocation on the cash basis, including provision—

[Schedule 10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/2024-09-03) contains provision about the calculation of the profits of a trade, profession or vocation on the cash basis, including provision—

- (a) for the cash basis to be the default basis of calculation for certain persons,

@@ -385,7 +385,7 @@

> in a case where an estimate of that amount is treated as having been recovered from the payee as a result of provision made by virtue of this section.

> (5) In this section, “*payee*” and “*payer*” have the same meaning as in section 684 (see subsection (7C) of that section).

- (2) PAYE Regulations made by virtue of [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/17/1/2024-04-06) may make provision in relation to deemed direct payments made on or after 6 April 2017.

- (2) PAYE Regulations made by virtue of [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/17/1/2024-09-03) may make provision in relation to deemed direct payments made on or after 6 April 2017.

#### Carer’s allowance supplement: correction of statutory reference

@@ -393,7 +393,7 @@

- (1) In Table A in section 660 of ITEPA 2003 (taxable UK benefits), in the entry for carer’s allowance supplement, for “Sections 24 and 28” substitute “Section 81”.

- (2) The amendment made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/18/1/2024-04-06) is treated as having had effect from the time when section 12 of FA 2019 (tax treatment of social security income) came into force.

- (2) The amendment made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/18/1/2024-09-03) is treated as having had effect from the time when section 12 of FA 2019 (tax treatment of social security income) came into force.

## Part 2 — Other taxes

@@ -428,7 +428,7 @@

##### 20

[Schedule 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/2024-04-06) makes provision for and in connection with ensuring that it continues to be the case that—

[Schedule 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/2024-09-03) makes provision for and in connection with ensuring that it continues to be the case that—

- (a) no 1.5% charge to stamp duty or stamp duty reserve tax arises in relation to—

@@ -484,7 +484,7 @@

##### 22

[Schedule 12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/2024-04-06) makes amendments to F(No.2)A 2023 in relation to multinational top-up tax and in relation to domestic top-up tax.

[Schedule 12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/2024-09-03) makes amendments to F(No.2)A 2023 in relation to multinational top-up tax and in relation to domestic top-up tax.

### Excise duty rates

@@ -503,7 +503,7 @@

- (2) In consequence of the provision made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/23/1/2024-04-06), in Schedule 2 to the Travellers’ Allowances Order 1994 (which provides in certain circumstances for a simplified calculation of excise duty on goods brought into Great Britain)—

- (2) In consequence of the provision made by [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/23/1/2024-09-03), in Schedule 2 to the Travellers’ Allowances Order 1994 (which provides in certain circumstances for a simplified calculation of excise duty on goods brought into Great Britain)—

- (a) in the entry relating to cigarettes, for “£393.45” substitute “£422.80”,

@@ -696,7 +696,7 @@

##### 28

- (1) [This section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-04-06) makes provision about how—

- (1) [This section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-09-03) makes provision about how—

- (a) the European Union (Withdrawal) Act 2018 (“EUWA 2018”), and

@@ -716,7 +716,7 @@

- (b) otherwise have effect for that purpose subject to the provision made by that Act (including, in particular, the amendments made by section 6 of that Act (role of courts)).

- (6) In [this section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-04-06)—

- (6) In [this section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-09-03)—

- (a) the reference to any duty of excise is to be read in accordance with section 49 of TCTA 2018,

@@ -724,7 +724,7 @@

- (c) the reference to retained general principles of EU law is to be read in accordance with EUWA 2018 as that Act had effect immediately before the passing of REULA 2023.

- (7) [This section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-04-06) needs to be read with sections 42 and 47 of TCTA 2018 (which make other provision about EU law relating to VAT and excise law and which continue to have effect for the purpose mentioned in [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/28/1/2024-04-06) above).

- (7) [This section](https://www.legislation.gov.uk/ukpga/2024/3/section/28/2024-09-03) needs to be read with sections 42 and 47 of TCTA 2018 (which make other provision about EU law relating to VAT and excise law and which continue to have effect for the purpose mentioned in [subsection (1)](https://www.legislation.gov.uk/ukpga/2024/3/section/28/1/2024-09-03) above).

- (8) This section is treated as having come into force on 1 January 2024.

@@ -810,7 +810,7 @@

| FA 2021 | Section 78(3)(d)(i) (false statements in connection with plastic packaging tax) |

| FA 2021 | Section 79(3)(d)(i) (plastic packaging tax: conduct involving evasions or false statements) |

- (2) Subsections [(3)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/3/2024-04-06) to (5) make amendments to CEMA 1979 which are consequential on amendments to that Act made by subsection [(1)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/1/2024-04-06).

- (2) Subsections [(3)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/3/2024-09-03) to (5) make amendments to CEMA 1979 which are consequential on amendments to that Act made by subsection [(1)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/1/2024-09-03).

- (3) In section 50—

@@ -846,7 +846,7 @@

- (e) omit subsection (4C).

- (6) Subject to subsection [(7)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/7/2024-04-06), the amendments made by this section have effect in relation to offences committed on or after the day on which this Act is passed.

- (6) Subject to subsection [(7)](https://www.legislation.gov.uk/ukpga/2024/3/section/32/7/2024-09-03), the amendments made by this section have effect in relation to offences committed on or after the day on which this Act is passed.

- (7) The amendment made to section 14F of HODA 1979 so far as applying to a part of the United Kingdom other than Northern Ireland—

@@ -858,7 +858,7 @@

##### 33

[Schedule 13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/2024-04-06) makes provision for HMRC to apply for disqualification orders under the Company Directors Disqualification Act 1986 in connection with the promotion of tax avoidance schemes.

[Schedule 13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/2024-09-03) makes provision for HMRC to apply for disqualification orders under the Company Directors Disqualification Act 1986 in connection with the promotion of tax avoidance schemes.

#### Promoters of tax avoidance: failure to comply with stop notice etc

@@ -965,9 +965,9 @@

- (a) applications for gross payment status made on or after 6 April 2024, and

- (b) registrations for gross payment status which are in effect on or after 6 April 2024 (but see [subsection (5)](https://www.legislation.gov.uk/ukpga/2024/3/section/35/5/2024-04-06)).

- (5) When making a determination under section 66(1)(a) of FA 2004 (cancellation of registration for gross payment) in relation to a person registered for gross payment status before 6 April 2024, any failure by that person before 6 April 2024 to comply with an obligation to account for or pay VAT must be disregarded (notwithstanding the amendments made by [subsection (3)](https://www.legislation.gov.uk/ukpga/2024/3/section/35/3/2024-04-06)).

- (b) registrations for gross payment status which are in effect on or after 6 April 2024 (but see [subsection (5)](https://www.legislation.gov.uk/ukpga/2024/3/section/35/5/2024-09-03)).

### Administration

@@ -1022,7 +1022,7 @@

- (d) make provision about the consequences of an election ceasing to have effect.

- (4) The provision that may be made by virtue of [subsection (3)](https://www.legislation.gov.uk/ukpga/2024/3/section/37/3/2024-04-06)[(d)](https://www.legislation.gov.uk/ukpga/2024/3/section/37/3/d/2024-04-06) includes provision for an election that ceases to have effect to be treated as never having had effect, other than for the purposes of any failure in respect of which His Majesty’s Revenue and Customs have already assessed a penalty.

- (4) The provision that may be made by virtue of [subsection (3)](https://www.legislation.gov.uk/ukpga/2024/3/section/37/3/2024-09-03)[(d)](https://www.legislation.gov.uk/ukpga/2024/3/section/37/3/d/2024-09-03) includes provision for an election that ceases to have effect to be treated as never having had effect, other than for the purposes of any failure in respect of which His Majesty’s Revenue and Customs have already assessed a penalty.

### Final

@@ -1156,13 +1156,13 @@

> (2) The Treasury may by regulations replace the percentage for the time being specified in subsection [(1)](#p03498)[(a)](#p03503) or [(b)](#p03507) with a different percentage.

> (1042H) If a company is entitled to, and claims, an R&D expenditure credit for an accounting period, it must bring the amount of the credit into account as a receipt in calculating for corporation tax purposes the profits for the period of the trade concerned.

> (1042I) If a company is entitled to, and claims, an R&D expenditure credit for an accounting period, the credit is to be dealt with as follows.

> - *Step 1* The amount of the credit is to be applied in discharging any liability of the company to pay corporation tax for the accounting period.

> - *Step 2* If there is a notional tax deduction (see section [1042K](#p03589)), it is to be applied to any amount remaining after step 1.

> - *Step 3* If the amount remaining after step 2 exceeds the cap by reference to the company’s PAYE and NIC liabilities for the accounting period (see section [1112B](#p04432)), the excess is to be deducted.

> - *Step 4* Any amount remaining after step 3 is to be applied in discharging any liability of the company to pay corporation tax for any other accounting period.

> - *Step 5* If the company is a member of a group, it may surrender the whole or part of any amount remaining after step 4 to any other member of the group (as to which see section [1042N](#p03783)).

> - *Step 6* Any amount remaining after step 5 is to be applied in discharging any other liability of the company to pay a sum to the Commissioners for His Majesty’s Revenue and Customs— under or by virtue of an enactment, or under an agreement made in connection with any person’s liability to make a payment to the Commissioners under or by virtue of an enactment.

> - *Step 7* Any amount remaining after step 6 is (subject to sections [1112F](#p04826) and [1112H](#p04937)) to be paid to the company by an officer of Revenue and Customs.

> - *Step 1*The amount of the credit is to be applied in discharging any liability of the company to pay corporation tax for the accounting period.

> - *Step 2*If there is a notional tax deduction (see section [1042K](#p03589)), it is to be applied to any amount remaining after step 1.

> - *Step 3*If the amount remaining after step 2 exceeds the cap by reference to the company’s PAYE and NIC liabilities for the accounting period (see section [1112B](#p04432)), the excess is to be deducted.

> - *Step 4*Any amount remaining after step 3 is to be applied in discharging any liability of the company to pay corporation tax for any other accounting period.

> - *Step 5*If the company is a member of a group, it may surrender the whole or part of any amount remaining after step 4 to any other member of the group (as to which see section [1042N](#p03783)).

> - *Step 6*Any amount remaining after step 5 is to be applied in discharging any other liability of the company to pay a sum to the Commissioners for His Majesty’s Revenue and Customs—under or by virtue of an enactment, orunder an agreement made in connection with any person’s liability to make a payment to the Commissioners under or by virtue of an enactment.

> - *Step 7*Any amount remaining after step 6 is (subject to sections [1112F](#p04826) and [1112H](#p04937)) to be paid to the company by an officer of Revenue and Customs.

> (1042J)

> (1) This section applies if an amount is deducted under step 3 in section [1042I](#p03527).

> (2) The amount is to be added to the amount of R&D expenditure credit to which the company is entitled for its next accounting period (including where that amount would otherwise be nil).

@@ -1214,12 +1214,12 @@

> (a) the accounting period in respect of which the surrender is made is “the surrender AP”;

> (b) an accounting period of the other group member is an “overlapping AP” if it overlaps with the surrender AP to any extent.

> (3) The surrendered amount is to be dealt with as follows.

> - *Step 1* Select an overlapping AP.

> - *Step 2* Calculate the proportion of the overlapping AP that overlaps with the surrender AP, and apply that proportion to the amount of corporation tax payable by the other group member for that overlapping AP.

> - *Step 3* Calculate the proportion of the surrender AP that overlaps with the overlapping AP, and apply that proportion to the surrendered amount.

> - *Step 4* The amount given by step 3 is to be applied in discharging the liability of the other group member to pay the corporation tax mentioned in step 2, up to the amount given by that step.

> - *Step 5* Select another overlapping AP, if there is one, and repeat steps 2 to 4.

> - *Step 6* If any of the surrendered amount remains after steps 2 to 4 have been taken in relation to each overlapping AP, the remainder is to be treated for the purposes of section [1042I](#p03527) or (as the case may be) section [1042L](#p03711)[(2)](#p03719) as if it had not been surrendered as mentioned in subsection [(1)](#p03785).

> - *Step 1*Select an overlapping AP.

> - *Step 2*Calculate the proportion of the overlapping AP that overlaps with the surrender AP, and apply that proportion to the amount of corporation tax payable by the other group member for that overlapping AP.

> - *Step 3*Calculate the proportion of the surrender AP that overlaps with the overlapping AP, and apply that proportion to the surrendered amount.

> - *Step 4*The amount given by step 3 is to be applied in discharging the liability of the other group member to pay the corporation tax mentioned in step 2, up to the amount given by that step.

> - *Step 5*Select another overlapping AP, if there is one, and repeat steps 2 to 4.

> - *Step 6*If any of the surrendered amount remains after steps 2 to 4 have been taken in relation to each overlapping AP, the remainder is to be treated for the purposes of section [1042I](#p03527) or (as the case may be) section [1042L](#p03711)[(2)](#p03719) as if it had not been surrendered as mentioned in subsection [(1)](#p03785).

> (4) A surrender to which subsection [(3)](#p03806) applies is not to be—

> (a) taken into account in determining, for corporation tax purposes, the profits or losses of the qualifying company or the other group member, or

> (b) regarded for corporation tax purposes as the making of a distribution.

@@ -1436,15 +1436,15 @@

> (1112C)

> (1) This section determines the amount of a company’s relevant PAYE and NIC liabilities for a payment period for the purposes of section [1112B](#p04432).

> (2) The amount is to be calculated as follows.

> - *Step 1* Take the total amount of the company’s PAYE and NIC liabilities for the payment period (see section [1112D](#p04636)).

> - *Step 2* Add any amount produced by the application of subsection [(4)](#p04528) or [(6)](#p04578) to the company as company A.

> - *Step 3* Deduct any amount produced by the application of subsection [(4)](#p04528) or [(6)](#p04578) to the company as company B.

> - *Step 1*Take the total amount of the company’s PAYE and NIC liabilities for the payment period (see section [1112D](#p04636)).

> - *Step 2*Add any amount produced by the application of subsection [(4)](#p04528) or [(6)](#p04578) to the company as company A.

> - *Step 3*Deduct any amount produced by the application of subsection [(4)](#p04528) or [(6)](#p04578) to the company as company B.

> (3) An amount is produced by subsection [(4)](#p04528) where—

> (a) two companies (“*company A*” and “*company B*”) are connected,

> (b) company A incurs expenditure in the payment period on externally provided workers (see sections 1127 and 1128), and

> (c) company B incurs staffing costs in the payment period in providing any of those workers for company A.

> (4) The amount produced is the sum of the amounts given, in relation to each worker in respect of whom subsection [(3)](#p04511)[(c)](#p04523) is satisfied, by—

> $$X × Y Z$ where— X is the amount of expenditure that— has been incurred on staffing costs by company B in providing the worker for company A, and forms part of the total amount of company B’s PAYE and NIC liabilities for the payment period (see section [1112D](#p04636)), Y is the amount of company A’s expenditure on the externally provided worker that has been taken into account in calculating the amount of company A’s qualifying expenditure for the payment period, and Z is the total amount of company A’s qualifying expenditure on the externally provided worker (see section 1127) for the payment period.$

> $$X×YZ$where—X is the amount of expenditure that—has been incurred on staffing costs by company B in providing the worker for company A, andforms part of the total amount of company B’s PAYE and NIC liabilities for the payment period (see section [1112D](#p04636)),Y is the amount of company A’s expenditure on the externally provided worker that has been taken into account in calculating the amount of company A’s qualifying expenditure for the payment period, andZ is the total amount of company A’s qualifying expenditure on the externally provided worker (see section 1127) for the payment period.$

> (5) Subsection [(6)](#p04578) produces an amount where—

> (a) two companies (“*company A*” and “*company B*”) are connected,

> (b) company A incurs qualifying contractor expenditure in the payment period, and

@@ -1452,10 +1452,10 @@

> (6) That amount is such amount of those staffing costs as forms part of the total amount of company B’s PAYE and NIC liabilities for the payment period (see section [1112D](#p04636)).

> (7) In this section as it applies for the purposes of section [1042I](#p03527)—

> - “*qualifying expenditure*” (except in the expression “*qualifying expenditure on the externally provided worker*”) means expenditure that is qualifying Chapter [1A](#p03265) expenditure by virtue of section [1042D](#p03376), [1042E](#p03426) or [1042F](#p03457);

> - “*qualifying contractor expenditure*” means expenditure that is qualifying Chapter [1A](#p03265) expenditure by virtue of— section [1042E](#p03426), or section [1042F](#p03457) as it applies by reference to section [1042E](#p03426).

> - “*qualifying contractor expenditure*” means expenditure that is qualifying Chapter [1A](#p03265) expenditure by virtue of—section [1042E](#p03426), orsection [1042F](#p03457) as it applies by reference to section [1042E](#p03426).

> (8) In this section as it applies for the purposes of section 1058(1)—

> - “*qualifying expenditure*” (except in the expression “*qualifying expenditure on the externally provided worker*”) means qualifying Chapter 2 expenditure (see section 1051);

> - “*qualifying contractor expenditure*” means qualifying expenditure that is qualifying Chapter 2 expenditure by virtue of— section [1053](#p04220), or section [1053A](#p04250) as it applies by reference to section [1053](#p04220).

> - “*qualifying contractor expenditure*” means qualifying expenditure that is qualifying Chapter 2 expenditure by virtue of—section [1053](#p04220), orsection [1053A](#p04250) as it applies by reference to section [1053](#p04220).

> (1112D)

> (1) For the purposes of section [1112C](#p04483), the total amount of a company’s PAYE and NIC liabilities for a payment period is the sum of amount A and amount B.

> (2) Amount A is the total amount of income tax for which the company is required to account to an officer of Revenue and Customs under PAYE regulations for the period.

@@ -1484,7 +1484,7 @@

> (b) intellectual property is “relevant” intellectual property in relation to a company if the whole or the greater part (in terms of value) of it is created by the company;

> (c) intellectual property is created by a company if it is created in circumstances in which the right to exploit it vests in the company (whether alone or jointly with others).

> (4) For the purposes of this section—

> - “*intellectual property*” means— any patent, trade mark, registered design, copyright, design right or plant breeder’s right, any rights under the law of a country or territory outside the United Kingdom which correspond or are similar to those falling within paragraph (a), or any information or technique not protected by a right within paragraph (a) or (b) but having industrial, commercial or other economic value;

> - “*intellectual property*” means—any patent, trade mark, registered design, copyright, design right or plant breeder’s right,any rights under the law of a country or territory outside the United Kingdom which correspond or are similar to those falling within paragraph (a), orany information or technique not protected by a right within paragraph (a) or (b) but having industrial, commercial or other economic value;

> - “*management activity*”, in relation to intellectual property, means formulating plans and making decisions in relation to the development or exploitation of the intellectual property.

> (5) A company meets condition B for an accounting period if the amount (if any) given by subsection [(6)](#p04782) does not exceed 15% of the company’s qualifying expenditure for the period.

> (6) The amount given by this subsection is the sum of the following incurred by the company in the period—

@@ -1728,7 +1728,7 @@

> (2) Accordingly, a purported assignment of such a right, or an agreement to assign such a right, is void.

> (3) References to assignment in this section are to be read in Scotland as references to assignation.

- (17) After section [1142C](#p05527) (inserted by sub-paragraph [(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-04-06)) insert—

- (17) After section [1142C](#p05527) (inserted by sub-paragraph [(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-09-03)) insert—

> (1142D)

> (1) Where an amount of R&D expenditure credit or R&D tax credit is owed to a company, an officer of Revenue and Customs may not pay the amount to a person other than the company (even on the instruction or at the request of the company).

@@ -1736,7 +1736,7 @@

> (a) the company requests that payment be made to a person connected with the company, or

> (b) the officer is satisfied that exceptional circumstances make payment to the company impracticable or inconvenient.

- (18) After section [1142D](#p05551) (inserted by sub-paragraph [(17)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/17/2024-04-06)) insert—

- (18) After section [1142D](#p05551) (inserted by sub-paragraph [(17)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/17/2024-09-03)) insert—

> (1142E) Any order or regulations under this Part may—

> (a) contain incidental, supplemental, consequential and transitional provision and savings;

@@ -1772,7 +1772,7 @@

- (1) CTA 2009 is amended as follows.

- (2) In [Part 14A](#p06244) (inserted by paragraph [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/1/2024-04-06) of [Schedule 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/2024-04-06))—

- (2) In [Part 14A](#p06244) (inserted by paragraph [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/1/2024-09-03) of [Schedule 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/2024-09-03))—

- (a) in section [1179DT](#p08110) (expenditure attracting R&D relief not eligible for audiovisual expenditure credit), omit paragraph [(a)](#p08114);

@@ -1802,7 +1802,7 @@

- (b) in paragraph (b), omit “additional”.

- (7) In section 1217RF(2) (expenditure attracting R&D relief or other creative sector relief not eligible for orchestra relief), omit paragraph [(za)](#p11459) (inserted by paragraph [8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/8/2024-04-06) of [Schedule 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/2024-04-06)).

- (7) In section 1217RF(2) (expenditure attracting R&D relief or other creative sector relief not eligible for orchestra relief), omit paragraph [(za)](#p11459) (inserted by paragraph [8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/8/2024-09-03) of [Schedule 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/2024-09-03)).

- (8) In section 1218ZCG(2) (expenditure attracting R&D relief or other creative sector relief not eligible for museum and gallery exhibition relief)—

@@ -1918,7 +1918,7 @@

- (a) in section 357BJB(3) (R&D expenditure not to be routine deduction in calculating IP profits), in paragraph (a)(ii), for “Chapter 6A of Part 3 of CTA 2009” substitute “Chapter [1A](#p03265) of that Part”;

- (b) in section 357BLB(7)(e) (application of sections 1127 to 1131 of CTA 2009 for purpose of determining in-house R&D expenditure under Part 8A), at the end insert “as those provisions had effect before the amendments made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-04-06) of [Schedule 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/2024-04-06) to FA 2024,”;

- (b) in section 357BLB(7)(e) (application of sections 1127 to 1131 of CTA 2009 for purpose of determining in-house R&D expenditure under Part 8A), at the end insert “as those provisions had effect before the amendments made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-09-03) of [Schedule 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/2024-09-03) to FA 2024,”;

- (c) in section 357CG(4)(a) (R&D expenditure credit to be deducted in calculating IP profits), for “Chapter 6A of Part 3” substitute “Chapter [1A](#p03265) of Part 13”.

@@ -1971,7 +1971,7 @@

##### 16

- (1) The amendments made by this Schedule, except those made by sub-paragraphs [(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-04-06) to [(18)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/18/2024-04-06) of paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-04-06), have effect in relation to accounting periods beginning on or after the appointed day.

- (1) The amendments made by this Schedule, except those made by sub-paragraphs [(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-09-03) to [(18)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/18/2024-09-03) of paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-09-03), have effect in relation to accounting periods beginning on or after the appointed day.

- (2) In this Part, the “appointed day” is a day appointed by the Treasury in regulations.

@@ -1979,7 +1979,7 @@

##### 17

- (1) The amendment made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-04-06)[(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-04-06) does not have effect in relation to—

- (1) The amendment made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-09-03)[(16)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/16/2024-09-03) does not have effect in relation to—

- (a) an assignment made before 22 November 2023,

@@ -1987,13 +1987,13 @@

- (c) an assignment made on or after that date to carry out an agreement made before that date.

- (2) The amendment made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-04-06)[(17)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/17/2024-04-06) has effect only in relation to claims made on or after 1 April 2024.

- (2) The amendment made by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-09-03)[(17)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/17/2024-09-03) has effect only in relation to claims made on or after 1 April 2024.

#### Avoidance of overlaps and gaps in entitlement during transition

##### 18

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/2/2024-04-06) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/3/2024-04-06) apply if, but for those sub-paragraphs—

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/2/2024-09-03) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/3/2024-09-03) apply if, but for those sub-paragraphs—

- (a) one company (“*company A*”) would be entitled to old R&D relief, and

@@ -2001,11 +2001,11 @@

in respect of expenditure attributable to the same research and development.

- (2) If company B would have been entitled to old R&D relief in respect of its expenditure had the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments not been made, only company B is entitled to the relief.

- (2) If company B would have been entitled to old R&D relief in respect of its expenditure had the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-09-03) amendments not been made, only company B is entitled to the relief.

- (3) In any other case, only company A is entitled to the relief.

- (4) Sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/5/2024-04-06) applies if—

- (4) Sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/5/2024-09-03) applies if—

- (a) a company incurs pre-commencement expenditure,

@@ -2015,33 +2015,33 @@

- (i) qualifying [Chapter 1A](#p03265) expenditure by virtue of section [1042E](#p03426) of CTA 2009 or section [1042F](#p03457) of that Act as it refers to section [1042E](#p03426), or

- (ii) qualifying Chapter 2 expenditure by virtue of section 1053 of CTA 2009 (as it has effect after the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments) or section [1053A](#p04250) of that Act as it refers to section 1053.

- (5) The company is to be treated as satisfying sections [1042F](#p03457)[(4)](#p03474) and [1053A](#p04250)[(4)](#p04266) of CTA 2009 for the purposes of ascertaining the entitlement of another company to new R&D relief in respect of expenditure attributable to the same research and development as the expenditure mentioned in sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/4/2024-04-06).

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/7/2024-04-06) applies if—

- (ii) qualifying Chapter 2 expenditure by virtue of section 1053 of CTA 2009 (as it has effect after the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-09-03) amendments) or section [1053A](#p04250) of that Act as it refers to section 1053.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/18/7/2024-09-03) applies if—

- (a) in respect of pre-commencement expenditure attributable to research and development, one company (“*company C*”)—

- (i) is not entitled to old R&D relief, but

- (ii) would be so entitled if none of sections 104C(2), 104G(5), 104H(6), 104J(4), 104K(5), 104L(4), 1052(5) and 1053(4) of CTA 2009 (as they have effect before the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments) applied, and

- (b) in respect of post-commencement expenditure attributable to the same research and development, another company (“*company D*”) would, had the expenditure been pre-commencement expenditure, have been entitled to old R&D relief by virtue of section 1053 of CTA 2009 (as it has effect before the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments).

- (7) For the purpose of ascertaining the entitlement of company D to new R&D relief, the research and development is to be treated as contracted out by company D within the meaning of section [1133](#p05125) of CTA 2009 (as it has effect after the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments).

- (8) In this paragraph—

- “*the new R&D provisions*” means Part 13 of CTA 2009 as it has effect after the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments;

- “*the new R&D provisions*” means Part 13 of CTA 2009 as it has effect after the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-09-03) amendments;

- “*new R&D relief*” means relief under the new R&D provisions;

- “*the old R&D provisions*” means Chapter 6A of Part 3 or Part 13 of CTA 2009 as that Chapter or Part has effect before the [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) amendments;

- “*old R&D relief*” means relief under the old R&D provisions;

- “*the Part 1 amendments*” means the amendments made by [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-04-06) of this Schedule;

- “*the Part 1 amendments*” means the amendments made by [Part 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/part/1/2024-09-03) of this Schedule;

- “*post-commencement expenditure*” means expenditure incurred in an accounting period beginning on or after the appointed day;

@@ -2051,15 +2051,15 @@

##### 19

The reference in section 1142B of CTA 2009 (as amended by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-04-06)[(15)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/15/2024-04-06)) to claims under section [1042C](#p03345) of that Act is to be read as including claims under section 104A of that Act before its repeal by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/2/2024-04-06).

The reference in section 1142B of CTA 2009 (as amended by paragraph [9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/2024-09-03)[(15)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/15/2024-09-03)) to claims under section [1042C](#p03345) of that Act is to be read as including claims under section 104A of that Act before its repeal by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/2/2024-09-03).

#### Transitional provision relating to the R&D intensity condition

##### 20

The references in sections 1044[(2A)](#p03966)[(b)](#p03973) and 1045[(2A)](#p04034)[(b)](#p04041) of CTA 2009 (inserted by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/2024-04-06)[(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/4/2024-04-06) and [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/5/2024-04-06)) to having met the R&D intensity condition in an accounting period—

- (a) include having met the R&D intensity condition for the purposes of paragraph [21](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/2024-04-06) in an accounting period to which that paragraph applies, but

The references in sections 1044[(2A)](#p03966)[(b)](#p03973) and 1045[(2A)](#p04034)[(b)](#p04041) of CTA 2009 (inserted by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/2024-09-03)[(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/4/2024-09-03) and [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/5/2024-09-03)) to having met the R&D intensity condition in an accounting period—

- (a) include having met the R&D intensity condition for the purposes of paragraph [21](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/2024-09-03) in an accounting period to which that paragraph applies, but

- (b) are not applicable to any other accounting period beginning before the appointed day.

@@ -2067,7 +2067,7 @@

##### 21

- (1) Sub-paragraph [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/2/2024-04-06) applies if, in an accounting period beginning before the appointed day but ending on or after 1 April 2023, a company—

- (1) Sub-paragraph [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/2/2024-09-03) applies if, in an accounting period beginning before the appointed day but ending on or after 1 April 2023, a company—

- (a) has a Chapter 2 surrenderable loss, and

@@ -2075,7 +2075,7 @@

- (2) The amount of R&D tax credit to which the company is entitled for the period is to be determined as if the amendment made by section 4(3)(d) of FA 2023 (reduction in rate of credit from 14.5% to 10%) had not been made.

- (3) Subsections [(2)](#p04088) to [(7)](#p04134) of section [1045ZA](#p04082) of CTA 2009, as inserted by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/2024-04-06)[(6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/6/2024-04-06), determine whether a company meets the R&D intensity condition in an accounting period for the purposes of sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/1/2024-04-06)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/1/b/2024-04-06).

- (3) Subsections [(2)](#p04088) to [(7)](#p04134) of section [1045ZA](#p04082) of CTA 2009, as inserted by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/2024-09-03)[(6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/6/6/2024-09-03), determine whether a company meets the R&D intensity condition in an accounting period for the purposes of sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/1/2024-09-03)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/1/b/2024-09-03).

- (4) But that section is to be read for the purposes of sub-paragraph (3) as if—

@@ -3015,9 +3015,9 @@

- (1) The Films Act 1985 is amended as follows.

- (2) In section 6 (certification of British films) (as amended by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/2/2024-04-06)), omit “and film tax relief”.

- (3) In Schedule 1 (certification of British films) (as amended by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/2/2024-04-06))—

- (2) In section 6 (certification of British films) (as amended by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/2/2024-09-03)), omit “and film tax relief”.

- (3) In Schedule 1 (certification of British films) (as amended by paragraph [2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/2/2024-09-03))—

- (a) in the heading, omit “and film tax relief”;

@@ -3045,7 +3045,7 @@

- (2) In paragraph 10 (certain claims and elections to be included in tax return), omit sub-paragraphs (5) to (7).

- (3) In paragraph 52 (recovery of excessive payments), in sub-paragraph [(2B)](#p12295) (inserted by [Schedule 6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/6/2024-04-06)), omit paragraphs [(b)](#p12304) to [(d)](#p12312).

- (3) In paragraph 52 (recovery of excessive payments), in sub-paragraph [(2B)](#p12295) (inserted by [Schedule 6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/6/2024-09-03)), omit paragraphs [(b)](#p12304) to [(d)](#p12312).

- (4) In paragraph 83S (application of Part 9D), omit sub-paragraphs (a) to (c).

@@ -3361,7 +3361,7 @@

- (1) No election under section [1179B](#p06412)[(1)](#p06414) of CTA 2009 may be made in a company tax return for an accounting period ending before 1 January 2024.

- (2) The amendments made by Parts [3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/part/3/2024-04-06) and [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/part/4/2024-04-06) of this Schedule have effect in relation to accounting periods beginning on or after 1 April 2027.

- (2) The amendments made by Parts [3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/part/3/2024-09-03) and [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/part/4/2024-09-03) of this Schedule have effect in relation to accounting periods beginning on or after 1 April 2027.

#### Closure of existing regimes to new productions

@@ -3379,9 +3379,9 @@

- (b) the relevant existing regime applies in respect of the portion of the accounting period that falls before that date.

- (2) If a company makes an election under section [1179B](#p06412)[(1)](#p06414) of CTA 2009 in its company tax return for an accounting period beginning on or after 1 January 2024, the relevant existing regime does not apply in relation to that accounting period or any subsequent accounting period, subject to sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/3/2024-04-06) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/4/2024-04-06).

- (3) If a company makes an election under section [1179B](#p06412)[(1)](#p06414) of CTA 2009 in its company tax return for an accounting period beginning on or before but ending after the relevant closure date, it may further elect in the return for sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/4/2024-04-06) to apply.

- (2) If a company makes an election under section [1179B](#p06412)[(1)](#p06414) of CTA 2009 in its company tax return for an accounting period beginning on or after 1 January 2024, the relevant existing regime does not apply in relation to that accounting period or any subsequent accounting period, subject to sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/3/2024-09-03) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/4/2024-09-03).

- (4) If it does so—

@@ -3393,7 +3393,7 @@

- (a) those Parts, and

- (b) paragraphs [19](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/2024-04-06) to [24](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/2024-04-06) (but not for other corporation tax purposes).

- (b) paragraphs [19](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/2024-09-03) to [24](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/2024-09-03) (but not for other corporation tax purposes).

- (6) For the purposes of this paragraph—

@@ -3419,7 +3419,7 @@

##### 19

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/2/2024-04-06) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/3/2024-04-06) apply if, but for this paragraph, Part 15, 15A or 15B of CTA 2009 would apply to a company in relation to a film, television programme or video game in respect of an accounting period beginning on or before but ending after the relevant closure date.

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/2/2024-09-03) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/19/3/2024-09-03) apply if, but for this paragraph, Part 15, 15A or 15B of CTA 2009 would apply to a company in relation to a film, television programme or video game in respect of an accounting period beginning on or before but ending after the relevant closure date.

- (2) The company is to be treated for the purposes of the Part in question as if, at the end of the relevant closure date, it—

@@ -3429,13 +3429,13 @@

- (3) No election under section [1179B](#p06412)[(1)](#p06414) of CTA 2009 may be made in relation to the film, television programme or video game.

- (4) The date that is the relevant closure date for the purposes of paragraph [18](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/2024-04-06) is also the relevant closure date for the purposes of this paragraph.

- (4) The date that is the relevant closure date for the purposes of paragraph [18](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/18/2024-09-03) is also the relevant closure date for the purposes of this paragraph.

#### Continuity between regimes: taxation as separate trade

##### 20

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/20/2/2024-04-06) to [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/20/5/2024-04-06) apply if—

- (1) Sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/20/2/2024-09-03) to [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/20/5/2024-09-03) apply if—

- (a) a company is treated as carrying on a separate trade under Part 15, 15A or 15B of CTA 2009 in an accounting period (“AP1”),

@@ -3459,7 +3459,7 @@

##### 21

- (1) Sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/3/2024-04-06) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/4/2024-04-06) apply if—

- (1) Sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/3/2024-09-03) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/4/2024-09-03) apply if—

- (a) a company is entitled to audiovisual expenditure credit or video game expenditure credit under Chapter [3](#p06797) of Part [14A](#p06244) of CTA 2009 for an accounting period, and

@@ -3473,7 +3473,7 @@

- (c) both entitlements relate to the same film, television programme or video game.

- (2) In those sub-paragraphs, the earliest accounting period within sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/2024-04-06)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/a/2024-04-06) is “AP2” and the latest accounting period within sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/2024-04-06)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/b/2024-04-06) is “AP1”.

- (2) In those sub-paragraphs, the earliest accounting period within sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/2024-09-03)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/a/2024-09-03) is “AP2” and the latest accounting period within sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/2024-09-03)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/21/1/b/2024-09-03) is “AP1”.

- (3) For the purposes of step 1 in section [1179CA](#p06840)[(1)](#p06842) of CTA 2009 as it applies in relation to AP2, the reference to relevant global expenditure includes the amount that was “*qualifying expenditure incurred to date*” for the purposes of section 1200(1) or (2), 1216CG(1) or (2) or 1217CG(1) or (2) of that Act in relation to AP1.

@@ -3514,7 +3514,7 @@

##### 24

- (1) Sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/3/2024-04-06) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/4/2024-04-06) apply if—

- (1) Sub-paragraphs [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/3/2024-09-03) and [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/2/paragraph/24/4/2024-09-03) apply if—

- (a) a company makes an election under section [1179B](#p06412)[(1)](#p06414) in relation to a video game in its company tax return for an accounting period (“the opt-in period”),

@@ -3655,7 +3655,7 @@

- (5) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/2024-04-06).

- (5) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/2024-09-03).

#### EEA expenditure not to qualify for relief

@@ -3663,7 +3663,7 @@

- (1) In section 1217J(2) and (3) (amount of relief for theatrical production), for “European” substitute “UK”.

- (2) For transitional provision in relation to this paragraph, see paragraph [12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/2024-04-06).

- (2) For transitional provision in relation to this paragraph, see paragraph [12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/2024-09-03).

#### Profit element of non-arm's-length payments to connected parties not to qualify for relief

@@ -3740,7 +3740,7 @@

##### 11

- (1) This paragraph makes transitional provision in connection with paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06).

- (1) This paragraph makes transitional provision in connection with paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03).

- (2) The amendments made by that paragraph do not apply in relation to a theatrical production if—

@@ -3748,7 +3748,7 @@

- (b) the separate theatrical trade in respect of it ceases before 1 April 2025.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/4/2024-04-06) applies if—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/4/2024-09-03) applies if—

- (a) a theatrical production has entered production before 1 April 2024,

@@ -3766,21 +3766,21 @@

is unaffected by a failure to meet the UK expenditure condition so far as the entitlement derives from expenditure incurred before 1 April 2025.

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/4/2024-04-06), an entitlement to a tax credit under section 1217H of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1217KA of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/7/2024-04-06) applies in relation to a theatrical production in respect of which the separate theatrical trade continues on or after 1 April 2025.

- (7) The reference in section 1217NA(1) of CTA 2009, as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06), to a statement having been made under section 1217N(2) of that Act includes reference to a statement having been made in relation to the European expenditure condition under that provision before it was amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06).

- (8) But the application of section 1217NA(1) of CTA 2009 as so amended is subject to sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/4/2024-04-06) (where that sub-paragraph applies).

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/4/2024-09-03), an entitlement to a tax credit under section 1217H of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1217KA of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/11/7/2024-09-03) applies in relation to a theatrical production in respect of which the separate theatrical trade continues on or after 1 April 2025.

- (7) The reference in section 1217NA(1) of CTA 2009, as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03), to a statement having been made under section 1217N(2) of that Act includes reference to a statement having been made in relation to the European expenditure condition under that provision before it was amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03).

- (9) In this paragraph—

- “*theatrical production*”, “*separate theatrical trade*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15C of CTA 2009;

- “*UK expenditure condition*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06);

- “*European expenditure*” and “European expenditure condition” have the same meanings as in that Part before the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06).

- “*UK expenditure condition*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03);

- (10) For the purposes of this paragraph, a theatrical production “enters production” when core expenditure is first incurred on it.

@@ -3788,29 +3788,29 @@

##### 12

- (1) This paragraph makes transitional provision in relation to paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/6/2024-04-06).

- (1) This paragraph makes transitional provision in relation to paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/6/2024-09-03).

- (2) The amendments made by that paragraph have effect in relation to accounting periods ending on or after 1 April 2024.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/4/2024-04-06) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217J of CTA 2009 (amount of relief for theatrical production).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/6/2024-04-06)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/4/2024-09-03) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217J of CTA 2009 (amount of relief for theatrical production).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/6/2024-09-03)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (a) has been incurred before 1 April 2024 and is European expenditure, or

- (b) has been incurred on or after that date and is UK expenditure.

- (5) But if the theatrical production in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/4/2024-04-06) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that production as if “2025” were substituted for “2024”.

- (5) But if the theatrical production in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/4/2024-09-03) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that production as if “2025” were substituted for “2024”.

- (6) In this paragraph—

- “*theatrical production*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15C of CTA 2009;

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06);

- “*European expenditure*” has the same meaning as in that Part before the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-04-06).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/5/2024-04-06), a theatrical production “enters production” when core expenditure is first incurred on it.

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03);

- “*European expenditure*” has the same meaning as in that Part before the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/5/2024-09-03).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/3/paragraph/12/5/2024-09-03), a theatrical production “enters production” when core expenditure is first incurred on it.

## Schedule 4

@@ -3909,7 +3909,7 @@

- (5) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/2024-04-06).

- (5) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/2024-09-03).

#### EEA expenditure not to qualify for relief

@@ -3917,7 +3917,7 @@

- (1) In section 1217RE(2) and (3) (amount of relief for orchestral concert), for “European” substitute “UK”.

- (2) For transitional provision in relation to this paragraph, see paragraph [12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/2024-04-06).

- (2) For transitional provision in relation to this paragraph, see paragraph [12](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/2024-09-03).

#### Profit element of non-arm's-length payments to connected parties not to qualify for relief

@@ -4006,7 +4006,7 @@

##### 11

- (1) This paragraph makes transitional provision in relation to paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-04-06).

- (1) This paragraph makes transitional provision in relation to paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-09-03).

- (2) The amendments made by that paragraph do not apply in relation to an orchestral concert or concert series if—

@@ -4014,7 +4014,7 @@

- (b) the separate orchestral trade in respect of it ceases before 1 April 2025.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/4/2024-04-06) applies if—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/4/2024-09-03) applies if—

- (a) an orchestral concert or concert series has entered production before 1 April 2024,

@@ -4032,21 +4032,21 @@

is unaffected by a failure to meet the UK expenditure condition so far as the entitlement derives from expenditure incurred before 1 April 2025.

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/4/2024-04-06), an entitlement to a tax credit under section 1217RG of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1217RH of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/7/2024-04-06) applies in relation to an orchestral concert or concert series in respect of which the separate orchestral trade continues on or after 1 April 2025.

- (7) The reference in section 1217TA(1) of CTA 2009, as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-04-06)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2/2024-04-06)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2/c/2024-04-06), to a statement having been made under section 1217T(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition.

- (8) But the application of section 1217TA(1) of CTA 2009 as so amended is subject to sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/4/2024-04-06) (where that sub-paragraph applies).

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/4/2024-09-03), an entitlement to a tax credit under section 1217RG of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1217RH of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/11/7/2024-09-03) applies in relation to an orchestral concert or concert series in respect of which the separate orchestral trade continues on or after 1 April 2025.

- (7) The reference in section 1217TA(1) of CTA 2009, as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-09-03)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2/2024-09-03)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2/c/2024-09-03), to a statement having been made under section 1217T(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition.

- (9) In this paragraph—

- “*orchestral concert*”, “*concert series*”, “*separate orchestral trade*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15D of CTA 2009;

- “*UK expenditure condition*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-04-06);

- “*UK expenditure condition*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-09-03);

- (10) For the purposes of this paragraph, an orchestral concert or concert series “enters production” when core expenditure is first incurred on it.

@@ -4054,29 +4054,29 @@

##### 12

- (1) This paragraph makes transitional provision in relation to paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/6/2024-04-06).

- (1) This paragraph makes transitional provision in relation to paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/6/2024-09-03).

- (2) The amendments made by that paragraph have effect in relation to accounting periods ending on or after 1 April 2024.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/4/2024-04-06) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217RE of CTA 2009 (amount of relief for orchestral concert).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/6/2024-04-06)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/4/2024-09-03) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217RE of CTA 2009 (amount of relief for orchestral concert).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [6](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/6/2024-09-03)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (a) has been incurred before 1 April 2024 and is European expenditure, or

- (b) has been incurred on or after that date and is UK expenditure.

- (5) But if the orchestral concert or concert series in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/4/2024-04-06) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that concert or series as if “2025” were substituted for “2024”.

- (5) But if the orchestral concert or concert series in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/4/2024-09-03) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that concert or series as if “2025” were substituted for “2024”.

- (6) In this paragraph—

- “*orchestral concert*”, “*concert series*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15D of CTA 2009;

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-04-06);

- “*European expenditure*” has the same meaning as in that Part before the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-04-06).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/5/2024-04-06), an orchestral concert or concert series “enters production” when core expenditure is first incurred on it.

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-09-03);

- “*European expenditure*” has the same meaning as in that Part before the amendments made by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/5/2024-09-03).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/4/paragraph/12/5/2024-09-03), an orchestral concert or concert series “enters production” when core expenditure is first incurred on it.

## Schedule 5

@@ -4163,7 +4163,7 @@

- (5) For transitional provision in relation to this paragraph, see paragraph [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/2024-04-06).

- (5) For transitional provision in relation to this paragraph, see paragraph [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/2024-09-03).

#### EEA expenditure not to qualify for relief

@@ -4171,7 +4171,7 @@

- (1) In section 1218ZCF(2) and (3) (amount of relief for museum or gallery exhibition), for “European” substitute “UK”.

- (2) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/2024-04-06).

- (2) For transitional provision in relation to this paragraph, see paragraph [11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/2024-09-03).

#### Profit element of non-arm's-length payments to connected parties not to qualify for relief

@@ -4248,7 +4248,7 @@

##### 10

- (1) This paragraph makes transitional provision in relation to paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06).

- (1) This paragraph makes transitional provision in relation to paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-09-03).

- (2) The amendments made by that paragraph do not have effect in relation to an exhibition if—

@@ -4256,7 +4256,7 @@

- (b) the separate exhibition trade in respect of it ceases before 1 April 2025.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/4/2024-04-06) applies if—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/4/2024-09-03) applies if—

- (a) an exhibition has entered production before 1 April 2024,

@@ -4274,21 +4274,21 @@

is unaffected by a failure to meet the UK expenditure condition so far as the entitlement derives from expenditure incurred before 1 April 2025.

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/4/2024-04-06), an entitlement to a tax credit under section 1218ZCH of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1218ZCI of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/7/2024-04-06) applies in relation to an exhibition in respect of which the separate exhibition trade continues on or after 1 April 2025.

- (7) The reference in section 1218ZEA(1) of CTA 2009, as amended by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2/2024-04-06)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2/c/2024-04-06), to a statement having been made under section 1218ZE(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition.

- (8) But the application of section 1218ZEA(1) of CTA 2009 as so amended is subject to sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/4/2024-04-06) (where that sub-paragraph applies).

- (5) For the purposes of sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/4/2024-09-03), an entitlement to a tax credit under section 1218ZCH of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1218ZCI of that Act.

- (6) Sub-paragraph [(7)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/10/7/2024-09-03) applies in relation to an exhibition in respect of which the separate exhibition trade continues on or after 1 April 2025.

- (7) The reference in section 1218ZEA(1) of CTA 2009, as amended by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-09-03)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2/2024-09-03)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2/c/2024-09-03), to a statement having been made under section 1218ZE(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition.

- (9) In this paragraph—

- “*exhibition*”, “*separate exhibition trade*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15E of CTA 2009;

- “*UK expenditure*” and “UK expenditure condition” have the same meanings as in that Part after the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06);

- “*European expenditure*” and “European expenditure condition” have the same meanings as in that Part before the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06).

- (10) For the purposes of this paragraph, an exhibition “enters production” when core expenditure is first incurred on it.

@@ -4296,29 +4296,29 @@

##### 11

- (1) This paragraph makes transitional provision in relation to paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/5/2024-04-06).

- (1) This paragraph makes transitional provision in relation to paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/5/2024-09-03).

- (2) The amendments made by that paragraph have effect in relation to accounting periods ending on or after 1 April 2024.

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/4/2024-04-06) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1218ZCF of CTA 2009 (amount of relief for museum or gallery exhibition).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/5/2024-04-06)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (3) Sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/4/2024-09-03) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1218ZCF of CTA 2009 (amount of relief for museum or gallery exhibition).

- (4) The references in subsections (2) and (3) of that section (as amended by paragraph [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/5/2024-09-03)) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as—

- (a) has been incurred before 1 April 2024 and is European expenditure, or

- (b) has been incurred on or after that date and is UK expenditure.

- (5) But if the exhibition in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/4/2024-04-06) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that exhibition as if “2025” were substituted for “2024”.

- (5) But if the exhibition in relation to which sub-paragraph [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/4/2024-09-03) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that exhibition as if “2025” were substituted for “2024”.

- (6) In this paragraph—

- “*exhibition*”, “*production company*” and “*core expenditure*” have the same meanings as in Part 15E of CTA 2009;

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06);

- “*European expenditure*” has the same meanings as in that Part before the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-04-06).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/5/2024-04-06), an exhibition “enters production” when core expenditure is first incurred on it.

- “*UK expenditure*” has the same meaning as in that Part after the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-09-03);

- “*European expenditure*” has the same meanings as in that Part before the amendments made by paragraph [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/4/2024-09-03).

- (7) For the purposes of sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/5/paragraph/11/5/2024-09-03), an exhibition “enters production” when core expenditure is first incurred on it.

## Schedule 6

@@ -4399,7 +4399,7 @@

##### 1

CTA 2010 is amended in accordance with [paragraphs 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/2/2024-04-06) to [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/10/2024-04-06).

CTA 2010 is amended in accordance with [paragraphs 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/2/2024-09-03) to [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/10/2024-09-03).

#### CoACS to be institutional investors

@@ -4435,7 +4435,7 @@

- (4) In subsection (5), for “subsection (4)(a)” substitute “determining whether the non-close condition is met”.

- (5) After subsection (5A) (as inserted by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06)) insert—

- (5) After subsection (5A) (as inserted by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-09-03)) insert—

> (5B) For the purposes of subsection (4C)(a)(ii)—

> (a) a person is a “direct participator” if the person is a participator for the purposes of Part 10 of CTA 2010 (see section 454), and

@@ -4444,7 +4444,7 @@

> (a) reference to having a share or interest in the capital or income of a company through a body corporate is to be read in accordance with sub-paragraphs (9) and (10) of paragraph 46 of Schedule 5AAA to TCGA 1992 (meaning of direct or indirect participator), and

> (b) a person is regarded for the purposes of those sub-paragraphs, and for the purposes of subsection [(5B)](#p12512)[(b)](#p12519) of this section, as having a share or interest in the capital or income of a company if the person would be a participator in the company as a result of section 454(2) of CTA 2010.

- (6) Section 528 has effect, and is to be deemed always to have had effect, with the amendments made by [this paragraph](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-04-06).

#### Certain institutional investors required to meet GDO or non-close condition

@@ -4472,13 +4472,13 @@

- (d) in paragraph (e), after “who” insert “meets the non-close condition and who”.

- (3) After subsection (4C) (as inserted by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-04-06)) insert—

- (3) After subsection (4C) (as inserted by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-09-03)) insert—

> (4D) But for the purposes of applying the non-close condition for the purpose of any of paragraphs (a) to (c) of subsection (4A), subsection (4C) has effect as if—

> (a) paragraph (a)(ii) were omitted, and

> (b) in paragraph (b), in the words before sub-paragraph (i), “or (ii)” were omitted.

- (4) In subsection (5) (as amended by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-04-06))—

- (4) In subsection (5) (as amended by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-09-03))—

- (a) the words from “a company” to the end become paragraph (a),

@@ -4491,7 +4491,7 @@

> (5A) But subsection (5)(a) does not apply for the purpose of determining whether a person acting in the course of a long term insurance business meets the non-close condition.

- (6) After subsection (5C) (as inserted by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-04-06)) insert—

- (6) After subsection (5C) (as inserted by [paragraph 3](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/3/2024-09-03)) insert—

> (5D) In determining whether a company is a close company for the purposes of the non-close condition—

> (a) the rights and powers of a person (“*A*”) are not to be attributed to another person (“*P*”) merely because A is a partner of P for the purposes of any attribution under section 451(4) (rights of a person's associates to be attributed to the person etc in determining “control”), and

@@ -4516,37 +4516,37 @@

- (9) In consequence of the other amendments made by [this paragraph](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06), in Schedule 5AAA to TCGA 1992, in paragraph 46(3)(a), for “section 528(4A)(a), (b), (c), (i) or (j)” substitute “section 528(4A)(i) or (j)“.

- (9) In consequence of the other amendments made by [this paragraph](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-09-03), in Schedule 5AAA to TCGA 1992, in paragraph 46(3)(a), for “section 528(4A)(a), (b), (c), (i) or (j)” substitute “section 528(4A)(i) or (j)“.

#### Paragraph 4: transitional provision

##### 5

- (1) [Sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/2/2024-04-06) applies where—

- (1) [Sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/2/2024-09-03) applies where—

- (a) immediately before the day on which this Act is passed, a company that is a company UK REIT or the principal member of a group UK REIT, met the conditions in section 528 of CTA 2010, and

- (b) the company ceases to meet one or more of those conditions on that day as a result of one or more persons ceasing to be regarded as institutional investors as a result of the amendments made by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06).

- (2) Part 12 of CTA 2010 has effect in relation to such a person for the purposes of determining whether the company meets those conditions as if the amendments made by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06) had not been made for so long as the person’s interest in the company as a proportion of all interests in the company—

- (2) Part 12 of CTA 2010 has effect in relation to such a person for the purposes of determining whether the company meets those conditions as if the amendments made by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-09-03) had not been made for so long as the person’s interest in the company as a proportion of all interests in the company—

- (a) does not increase as a result of the acquisition by the person of further interests in the company, and

- (b) continuously remains relevant to the question of whether those conditions are met.

- (3) [Sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/4/2024-04-06) applies where—

- (3) [Sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/4/2024-09-03) applies where—

- (a) immediately before the day on which this Act is passed, a collective investment vehicle, or a company that is not a collective investment vehicle, (“the reliant entity”) relied on its having a qualifying investor as a direct or indirect participator for the purpose of any provision of Schedule 5AAA to TCGA 1992 (“a qualifying purpose”), and

- (b) the qualifying investor (“the former qualifying investor”) ceased to be a qualifying investor a result of the amendments made by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06).

- (4) That Schedule has effect in relation to the former qualifying investor for a qualifying purpose as if the amendments made by [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/4/2024-04-06) had not been made for so long as—

- (a) the investor’s interest in the reliant entity as a proportion of all interests in the entity does not increase as a result of the acquisition by the investor of further interests in the reliant entity, and

- (b) the investor being a direct or indirect participator in the reliant entity continuously remains relevant for at least one qualifying purpose.

- (5) [Sub-paragraph (6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/6/2024-04-06) applies when determining whether a collective investment scheme constituted before the day on which this Act is passed meets the genuine diversity of ownership condition for the purposes of any of paragraphs (a) to (c) of section 528(4A).

- (5) [Sub-paragraph (6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/5/6/2024-09-03) applies when determining whether a collective investment scheme constituted before the day on which this Act is passed meets the genuine diversity of ownership condition for the purposes of any of paragraphs (a) to (c) of section 528(4A).

- (6) Regulation 75(2) of the Offshore Funds (Tax) Regulations 2009 (including as it applies for the purposes of regulation 75(5) of those Regulations) has effect, for those purposes, as if it referred to a statement prepared by the manager of the scheme (instead of the documents referred to in that paragraph) which—

@@ -4582,13 +4582,13 @@

> (a) property rental business of UK members of the group, and

> (b) UK property rental business of other members.

- (4) Section 544 has effect, and is to be deemed always to have had effect, with the amendments made by [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/2/2024-04-06) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/3/2024-04-06).

- (4) Section 544 has effect, and is to be deemed always to have had effect, with the amendments made by [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/2/2024-09-03) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/3/2024-09-03).

- (5) After subsection (4) insert—

> (4A) But property financing costs do not (for the purposes of section 543) include any expense for which a deduction would not be allowed in calculating profits in accordance with section 599, other than an expense which is disallowed only as a result of the application of Part 10 of TIOPA 2010 (corporate interest restriction).

- (6) The amendment made by [sub-paragraph (5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/5/2024-04-06) has effect for accounting periods ending on or after 1 April 2023.

- (6) The amendment made by [sub-paragraph (5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/7/paragraph/7/5/2024-09-03) has effect for accounting periods ending on or after 1 April 2023.

#### Single property rule

@@ -5066,7 +5066,7 @@

##### 25

Schedule 29 (authorised lump sums - supplementary) is amended in accordance with paragraphs [26](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/26/2024-04-06) to [37](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/37/2024-04-06).

Schedule 29 (authorised lump sums - supplementary) is amended in accordance with paragraphs [26](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/26/2024-09-03) to [37](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/37/2024-09-03).

##### 26

@@ -5151,7 +5151,7 @@

> (a) the defined benefits arrangement mentioned in paragraph [(a)](#p14177) or [(b)](#p14181) of sub-paragraph [(3)](#p14173), or

> (b) any other defined benefits arrangement relating to the member (under the pension scheme or any other registered pension scheme) in the case of which any of the sums or assets held for the purposes of, or representing accrued rights under, the arrangement directly or indirectly represent sums or assets previously held for the purposes of, or representing accrued rights under, the defined benefits arrangement so mentioned.

- (9) After paragraph 3B (as inserted by sub-paragraph [(8)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/26/8/2024-04-06)) insert—

- (9) After paragraph 3B (as inserted by sub-paragraph [(8)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/26/8/2024-09-03)) insert—

> (3C)

> (1) For the purposes of this Part a lump sum is a pension commencement excess lump sum if—

@@ -5507,7 +5507,7 @@

> (5) For this purpose “the previously-used amount” is the aggregate of the non-taxable amounts in relation to each relevant benefit crystallisation event that has occurred in relation to the individual before the current event.

> (6) In subsection [(5)](#p15376) “*non-taxable amount*”, in relation to a relevant benefit crystallisation event, means so much (if any) of the relevant lump sum to which the event relates as is exempt from the charge to income tax by virtue of any provision of this Chapter.

> (7) A reference in this section to a relevant benefit crystallisation event is to a relevant benefit crystallisation event occurring on or after 6 April 2024.

> (8) For transitional provision under which the amount of an individual’s lump sum allowance available on the occurrence of a relevant benefit crystallisation event may be reduced as a result of events occurring before 6 April 2024, see [paragraph 125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-04-06) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06) to FA 2024.

> (8) For transitional provision under which the amount of an individual’s lump sum allowance available on the occurrence of a relevant benefit crystallisation event may be reduced as a result of events occurring before 6 April 2024, see [paragraph 125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-09-03) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-09-03) to FA 2024.

> (637R) An individual’s “lump sum and death benefit allowance” is £1,073,100.

> (637S)

> (1) This section is about the availability of an individual’s lump sum and death benefit allowance on the occurrence of a relevant benefit crystallisation event (“the current event”).

@@ -5534,7 +5534,7 @@

> (b) immediately after any pension commencement lump sum to which the individual becomes entitled immediately before death by virtue of section 166(2) of FA 2004 (lump sum rule), and

> (c) in such order as may be decided by the individual’s personal representatives.

> (9) A reference in this section to a relevant benefit crystallisation event is to a relevant benefit crystallisation event occurring on or after 6 April 2024.

> (10) For transitional provision under which the amount of an individual’s lump sum and death benefit allowance available on the occurrence of a relevant benefit crystallisation event may be reduced as a result of events occurring before 6 April 2024, see [paragraph 126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-04-06) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06) to FA 2024.

> (10) For transitional provision under which the amount of an individual’s lump sum and death benefit allowance available on the occurrence of a relevant benefit crystallisation event may be reduced as a result of events occurring before 6 April 2024, see [paragraph 126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-09-03) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-09-03) to FA 2024.

> (11) For further transitional provision that may affect the operation of this section, see paragraph 20 of Schedule 36 to FA 2004 (pensions in payment before commencement of Part 4 of FA 2004).

#### Amendments of the Registered Pension Schemes (Authorised Payments) Regulations 2009

@@ -6426,7 +6426,7 @@

##### 85

After paragraph 29 (substituted by [paragraph 84](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/84/2024-04-06)) insert—

After paragraph 29 (substituted by [paragraph 84](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/84/2024-09-03)) insert—

> (29A) [Chapter 15A](#p14562) of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) has effect in relation to the individual as if the amount specified in [section 637P](#p15329) of ITEPA 2003 (individual’s lump sum allowance) were an amount equal to the maximum amount of a pension commencement lump sum that could have been paid to the member on 5th April 2023.

@@ -7246,7 +7246,7 @@

##### 124

The amendments made by section [14](https://www.legislation.gov.uk/ukpga/2024/3/section/14/2024-04-06) and this Schedule have effect for the tax year 2024-25 and subsequent tax years.

The amendments made by section [14](https://www.legislation.gov.uk/ukpga/2024/3/section/14/2024-09-03) and this Schedule have effect for the tax year 2024-25 and subsequent tax years.

#### Availability of individual’s lump sum allowance

@@ -7294,7 +7294,7 @@

or, if that produces a negative result, nil.

- (6) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-04-06).

- (6) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-09-03).

#### Availability of individual’s lump sum and death benefit allowance

@@ -7340,7 +7340,7 @@

- (b) 25% in any other case.

- (5) But sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2/2024-04-06) to [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/4/2024-04-06) do not apply if, on the occurrence of the relevant benefit crystallisation event, a transitional tax-free amount certificate is in force in relation to the individual.

- (5) But sub-paragraphs [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2/2024-09-03) to [(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/4/2024-09-03) do not apply if, on the occurrence of the relevant benefit crystallisation event, a transitional tax-free amount certificate is in force in relation to the individual.

- (6) In such a case, the amount of the individual’s lump sum and death benefit allowance that is available on the occurrence of the relevant benefit crystallisation event is—

@@ -7350,7 +7350,7 @@

or, if that produces a negative result, nil.

- (7) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-04-06).

- (7) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-09-03).

#### Transitional tax-free amount certificates

@@ -7382,7 +7382,7 @@

- (b) notifying the applicant that the application is refused.

- (4) A certificate must (in addition to certifying the matter mentioned in [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/1/2024-04-06)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/1/b/2024-04-06)) contain the following information—

- (4) A certificate must (in addition to certifying the matter mentioned in [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/1/2024-09-03)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/1/b/2024-09-03)) contain the following information—

- (a) the individual’s name, address and national insurance number,

@@ -7394,25 +7394,25 @@

- (5) A certificate may be in such form as the scheme administrator may determine and may, in particular, be incorporated into any other document that is given to the applicant by the scheme.

- (6) If at any time it appears to the scheme administrator of a registered pension scheme that the amount specified on a certificate under [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/2024-04-06)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/c/2024-04-06) or [(d)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/d/2024-04-06) does not accurately reflect the individual’s lump sum transitional tax-free amount or (as the case may be) lump sum and death benefit transitional tax-free amount, they must cancel the certificate by giving notice of the cancellation to the applicant or, if the applicant is deceased, the applicant’s personal representatives.

- (6) If at any time it appears to the scheme administrator of a registered pension scheme that the amount specified on a certificate under [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/2024-09-03)[(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/c/2024-09-03) or [(d)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/4/d/2024-09-03) does not accurately reflect the individual’s lump sum transitional tax-free amount or (as the case may be) lump sum and death benefit transitional tax-free amount, they must cancel the certificate by giving notice of the cancellation to the applicant or, if the applicant is deceased, the applicant’s personal representatives.

- (7) A certificate—

- (a) comes into force when it is issued, and

- (b) ceases to be in force on the giving of a notice under sub-paragraph [(6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/6/2024-04-06).

- (b) ceases to be in force on the giving of a notice under sub-paragraph [(6)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/6/2024-09-03).

- (8) The Commissioners for His Majesty’s Revenue and Customs may by regulations—

- (a) amend sub-paragraph [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/3/2024-04-06) by substituting a different period for that for the time being specified there, or

- (a) amend sub-paragraph [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/3/2024-09-03) by substituting a different period for that for the time being specified there, or

- (b) make further provision about transitional tax-free certificates.

- (9) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-04-06).

- (9) For provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-09-03).

- (10) In the second column of the Table in section 98 of TMA 1970 (penalty for failure to give certificates etc), at the appropriate place insert—

| Paragraph [127](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/2024-04-06) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-04-06) to the Finance Act 2024 |

| Paragraph [127](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/2024-09-03) of [Schedule 9](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/2024-09-03) to the Finance Act 2024 |

| --- |

@@ -7423,31 +7423,31 @@

- (1) A reference in the Provision of Information Regulations to a relevant benefit crystallisation event is, in relation to times before 6 April 2024, a reference to a benefit crystallisation event within the meaning of Part 4 of FA 2004.

- (2) Sub-paragraph [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/3/2024-04-06) applies where—

- (2) Sub-paragraph [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/3/2024-09-03) applies where—

- (a) one or more benefit crystallisation events within the meaning of Part 4 of FA 2004 occurred in relation to a member of a registered pension scheme before 6 April 2024, and

- (b) it is necessary to determine, for the purposes of any provision of the Provision of Information Regulations as that provision has effect for the tax year 2024-25 or a subsequent tax year, the amount of the member’s lump sum allowance that has been expended by the events mentioned in paragraph [(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2/a/2024-04-06).

- (3) For those purposes, the amount of the member’s lump sum allowance that has been expended by the events mentioned in [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2/2024-04-06)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2/a/2024-04-06) is—

- (3) For those purposes, the amount of the member’s lump sum allowance that has been expended by the events mentioned in [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2/2024-09-03)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2/a/2024-09-03) is—

- (a) if a transitional tax-free amount certificate is in force in relation to the member, so much of the member’s lump sum transitional tax-free amount as is referable to those events;

- (b) otherwise, an amount equal to 25% of so much of the member’s lifetime allowance previously-used amount as is referable to those events.

- (4) Sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/2024-04-06) applies where—

- (4) Sub-paragraph [(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/2024-09-03) applies where—

- (a) one or more benefit crystallisation events within the meaning of Part 4 of FA 2004 occurred in relation to a member of a registered pension scheme before 6 April 2024, and

- (b) it is necessary to determine, for the purposes of any provision of the Provision of Information Regulations as it has effect for the tax year 2024-25 or a later tax year, the amount of the member’s lump sum and death benefit allowance that has been expended by the events mentioned in paragraph [(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/4/a/2024-04-06).

- (5) For those purposes, the amount of the member’s lump sum and death benefit allowance that has been expended by the events mentioned in [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/4/2024-04-06)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/4/a/2024-04-06) is—

- (5) For those purposes, the amount of the member’s lump sum and death benefit allowance that has been expended by the events mentioned in [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/4/2024-09-03)[(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/4/a/2024-09-03) is—

- (a) if a transitional tax-free amount certificate is in force in relation to the member, so much of the member’s lump sum and death benefit transitional tax-free amount as is referable to those events;

- (b) otherwise, an amount equal to the appropriate percentage of so much of the member’s lifetime allowance previously-used amount as is referable to those events.

- (6) In [sub-paragraph (5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/2024-04-06)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/b/2024-04-06) “*the appropriate percentage*” means—

- (6) In [sub-paragraph (5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/2024-09-03)[(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/5/b/2024-09-03) “*the appropriate percentage*” means—

- (a) 100% in a case in which—

@@ -7461,7 +7461,7 @@

- (7) In this paragraph “*the Provision of Information Regulations*” means the Registered Pension Schemes (Provision of Information) Regulations ([S.I. 2006/567](https://www.legislation.gov.uk/uksi/2006/567)).

- (8) For further provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-04-06).

- (8) For further provision about the meaning of expressions used in this paragraph, see [paragraph 129](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2024-09-03).

#### Paragraphs 125 to 128: interpretation

@@ -7485,7 +7485,7 @@

- (c) where a benefit crystallisation event within sub-paragraph (2)(a) of paragraph 20 of Schedule 36 to FA 2004 (pre-commencement pensions) was treated as having occurred before 6 April 2024 in relation to the individual, an amount equal to 25% of the amount treated as crystallised by that event under sub-paragraph (2)(b) of that paragraph.

- (3) For the purposes of [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/2024-04-06)—

- (3) For the purposes of [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/2024-09-03)—

- (a) a lump sum is “relevant” if the individual becoming entitled to it constituted a benefit crystallisation event within the meaning of Part 4 of FA 2004;

@@ -7499,19 +7499,19 @@

that is comprised, or any part of which is comprised, in the individual’s lump sum and death benefit transitional tax-free amount.

- (5) In paragraphs [125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-04-06) to [128](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2024-04-06) and this paragraph—

- “*complete evidence*” has the meaning given by [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/4/2024-04-06);

- (5) In paragraphs [125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-09-03) to [128](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2024-09-03) and this paragraph—

- “*complete evidence*” has the meaning given by [sub-paragraph (4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/4/2024-09-03);

- “*lifetime allowance*” has the same meaning as in Part 4 of FA 2004;

- “*lifetime allowance previously-used amount*” means the amount that would have been the previously-used amount for the purposes of section 219 of FA 2004 (availability of individual’s lifetime allowance) if a benefit crystallisation event (within the meaning of that section) had occurred immediately before 6 April 2024;

- “*lump sum and death benefit transitional tax-free amount*” has the meaning given by [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/2024-04-06) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/3/2024-04-06);

- “*lump sum and death benefit transitional tax-free amount*” has the meaning given by [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/2024-09-03) and [(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/3/2024-09-03);

- “*lump sum death benefit*” has the same meaning as in Part 4 of FA 2004;

- “*lump sum transitional tax-free amount*” has the meaning given by [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/1/2024-04-06);

- “*lump sum transitional tax-free amount*” has the meaning given by [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/1/2024-09-03);

- “*pension commencement lump sum*” has the same meaning as in Part 4 of FA 2004;

@@ -7525,11 +7525,11 @@

- “*standard lifetime allowance*”, in relation to an individual, has the same meaning as in Part 4 of FA 2004 as that Part has effect in relation to the individual;

- “*transitional tax-free amount certificate*” means a certificate under [paragraph 127](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/2024-04-06);

- “*transitional tax-free amount certificate*” means a certificate under [paragraph 127](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/127/2024-09-03);

- “*uncrystallised funds pension lump sum*” has the same meaning as in Part 4 of FA 2004.

- (6) A reference in any of paragraphs [125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-04-06) to [128](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2024-04-06) or this paragraph to a provision of FA 2004 is to that provision as it had effect immediately before 6 April 2024.

- (6) A reference in any of paragraphs [125](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/125/2024-09-03) to [128](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/128/2024-09-03) or this paragraph to a provision of FA 2004 is to that provision as it had effect immediately before 6 April 2024.

#### Statements for certain members who would not otherwise receive one in the tax year 2024-25

@@ -7537,7 +7537,7 @@

- (1) The scheme administrator of a registered pension scheme must provide a statement to each relevant person before the end of the tax year 2024-25.

- (2) In [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/130/1/2024-04-06) “*relevant person*” means—

- (2) In [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/130/1/2024-09-03) “*relevant person*” means—

- (a) any member of the scheme—

@@ -7545,7 +7545,7 @@

- (ii) who on that date does not have an actual (as opposed to prospective) entitlement to be paid a pension, or

- (b) the personal representatives of a member within [paragraph (a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/130/2/a/2024-04-06) who has died.

- (b) the personal representatives of a member within [paragraph (a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/130/2/a/2024-09-03) who has died.

- (3) The statement must contain the information in regulation 14(3) of the Provision of Information Regulations (percentage of standard lifetime allowance expended by benefit crystallisation events) in respect of benefit crystallisation events occurring before 6 April 2024.

@@ -7581,13 +7581,13 @@

##### 133

- (1) The Treasury may make transitional, transitory or saving provision (in addition to that contained in paragraphs [126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-04-06) to [132](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/132/2024-04-06)) in connection with the coming into force of any amendment made by section [14](https://www.legislation.gov.uk/ukpga/2024/3/section/14/2024-04-06) or this Schedule.

- (1) The Treasury may make transitional, transitory or saving provision (in addition to that contained in paragraphs [126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-09-03) to [132](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/132/2024-09-03)) in connection with the coming into force of any amendment made by section [14](https://www.legislation.gov.uk/ukpga/2024/3/section/14/2024-09-03) or this Schedule.

- (2) Regulations under this paragraph may—

- (a) insert provision into this Part of this Schedule;

- (b) amend any provision of paragraphs [126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-04-06) to [132](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/132/2024-04-06);

- (b) amend any provision of paragraphs [126](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/126/2024-09-03) to [132](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/132/2024-09-03);

- (c) make different provision for different purposes.

@@ -7595,7 +7595,7 @@

##### 134

- (1) The Treasury may by regulations make further provision (in addition to that contained in Parts [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/1/2024-04-06) to [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/5/2024-04-06) of this Schedule) in consequence of, or otherwise in connection with, the provision made by sections 18, 19 and 23 of F(No.2)A 2023.

- (1) The Treasury may by regulations make further provision (in addition to that contained in Parts [1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/1/2024-09-03) to [5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/part/5/2024-09-03) of this Schedule) in consequence of, or otherwise in connection with, the provision made by sections 18, 19 and 23 of F(No.2)A 2023.

- (2) Regulations under this paragraph may—

@@ -7611,7 +7611,7 @@

- (4) No regulations under this paragraph may be made after 5 April 2026.

- (5) In [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/134/2/2024-04-06) “*amend*” includes repeal or revoke.

- (5) In [sub-paragraph (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/134/2/2024-09-03) “*amend*” includes repeal or revoke.

## Schedule 10

@@ -7719,7 +7719,7 @@

##### 11

Before section 25C (inserted by [paragraph 5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/5/2024-04-06) of this Schedule) insert —

Before section 25C (inserted by [paragraph 5](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/5/2024-09-03) of this Schedule) insert —

> (25B)

> (1) A trade is an excluded trade in relation to a tax year if the trade meets any of conditions A to G.

@@ -7764,7 +7764,7 @@

##### 16

Omit section 31C (excluded persons) (but see [paragraph 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/11/2024-04-06), which inserts substantially similar provision).

Omit section 31C (excluded persons) (but see [paragraph 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/11/2024-09-03), which inserts substantially similar provision).

##### 17

@@ -8020,7 +8020,7 @@

> (5A) Subsection (11)(za) of section 1A (capital allowances and charges: cash basis) applies for the purposes of this section as it applies for the purposes of that section.

#### ITA 2007

#### Application of Pillar Two rules to members of a group

##### 45

@@ -8084,7 +8084,7 @@

##### 50

Paragraphs [48](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/48/2024-04-06) and [49](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/49/2024-04-06) apply to professions and vocations as they apply to trades.

Paragraphs [48](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/48/2024-09-03) and [49](https://www.legislation.gov.uk/ukpga/2024/3/schedule/10/paragraph/49/2024-09-03) apply to professions and vocations as they apply to trades.

## Schedule 11

@@ -8457,7 +8457,7 @@

- (1) This paragraph applies for the purposes of section 95A of FA 1986 (depositary receipts: exception for replacement securities) where the securities mentioned in subsection (3)(a) of that section were issued before 1 January 2024.

- (2) The amendments made by [paragraphs 7](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/7/2024-04-06) and [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/10/2024-04-06) are to be disregarded.

- (2) The amendments made by [paragraphs 7](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/7/2024-09-03) and [10](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/10/2024-09-03) are to be disregarded.

#### Transitional provision: clearance services: exception from SDRT for replacement securities

@@ -8465,7 +8465,7 @@

- (1) This paragraph applies for the purposes of section 97ZA of FA 1986 (clearance services: exception for replacement securities) where the securities mentioned in subsection (3)(a) of that section were issued before 1 January 2024.

- (2) The amendments made by [paragraphs 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/11/2024-04-06) and [13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/13/2024-04-06) are to be disregarded.

- (2) The amendments made by [paragraphs 11](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/11/2024-09-03) and [13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/13/2024-09-03) are to be disregarded.

#### Transitional provision: bearer instruments

@@ -8477,9 +8477,9 @@

- (b) outside the United Kingdom by or on behalf of a UK company.

- (2) The amendment made by [paragraph 19](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/19/2024-04-06)[(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/19/3/2024-04-06) is to be disregarded.

- (3) In [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/28/1/2024-04-06) “*bearer instrument*” and “*UK company*” have the same meaning as in Schedule 15 to FA 1999 (see paragraphs 3 and 11 of that Schedule).

- (2) The amendment made by [paragraph 19](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/19/2024-09-03)[(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/19/3/2024-09-03) is to be disregarded.

- (3) In [sub-paragraph (1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/28/1/2024-09-03) “*bearer instrument*” and “*UK company*” have the same meaning as in Schedule 15 to FA 1999 (see paragraphs 3 and 11 of that Schedule).

- (4) Sub-paragraph (5) applies in relation to UK bearer instruments within the meaning of section 99(1A) of FA 1986 issued before 1 January 2024.

@@ -8491,7 +8491,7 @@

- (1) This paragraph applies in relation to securities constituted by or transferable by means of an instrument issued before 1 January 2024.

- (2) The amendments made by [paragraph 23](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/23/2024-04-06) are to be disregarded.

- (2) The amendments made by [paragraph 23](https://www.legislation.gov.uk/ukpga/2024/3/schedule/11/paragraph/23/2024-09-03) are to be disregarded.

## Schedule 12

@@ -8499,7 +8499,7 @@

##### 1

- (1) F(No.2)A 2023 is amended in accordance with [Parts 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/part/2/2024-04-06) to [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/part/4/2024-04-06) of [this Schedule](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/2024-04-06).

- (1) F(No.2)A 2023 is amended in accordance with [Parts 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/part/2/2024-09-03) to [4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/part/4/2024-09-03) of [this Schedule](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/2024-09-03).

- (2) The amendments made by those Parts have effect for accounting periods beginning on or after 31 December 2023.

@@ -8961,7 +8961,7 @@

##### 14

- (1) Section 168 (underlying profits of transparent and reverse hybrid entities) is amended in accordance with [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/14/2/2024-04-06) to [(8)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/14/8/2024-04-06).

- (1) Section 168 (underlying profits of transparent and reverse hybrid entities) is amended in accordance with [sub-paragraphs (2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/14/2/2024-09-03) to [(8)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/14/8/2024-09-03).

- (2) In subsection (2), in paragraph (b), after territory insert “as a result of being tax resident in that territory”.

@@ -9008,7 +9008,7 @@

##### 16

- (1) After section [176C](#p24068) (as inserted by [paragraph 8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/8/2024-04-06)), insert—

- (1) After section [176C](#p24068) (as inserted by [paragraph 8](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/8/2024-09-03)), insert—

> (176D)

> (1) Where—

@@ -9754,7 +9754,7 @@

> (1) Schedule 16 contains transitional provision and provision about a general transitional safe harbour.

> (2) Schedule 16A contains provision about other safe harbours.

- (4) In Schedule 15 (elections), in paragraph 2(1), after paragraph (k) (as inserted by [paragraph 40](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/40/2024-04-06)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/40/2/2024-04-06) of this Schedule) insert—

- (4) In Schedule 15 (elections), in paragraph 2(1), after paragraph (k) (as inserted by [paragraph 40](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/40/2024-09-03)[(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/40/2/2024-09-03) of this Schedule) insert—

> (l) paragraph 1 of Schedule 16A.

@@ -9811,7 +9811,7 @@

- (a) in subsection (2), after “subsection (1)” insert “or [(3B)](#p26774)[(b)](#p26781)”, and

- (b) after subsection (3A) (as inserted by [paragraph 42](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/42/2024-04-06)) insert—

- (b) after subsection (3A) (as inserted by [paragraph 42](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/42/2024-09-03)) insert—

> (3B) An investment entity is a DTT excluded entity if—

> (a) it is not a member of a group, or

@@ -9824,7 +9824,7 @@

> (b) applying Condition C in section 266 in relation to other members of the group (revenue threshold for group), and

> (c) subsections (8)(e) [(9)](#p26845), [(10)](#p26857) and [(11)](#p26871) of section 272.

- (2) In consequence of the amendments made by sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/43/1/2024-04-06), in section 266(1) (qualifying entities) omit “or an investment entity”.

- (2) In consequence of the amendments made by sub-paragraph [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/43/1/2024-09-03), in section 266(1) (qualifying entities) omit “or an investment entity”.

- (3) In section 272 (determining top-up amounts of entity that is a member of a group)—

@@ -9917,7 +9917,7 @@

##### 46

After section 273B (as inserted by [paragraph 45](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/45/2024-04-06)) insert—

After section 273B (as inserted by [paragraph 45](https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/45/2024-09-03)) insert—

> (273C)

> (1) This section applies to a dividend or other distribution made by a protected cell company that is received or accrued by—

@@ -10511,7 +10511,7 @@

- (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](#p27889) or [8ZG](#p27954), see [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/4/2024-04-06) of [Schedule 13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/2024-04-06) to the Finance Act 2024.

> (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](#p27889) or [8ZG](#p27954), see [paragraph 4](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/4/2024-09-03) of [Schedule 13](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/2024-09-03) to the Finance Act 2024.

##### 3

@@ -10521,13 +10521,13 @@

##### 4

- (1) The amendments made by [paragraph 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/1/2024-04-06) extend to England and Wales, Scotland and Northern Ireland.

- (2) The amendments made by [paragraph 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/2/2024-04-06) extend to—

- (1) The amendments made by [paragraph 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/1/2024-09-03) extend to England and Wales, Scotland and Northern Ireland.

- (2) The amendments made by [paragraph 2](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/2/2024-09-03) 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](#p27889) or [8ZG](#p27954) of CDDA 1986 (inserted by [paragraph 1](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/1/2024-04-06)).

- (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](#p27889) or [8ZG](#p27954).

@@ -10539,7 +10539,7 @@

- (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))](https://www.legislation.gov.uk/nisi/2002/3150) 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)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/5/1/2024-04-06) and [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/5/2/2024-04-06) apply only if, and to the extent that, there are not otherwise procedural rules for HMRC disqualification applications.

- (3) Sub-paragraphs [(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/5/1/2024-09-03) and [(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/13/paragraph/5/2/2024-09-03) apply only if, and to the extent that, there are not otherwise procedural rules for HMRC disqualification applications.

- (4) In this paragraph—

@@ -10993,6 +10993,620 @@

#### 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

[^key-697b2e40cf259745f6b2d36fb443dfb0]: [Sch. 9 para. 127A](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(12)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/12)

[^key-19d5f6ca5c8442ff1eaf413b09f4534c]: [Sch. 9 para. 130A](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(21)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/21)

[^key-105fdf2a72adf4a959087012c0bc4063]: [Sch. 9 para. 132A](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(24)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/24)

[^key-52455820dae27d36760a530b37f7b4d9]: [Sch. 9 para. 125(2)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(4)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/4)

[^key-c9d17b62474f3a6ab5bce8742ec9297d]: [Sch. 9 para. 125(1)(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(3)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/3/b)

[^key-034e486d3e79b7b2aa3da78849481c90]: [Sch. 9 para. 125(3A)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(6)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/6)

[^key-28031f4c4af84564f64ce0ab7c7fa547]: Word in [Sch. 9 para. 125(1)(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(3)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/3/a)

[^key-9c9742916bfcf9f855442275bb923e15]: Word in [Sch. 9 para. 125(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(5)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/5)

[^key-2540fae79caa218798254f56518c31d0]: Words in [Sch. 9 para. 125(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(7)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/7)

[^key-4eafd66fe9b44b4b71e7919ea7a51fff]: [Sch. 9 para. 126(3A)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(10)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/10)

[^key-c60aa3a1ae39dab9759eb23900ced6b6]: Word in [Sch. 9 para. 126(1)(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(9)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/9/a)

[^key-b3e5d2938c122f2370d980dfa0f714d4]: Word in [Sch. 9 para. 126(1)(b)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(9)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/9/b)

[^key-4003b912783025bf3d60a7e9e30f269d]: [Sch. 9 para. 126(1)(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(9)(c)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/9/c)

[^key-2c41446258f2dde7754382d01c978d4a]: Words in [Sch. 9 para. 126(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(11)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/11)

[^key-35f4812a2a801c481b26547bb801134e]: [Sch. 9 para. 128(6)(a)(zi)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(13)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/13)

[^key-6b6c2ec99ecd6a31e000e90605605cd6]: Word in [Sch. 9 para. 129(1)(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(15)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/15/a)

[^key-a8fed48d73ed7f298e9465fd41b136b7]: [Sch. 9 para. 129(1)(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/1/c)[(d)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/1/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(15)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/15/b)

[^key-35f7940393c5976b25e1b8ba737c6cd7]: Word in [Sch. 9 para. 129(2)(a)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(16)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/16/a)

[^key-c6f32a71a1334e0141ddf4a1ea78e6a1]: [Sch. 9 para. 129(2)(c)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/129/2/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(16)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/16/b)

[^key-858050dcd5059212efb07c4edfc8b99e]: Words in [Sch. 9 para. 129(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(17)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/17/a)

[^key-dbd272522a0228dd684adb13634960bf]: Word in [Sch. 9 para. 129(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(17)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/17/b)

[^key-f651fa4e77afefffe7df38b94cd26197]: [Sch. 9 para. 130(3)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(19)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/19)

[^key-7b4f3db4ded3d9b685394a399f5cc6e1]: Words in [Sch. 9 para. 130(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(20)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/20)

[^key-a8411c8b8efed4fb7ac4cb385fcfee9c]: [Sch. 9 para. 132](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(22)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/22)

[^key-36df30aeea8bbbd4929e7286d375357d]: 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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(23)(a)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/23/a)

[^key-9d7a8e55d3e8fb37538a9c721f0510d6]: [Sch. 9 para. 132(2)-(5)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/132/2) 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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(23)(c)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/23/c)

[^key-1a56b1c592ae35df82127d29d4f1ea58]: Words in [Sch. 9 para. 132(1)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/9/paragraph/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)](https://www.legislation.gov.uk/uksi/2024/356), [reg. 4(23)(b)](https://www.legislation.gov.uk/uksi/2024/356/regulation/4/23/b)

[^key-b7bccb07a6f6f27635c74f6d12fed1c4]: [S. 11](https://www.legislation.gov.uk/ukpga/2024/3/section/11) in force at 3.9.2024 by [S.I. 2024/897](https://www.legislation.gov.uk/uksi/2024/897), [reg. 2](https://www.legislation.gov.uk/uksi/2024/897/regulation/2)

[^M_I_6e69f8ef-530d-4212-9bdb-054a28d4dd5e]: Sch. 1 para. 6: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_P_ac94cca8-fef9-421a-ba46-2426ae07bc5a]: Sch 1 para. 16: 1.4.2024 appointed for the purposes of Sch. 1 para. 16 by [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_41ef3c45-5dad-4b90-d100-fd6c1bdae224]: Sch. 1 para. 10: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by[2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_77eab75f-adb8-4332-e389-f0339c86ef86]: Sch. 1 para. 15: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_66e64acd-f6b0-4812-a933-6a14bb3e1d57]: Sch. 1 para. 13: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_51ea6980-35d3-4559-9ea0-e6451591df54]: Sch. 1 para. 11: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_83c2034d-bac2-45f0-c53b-8521d22ee163]: Sch. 1 para. 5: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_e6f3442d-51bd-41b5-8048-daebd66328ef]: Sch. 1 para. 14: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_e3590b69-c216-4e48-c709-36d6fd85e00b]: Sch. 1 para. 2: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_43b8c7ab-2ddc-419e-fd52-d0d4be3dda3a]: Sch. 1 para. 8: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_03ae88ae-34c3-4d16-c9cb-5f051862550e]: [Sch. 1 para. 9(1)-(15)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/9/1): amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_e4a5ed11-eb8a-458b-e384-b0af0808dbc3]: Sch. 1 para. 12: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_7321294b-e0e0-4a6a-c809-2bdf60c88b10]: Sch. 1 para. 3: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_e0c3908e-dc21-4830-e010-531584daed10]: Sch. 1 para. 4: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^M_I_ca6e07c1-4c52-4025-e7b3-030b1139be28]: Sch. 1 para. 7: amendments have effect in relation to accounting periods beginning on or after 1.4.2024 by [2024 c. 3](https://www.legislation.gov.uk/ukpga/2024/3), [Sch. 1 para. 16](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/16); [S.I. 2024/286](https://www.legislation.gov.uk/uksi/2024/286), [reg. 2](https://www.legislation.gov.uk/uksi/2024/286/regulation/2)

[^key-03ff3b4fd3a70d598fab44bd36a2b80e]: [Sch. 1 para. 21(4)](https://www.legislation.gov.uk/ukpga/2024/3/schedule/1/paragraph/21/4) substituted (retrospectively) by [Finance Act 2025 (c. 8)](https://www.legislation.gov.uk/ukpga/2025/8), [s. 30(1)(2)](https://www.legislation.gov.uk/ukpga/2025/8/section/30/1)

#### 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 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 lifetime allowance previously-used amount,

or, if that produces a negative result, nil.

##### 130A

- (1) This paragraph applies in relation to 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.

- (2) The amendments made by Schedule 9 to FA 2024 and these regulations are to be disregarded for the purposes of determining—

- (a) the extent (if any) to which the lump sum is a lump sum within subsection (1) of section 166 of FA 2004 (lump sum rule), and

- (b) the tax treatment of the lump sum.

##### 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.

- (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)

@@ -11025,188 +11639,32 @@

#### Interpretation

## Editorial notes

#### 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

#### Films Act 1985

#### 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

#### ICTA

#### FA 1998

#### FA 2007

#### CTA 2009

#### FA 2009

#### CTA 2010

#### Films Act 1985

#### ICTA

#### FA 1998

#### FA 2007

#### CTA 2009

#### FA 2009

#### CTA 2010

#### FA 2016

#### General commencement

@@ -11391,56 +11849,6 @@

#### 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.

- (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 lifetime allowance previously-used amount,

or, if that produces a negative result, nil.

##### 130A

- (1) This paragraph applies in relation to 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.

- (2) The amendments made by Schedule 9 to FA 2024 and these regulations are to be disregarded for the purposes of determining—

- (a) the extent (if any) to which the lump sum is a lump sum within subsection (1) of section 166 of FA 2004 (lump sum rule), and

- (b) the tax treatment of the lump sum.

##### 132A

- (2) The repeal and re-enactment does not affect the continuity of the law.

- (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

@@ -11547,8 +11955,6 @@

#### 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

@@ -11571,8 +11977,6 @@

#### 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)

2024-04-06

Finance Act 2024

View changes Text at this date

2024-04-01

Finance Act 2024

View changes Text at this date

2024-02-22

Finance Act 2024

original version Text at this date