The Horizon Convictions Redress Scheme and Horizon Shortfall Scheme Fixed Sum Award (Tax Exemptions and Relief) Regulations 2024

Made: 25th July 2024

Laid before the House of Commons: 26th July 2024

Coming into force: 16th August 2024

The Treasury make these Regulations in exercise of the powers conferred by paragraphs 2(5), 3(5), 4(3)(c) and 5(7) of Part 1 and 7(1)(e), 7(3), 9(3)(b) and (d) and (4) and 10(3)(b), (4)(b) and (5) of Part 2 of Schedule 15 to the Finance Act 2020[^f00001].

Citation and commencement

1

These Regulations may be cited as the Horizon Convictions Redress Scheme and Horizon Shortfall Scheme Fixed Sum Award (Tax Exemptions and Relief) Regulations 2024 and come into force on 16th August 2024.

Interpretation

2

• (1) In these Regulations—

• “Horizon Convictions Redress Scheme compensation payment” means a payment made by the Department for Business and Trade to a person eligible for compensation under the scheme announced by His Majesty’s Government on 13th March 2024 and who—had a conviction involving the Horizon system quashed by legislation,had a conviction involving the Horizon system quashed by a court,received a caution of any kind for an offence involving the Horizon system,in Scotland received an alternative to prosecution within the definition given in section 4(5) of the Post Office (Horizon System) Offences (Scotland) Act 2024 or received a purported alternative to prosecution from the Post Office Limited, orwas the subject of a criminal prosecution involving the Horizon system but was not convicted;

• “Horizon Shortfall Scheme Fixed Sum Award” means a payment of compensation made by Post Office Limited to a person eligible for compensation under the Horizon Shortfall Scheme or a nominated individual for the purpose of ensuring that person receives a total of £75,000 in compensation under that scheme;

• “nominated individual” means any person who was a shareholder or a director of a company or a partner in a partnership which ceased to exist and that would have been eligible for compensation under the Horizon Shortfall Scheme.

• (2) For the purposes of provision in these regulations made under Part 1 of Schedule 15 to the Finance Act 2020, “Horizon Shortfall Scheme”, “the Horizon system” and “Post Office Limited” have the same meaning as they do in Part 2 of that Schedule[^f00002].

Exemptions from income tax for Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards

3

• (1) Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards are qualifying payments for the purposes of paragraph 3 of Part 1 of Schedule 15 to the Finance Act 2020.

• (2) This regulation applies to payments received on or after 13th March 2024 , subject to paragraph (3).

• (3) For payments within sub-paragraphs (b), (c), (d) and (e) of the definition of “Horizon Convictions Redress Scheme compensation payment”, this regulation applies to payments received on or after 3rd June 2025.

Exemptions from capital gains tax for Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards

4

• (1) Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards are qualifying payments for the purposes of paragraph 4 of Part 1 of Schedule 15 to the Finance Act 2020.

• (2) This regulation applies to disposals made on or after 13th March 2024 , subject to paragraph (3).

• (3) For payments within sub-paragraphs (b), (c), (d) and (e) of the definition of “Horizon Convictions Redress Scheme compensation payment”, this regulation applies to disposals made on or after 3rd June 2025.

Relief from inheritance tax for Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards

5

• (1) Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards are qualifying payments for the purposes of paragraph 5 of Part 1 of Schedule 15 to the Finance Act 2020.

• (2) This regulation applies to deaths occurring on or after 13th March 2024 , subject to paragraph (3).

• (3) For payments within sub-paragraphs (b), (c), (d) and (e) of the definition of “Horizon Convictions Redress Scheme compensation payment”, this regulation applies to deaths occurring on or after 3rd June 2025.

Exemption from corporation tax for Horizon Shortfall Scheme Fixed Sum Awards

6

• (1) Horizon Shortfall Scheme Fixed Sum Awards are relevant compensation payments for the purposes of Part 2 of Schedule 15 to the Finance Act 2020.

• (2) This regulation applies to payments received on or after 13th March 2024.

Exemption from income tax and capital gains tax for relevant onward payments of Horizon Shortfall Scheme Fixed Sum Awards

7

• (1) Paragraph 10(3)(b) of Part 2 of Schedule 15 to the Finance Act 2020 has effect in relation to payments received on or after 13th March 2024 for Horizon Shortfall Scheme Fixed Sum Awards.

• (2) Paragraph 10(4)(b) of Part 2 of Schedule 15 to the Finance Act 2020 has effect in relation to disposals made on or after 13th March 2024 for Horizon Shortfall Scheme Fixed Sum Awards.

Signed

Jeff Smith — Vicky Foxcroft — Two of the Lords Commissioners of His Majesty’s Treasury — 25th July 2024

Explanatory note

(This note is not part of the Regulations)

Explanatory Note

These Regulations provide for exemptions from income tax and capital gains tax and a relief from inheritance tax for Horizon Convictions Redress Scheme compensation payments and Horizon Shortfall Scheme Fixed Sum Awards and an exemption from corporation tax for Horizon Shortfall Scheme Fixed Sum Awards. Horizon Convictions Redress Scheme compensation payments are made by the Department for Business and Trade to people who have had a conviction involving the Horizon system quashed by legislation. Horizon Shortfall Scheme Fixed Sum Awards are made by Post Office Limited to people who are eligible for compensation under the Horizon Shortfall Scheme or are a nominated individual to ensure they receive a total of £75,000 in compensation.

A Tax Information and Impact Note covering this instrument will be published on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins.

Footnotes

[^f00001]: 2020 c. 14. Schedule 15 was amended by section 12 of the Finance Act 2024 (c. 3).

[^f00002]: These terms are defined in paragraph 13 of Part 2 of Schedule 15 to the Finance Act 2020.

Editorial notes

[^key-aef5bc70879b0436d4c591e5e090b84d]: Reg. 1 in force at 16.8.2024, see reg. 1

[^key-d14b5dadf14d0b0832f33388cdd6b8d8]: Reg. 2 in force at 16.8.2024, see reg. 1

[^key-15129e316f2387903c8537bc230ceb27]: Reg. 3 in force at 16.8.2024, see reg. 1

[^key-95b0cd4c1d76c59c13560a4eaa541609]: Reg. 4 in force at 16.8.2024, see reg. 1

[^key-7e1355ac1b592d91ad3eb11096991a3a]: Reg. 5 in force at 16.8.2024, see reg. 1

[^key-049f1ee2ad7c62529e63e71f945c3041]: Reg. 6 in force at 16.8.2024, see reg. 1

[^key-23d56de5defa575f2a8a12a86b9e6094]: Reg. 7 in force at 16.8.2024, see reg. 1

[^key-88aaef0a59c3a2aa2296db9483a53d37]: Words in reg. 2(1) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(2)(a)

[^key-3882c4c2e4bc2650c985c9746503456c]: Words in reg. 2(1) substituted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(2)(b)

[^key-276818ffaccca2b6b03204849ef7a751]: Words in reg. 3(2) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(3)

[^key-7722315c97e4907c24be303e5e643b74]: Reg. 3(3) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(4)

[^key-5941bcb0f5a18df7540b2f0c57b6aeb7]: Reg. 4(3) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(6)

[^key-3e2c492b2f27fb083df83ec9a6be9703]: Words in reg. 4(2) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(5)

[^key-f731bd5212b6f2f6428fb56ad281befb]: Words in reg. 5(2) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(7)

[^key-5fa71ab378cf3bf3a8858478ee3e3576]: Reg. 5(3) inserted (7.8.2025) by The Horizon Convictions Redress Scheme (Amendment) and Grenfell Support (Restorative Justice) Programme (Income Tax Exemption) Regulations 2025 (S.I. 2025/867), regs. 1, 2(8)