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 3Other taxes

Inheritance tax

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

(1)

IHTA 1984 is amended as follows.

(2)

In section 13 (dispositions by close companies for benefit of employees), after subsection (4) insert—

“(4A)

Subsection (4)(a) does not apply if, immediately after the disposition of property mentioned in subsection (1), more than 25% of relevant beneficiaries are (disregarding subsection (4)(a)) persons falling within subsection (2)(a) to (d).

(4B)

In subsection (4A) “relevant beneficiary” means a person who—

(a)

is a person for whose benefit the trusts permit the property to be applied, and

(b)

is a person employed by or holding office with the company mentioned in subsection (1).”.

(3)

In section 28 (employee trusts), after subsection (6) insert—

“(6A)

Subsection (6) does not apply if, immediately after the transfer of value mentioned in subsection (1), more than 25% of relevant beneficiaries are (disregarding subsection (6)) persons falling within subsection (4)(a) to (d).

(6B)

In subsection (6A) “relevant beneficiary” means a person who—

(a)

is a person for whose benefit the trusts permit the settled property to be applied, and

(b)

is a person employed by or holding office with the company mentioned in subsection (1).”.

(4)

In section 75 (exemption from charge under section 65 where property becomes subject to employee benefit trust), in subsection (3), in the opening words, after “section 28(4)” insert “and (6A)”.

(5)

This section is treated as having come into force on 30 October 2024.