Legislation – Finance Act 2025

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Introduction

Part 1
Income tax, capital gains tax and corporate taxes

1 Income tax charge for tax year 2025-26

2 Main rates of income tax for tax year 2025-26

3 Default and savings rates of income tax for tax year 2025-26

4 Freezing starting rate limit for savings for tax year 2025-26

5 Appropriate percentage for cars: tax year 2028-29

6 Appropriate percentage for cars: subsequent tax years

7 Main rates of CGT for gains other than carried interest gains

8 Business asset disposal relief: increase in rate

9 Investors’ relief: increase in rate

10 Investors’ relief: reduction in amount qualifying for relief

11 Sections 7 to 10: transitional provision

12 Rate of CGT for carried interest gains

13 Charge and main rate for financial year 2026

14 Standard small profits rate and fraction for financial year 2026

15 Increase in rate of energy (oil and gas) profits levy

16 Relief from levy for investment expenditure

17 Extending the period for which levy has effect

18 Decommissioning of carbon storage installations

19 Pillar Two

20 Offshore receipts in respect of intangible property

21 Application of PAYE in relation to internationally mobile employees etc.

22 Advance pricing agreements: indirect participation in financing cases

23 Expenditure on zero-emission cars

24 Expenditure on plant or machinery for electric vehicle charging point

25 Commercial letting of furnished holiday accommodation

26 Films and television programmes: increased relief for visual effects

27 Certification of films etc: minor amendments

28 Films etc: unpaid amounts

29 Research and development relief: Northern Ireland companies

30 Research and development intensity condition: transitional provision

31 Employee-ownership trusts

32 Overseas transfer charge: pension schemes in EEA state or Gibraltar

33 Overseas pension schemes established in EEA states

34 Pension scheme administrators required to be resident in United Kingdom

35 Alternative finance: diminishing shared ownership refinancing arrangements

36 Statutory neonatal care pay

Part 2
Replacement of special rules relating to domicile

Chapter 1 New rules for foreign income and gains of individuals becoming UK resident

37 Claim for relief on foreign income

38 Claim for relief on foreign employment income

39 Claim for relief on foreign gains

Chapter 2 Ending the special treatment of individuals not domiciled in United Kingdom

40 Remittance basis not available after tax year 2024-25

41 Temporary repatriation facility

42 Rebasing of assets

Chapter 3 Trusts etc

43 Trusts: connected amendments, transitional provision etc

Chapter 4 Inheritance tax

44 Excluded property: domicile test replaced with long-term residence test

45 Corresponding change for settled property

46 Consequential, connected and transitional provision

Part 3
Other taxes

47 Removal of exemption for private school fees

48 Charge on pre-paid private school fees

49 Sections 47 and 48: commencement

50 Increased rates for additional dwellings: transactions before 1 April 2025

51 Increased rates for additional dwellings: transactions on or after 1 April 2025

52 Contracts substantially performed before relevant rate change

53 Purchases by companies etc

54 Alternative finance: land in England, Scotland or Northern Ireland

55 Alternative finance: land in Wales

56 Testing of FMI technologies or practices

57 Rate bands etc for tax years 2028-29 and 2029-30

58 EBTs: prohibition on applying property for benefit of participators etc

59 EBTs: restriction on proportion of beneficiaries who may be participators etc

60 EBTs: shares entering trust to have been held for two years

61 Agricultural property relief: environmental management agreements

62 National Savings Bank: statements from HMRC no longer to be required

63 Rates of alcohol duty

64 Abolition of duty stamps for alcoholic products

65 Rates of tobacco products duty

66 Rates of vehicle excise duty for light passenger or light goods vehicles etc

67 Rates of vehicle excise duty for rigid goods vehicles without trailers etc

68 Rates of vehicle excise duty for rigid goods vehicles with trailers

69 Vehicle excise duty for vehicles with exceptional loads etc

70 Rate of vehicle excise duty for haulage vehicles other than showman’s vehicles

71 Vehicle excise duty: zero-emission vehicles

72 Rates of HGV road user levy

73 Rates of air passenger duty until 1 April 2026

74 Rates of air passenger duty from 1 April 2026

75 Rates of climate change levy

76 Rates of landfill tax

77 Rate of aggregates levy

78 Rate of plastic packaging tax

79 Rates of soft drinks industry levy

Part 4
Miscellaneous and final

80 Limited liability partnerships

81 Loans to participators

82 OECD crypto-asset reporting framework

83 Duty on vaping products

84 Carbon border adjustment mechanism

85 Correction of wrong cross-reference etc

86 Interpretation

87 Short title

SCHEDULES

Schedule 1 Consequential provision in connection with section 7

Schedule 2 Sections 7 to 10 : transitional provision

Schedule 3 Payments into decommissioning funds

Schedule 4 Pillar two

Schedule 5 Furnished holiday lettings

Schedule 6 Employee-ownership trusts

Schedule 7 Diminishing shared ownership refinancing arrangements

Schedule 8 Relief on foreign employment income: consequential and transitional provision

Schedule 9 Income tax and capital gains tax: remittance basis and domicile

Schedule 10 Temporary repatriation facility

Schedule 11 Rebasing of assets

Schedule 12 Trusts: connected amendments, transitional provision etc

Schedule 13 Inheritance tax

Part 1Income tax, capital gains tax and corporate taxes

Reliefs for businesses

26Films and television programmes: increased relief for visual effects

(1)

In Part 14A of CTA 2009 (films, television programmes and video games), after section 1179EB insert—

“1179ECSpecial credit for visual effects

(1)

This section applies in relation to a qualifying film or qualifying television programme.

(2)

The production company is entitled to claim an additional amount of audiovisual expenditure credit for an accounting period (“the claim period”) that is the completion period (see section 1179DY) or a subsequent accounting period if—

(a)

the company has incurred relevant visual effects expenditure on the film or programme in that period or an earlier accounting period, and

(b)

where a claim has been made for Chapter 3 credit (whether for the claim period or earlier), the relevant percentage for the purposes of all such claims was the percentage given by subsection (2) or (5) of section 1179DV.

(3)

The additional amount is equal to—

(a)

39% of the total amount of the relevant visual effects expenditure incurred on the film or programme in the claim period and in previous periods, less

(b)

the sum of—

(i)

where Chapter 3 credits have been claimed by the production company, the adjusted VFX portion of those credits, and

(ii)

any additional amounts of audiovisual expenditure credit previously claimed under this section.

(4)

Take the following steps to determine the adjusted VFX portion of previously claimed Chapter 3 credits—

  • Step 1 (identify the total UK expenditure in the AVEC period)

    Determine the total amount of the company’s relevant global expenditure (see section 1179CA(2)) that—

    1. (a)

      is UK expenditure (see section 1179AB), and

    2. (b)

      was incurred for accounting periods falling within the company’s AVEC period.

  • Step 2 (identify the amount of visual effects expenditure)

    Determine how much of the result of Step 1 is relevant visual effects expenditure.

  • Step 3 (determine the extent to which the 80% cap applied)

    Determine the amount (if any) of the excess to be deducted at Step 3 in section 1179CA(1) for the most recent accounting period for which a claim for Chapter 3 credit was made (which may be the claim period).

    If that amount is nil go to Step 4, otherwise go to Step 5.

  • Step 4 (where the 80% cap did not apply, calculate the adjusted VFX portion)

    If this Step applies, the adjusted VFX portion is the amount given by multiplying—

    1. (a)

      the sum of Chapter 3 credits claimed by the production company, by

    2. (b)

      the amount given by dividing the result of Step 2 by the result of Step 1.

  • Step 5 (treat the 80% cap as affecting the VFX portion first)

    Subtract the result of Step 3 from the result of Step 2.

    If the result is nil or less, the adjusted VFX portion is nil. If not, go to Step 6.

  • Step 6 (calculate the adjusted VFX portion, taking account of the 80% cap)

    If this Step applies, the adjusted VFX portion is the amount given by multiplying the result of Step 5 by 0.34.

(5)

The Treasury may by regulations replace—

(a)

the percentage for the time being specified in subsection (3)(a), or

(b)

the number for the time being specified in Step 6 in subsection (4) as the number by which the result of Step 5 in that subsection is multiplied.

(6)

Sections 1179C and 1179CB to 1179CI (treatment of expenditure credits) apply to the additional amount as they apply to an expenditure credit under Chapter 3.

(7)

In this section—

a company’s “AVEC period” means the period beginning with the commencement of the first accounting period for which this Part applies further to the election by the company under section 1179B(1) and ending with the end of the claim period;

Chapter 3 credit” means an audiovisual expenditure credit in respect of the film or television programme determined under section 1179CA;

relevant visual effects expenditure” means UK expenditure that—

(a)

is incurred in respect of relevant visual effects work carried out in the United Kingdom, and

(b)

counts as relevant production expenditure for the purposes of section 1179CA(2) (see section 1179DR);

relevant visual effects work” means work consisting of the use of computer technology to create or alter images for inclusion in the film or programme.”

(2)

The amendment made by subsection (1) has effect only in relation to expenditure incurred on or after 1 January 2025.

(3)

A claim for audiovisual expenditure credit may not be made in reliance on that amendment before 1 April 2025.