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

Changes to legislation:

There are outstanding changes not yet made by the legislation.gov.uk editorial team to Finance Act 2025. Any changes that have already been made by the team appear in the content and are referenced with annotations. Help about Changes to Legislation

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Part 3Other taxes

Stamp duty land tax

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

(1)

Section 1 of the Stamp Duty Land Tax (Temporary Relief) Act 2023 (which provides for reduced rates of stamp duty land tax for transactions before 1 April 2025) is amended as follows.

(2)

In subsection (3) (which deals with purchases of additional dwellings), for the Table A mentioned there substitute—

“TABLE A: RESIDENTIAL

Part of relevant consideration

Percentage

So much as does not exceed £250,000

5%

So much as exceeds £250,000 but does not exceed £925,000

10%

So much as exceeds £925,000 but does not exceed £1,500,000

15%

The remainder (if any)

17%”.

(3)

The amendment made by this section has effect in relation to land transactions the effective date of which falls on or after 31 October 2024 but before 1 April 2025.

(4)

But the amendment made by this section does not have effect in relation to a land transaction which—

(a)

is effected in pursuance of a contract entered into before 31 October 2024, and

(b)

is not excluded.

(5)

For this purpose a land transaction is excluded if—

(a)

there is any variation of the contract, or assignment of rights under the contract, on or after 31 October 2024,

(b)

the transaction is effected in consequence of the exercise on or after that date of any option, right of pre-emption or similar right, or

(c)

on or after that date, there is an assignment, subsale or other transaction relating to the whole or part of the subject-matter of the contract as a result of which a person other than the purchaser under the contract becomes entitled to call for a conveyance.

(6)

This section also needs to be read with section 52 (which deals with cases where a contract has been substantially performed before the change in rates made by this section etc).