Legislation – Finance Act 2026

Part 1
Income tax, capital gains tax and corporate taxes

1 Income tax charge for tax year 2026-27

2 Main rates of income tax for tax year 2026-27

3 Default and savings rates of income tax for tax year 2026-27

4 Increase in dividend ordinary and upper rates

5 Savings rates of income tax for tax year 2027-28

6 New rates of income tax on property income

7 Property rates of income tax for tax year 2027-28

8 Scottish and Welsh property rates set by Scottish Parliament and Senedd

9 Freezing starting rate limit for savings for tax years 2026-27 to 2030-31

10 Basic rate limit and personal allowance for tax years 2028-29 to 2030-31

11 Charge and main rate for financial year 2027

12 Standard small profits rate and fraction for financial year 2027

13 Enterprise management incentives: thresholds and period for exercise

14 Enterprise investment scheme: increase in amounts and asset requirements

15 Venture capital trusts: rate of relief and amounts and asset requirements

16 CSOP schemes and EMI: PISCES shares

17 Employee car and van ownership schemes

18 Car or van made available on arm’s length terms

19 CO emissions figure for certain cars with an electric range figure

20 Employment income: miscellaneous exemptions

21 Disallowing deduction from earnings for additional household expenses

22 Payment for cancelled shifts etc.

23 Location of duties of employment where duties not performed

24 Umbrella companies

25 Loan charge settlement scheme

26 Loan charge settlement scheme: inheritance tax

27 Loan charge settlement scheme: supplementary

28 Main rate of writing-down allowances for expenditure on plant or machinery

29 First-year allowance for main rate expenditure on plant or machinery

30 Expenditure on zero-emission cars and electric vehicle charging points

31 Payments for surrender of expenditure credits

32 Transition from video games tax relief

33 Special credit for visual effects

34 R&D undertaken abroad: Chapter 2 relief only

35 Restriction of relief on disposals to employee-ownership trusts

36 Anti-avoidance: collective investment scheme reconstructions

37 Anti-avoidance: company reconstructions

38 Anti-avoidance: reconstructions involving transfer of business

39 Incorporation relief: requirement to claim

40 Non-residents: cell companies

41 Non-residents: double taxation relief relating to collective investment vehicles

42 Abolition of notional tax credit on distributions received by non-UK residents

43 Non-resident, and previously non-domiciled individuals

44 Trust protections etc: minor amendments and transitional protection

45 PAYE for treaty non-residents etc.

46 Unassessed transfer pricing profits

47 Transfer pricing reform

48 International controlled transactions

49 Permanent establishments

51 Controlled foreign companies: interest on reversal of state aid recovery

52 Offshore income gains

53 Offshore income gains: savings

54 Legacies to charities to be within scope of tax

55 Approved charitable investments: purpose test

56 Tainted charity donations: replacement of purpose test with outcome test

57 Winter fuel payment charge

58 Carried interest

59 Pensions: abolition of the lifetime allowance charge

60 Collective money purchase schemes and Master Trust schemes

61 Corporate interest restriction: reporting companies

62 Corporate interest restriction: capital expenditure and tax-EBITDA calculation

63 Avoidance schemes involving certain non-derecognition liabilities

64 Energy (oil and gas) profits levy: decommissioning relief agreements

Part 2
Inheritance tax

65 Agricultural property relief and business property relief etc

66 Tax to be charged on certain pension interests

67 Liability for tax on pension interests

68 Withholding of benefits and payment of tax by pension scheme administrator

69 Connected amendments to IHTA 1984

70 Connected amendments to income tax rules

71 Commencement of

72 Rate bands etc for tax year 2030-31

73 Relevant property: disapplication of exemptions from exit charges

74 Relevant property: cap on charges for pre-30 October 2024 excluded property

75 Foreign diplomats etc: periods of UK residence to be disregarded

76 Minor corrections

77 Power to make provision about infected blood compensation payments

78 Scope of exemption for gifts to charities and registered clubs

79 Section 78: transitional protection for existing interests in possession

Part 3
Other existing taxes

80 Zero-rating of leases of vehicles to recipients of disability benefits

81 Insurance premium tax relief limited to adapted vehicles

82 Private hire vehicles or taxis

83 Certain charitable donations not to be treated as supplies of goods

84 Refunds of VAT to combined county authorities

85 UK listing relief

86 Rate of remote gaming duty

87 General betting duty on remote bets

88 Abolition of bingo duty

89 Rates of duty

90 Rates of duty effective from 6pm on 26 November 2025

91 Rates of duty effective from 1 October 2026

92 Vehicle excise duty for light passenger or light goods vehicles etc

93 Vehicle excise duty for rigid goods vehicles without trailers and tractive units

94 Vehicle excise duty for rigid goods vehicles with trailers

95 Vehicle excise duty for vehicles with exceptional loads etc

96 Vehicle excise duty for haulage vehicles other than showman’s vehicles

97 Vehicle excise duty: expensive car supplement

98 Rates of HGV road user levy

99 Rates of air passenger duty

100 Rates of climate change levy

101 Rates of landfill tax

102 Rate of aggregates levy

103 Aggregates levy: amendments relating to disapplication of levy to Scotland

104 Rate of plastic packaging tax

105 Chemical recycling: mass balance approach

106 Pre-consumer plastic

107 Sections 105 and 106: commencement

108 Rates of levy

109 Amendment of customs tariff power

110 Dumping and subsidisation investigations

111 Safeguarding investigations

112 Customs facilities at approved wharves and other places

113 Increases to rates of levy

114 Removal of time limit to claim relief under section 106(3) of FA 2013

Part 4
Vaping products duty

115 Excise duty: charge

116 Vaping products

117 Production of vaping products

118 Excise duty point and payment

119 Administration

120 Stamping of vaping products

121 Issue and management of duty stamps

122 Approved stamp holders

123 United Kingdom representatives

125 Dealing in unstamped vaping products

126 Loss and misuse of duty stamps

127 Failure to comply with this Part etc

128 Forfeiture: civil penalties

129 Dealing in duty stamps

130 Dealing in unstamped vaping products

131 Sales ban following conviction for unlawful use of premises

132 Offences: penalties

133 Forfeiture: offences

134 Publication of information

135 Information sharing

136 Investigation and enforcement

137 Regulations: further provision

138 Regulations: procedure

139 Amendments of other enactments

140 Interpretation

141 Commencement and transitional provision

Part 5
Carbon border adjustment mechanism

142 Introduction to CBAM

143 Charge to CBAM

144 Importation

145 Goods processed under a special customs procedure

146 Person liable: the importer

148 Embodied emissions

150 Carbon price relief

151 Administration and enforcement

152 Criminal offences

153 Supplementary amendments

154 Emissions: meaning etc

155 Interpretation

156 Power to make provision for linked emissions trading schemes

157 Regulations and notices

158 Commencement and transitory provision

Part 6
Avoidance

Chapter 1 Prohibition of promotion of certain tax avoidance arrangements

159 Prohibition of promotion of certain tax avoidance arrangements

160 Meaning of promotion

162 Civil penalties

163 Criminal offence

164 Criminal liability of responsible persons

165 Interpretation and commencement

Chapter 2 Promoter action notices

Promoter action notices

166 Certification of promoters

167 Promoter action notices

168 Preliminary notices

169 Disclosure of information by HMRC

170 Appeal against a decision to issue a promoter action notice

171 Civil penalties

172 Publication

173 Reporting to regulators etc

174 Extension of time periods

175 Reasonable excuse

176 Interpretation

Chapter 3 Anti-avoidance information notices

Key definitions

177 Connected persons

178 Anti-avoidance enactments

Notices by type

179 Information notices: connected persons

180 Information notices: third parties

181 Information notices: unidentified connected persons

182 Information notices: identification

183 Information notices: financial institutions

Content, requirements and withdrawal of notices

184 Content and requirements of notices

185 Restriction on disclosure of notices

186 Excepted information

187 Tribunal approval of notices

188 Withdrawal of notices

Criminal sanctions

189 Offence of failing to comply with a notice

190 Offence of concealing information

191 Criminal liability of responsible persons

192 Criminal liability of responsible persons: no prosecution of recipient

193 Imprisonment or a fine

Civil sanctions

194 Penalty for failing to comply with a notice

195 Penalty for concealing information

196 Penalty for inaccurate information

197 Penalty for disclosing a notice

198 Penalty based on monies received

199 Increased daily default penalty

Sanctions: general

200 Extension of time periods

201 Reasonable excuse

202 Double jeopardy

203 Assessment etc of penalties: application of Schedule 36 to FA 2008

204 Appeals against notices

205 Appeals against penalties

Miscellaneous and interpretation

206 Interpretation

207 Application of provisions of TMA 1970

Chapter 4 Miscellaneous

Legal professionals

209 Declaration in relation to privileged material

210 Penalties for an incorrect declaration

211 Penalties: procedure, appeals etc

212 Publication following an incorrect declaration

213 Time limits for publication

214 Amendments to existing legislation: removal of privilege exemption

215 Commencement

Disclosure of tax avoidance schemes: consequences for failure to comply

216 Penalties for non-disclosure of tax avoidance schemes

217 Removal of time limits on publication by HMRC

218 Consequential amendments

219 Commencement

Construction industry scheme: amendments

220 Construction industry scheme: amendments

221 Construction industry scheme regulations: amendments

222 Commencement

Part 7
Tax advisers

Chapter 1 Registration

Prohibition against unregistered tax advisers interacting with HMRC

223 Prohibition against unregistered tax advisers interacting with HMRC

224 Meaning of “tax adviser” and “client”

Application process

225 Application for registration

226 Meaning of “relevant individual” and “officer”

227 Registration conditions

228 Registration conditions: interpretation

229 Registration conditions: offences

230 Registration of tax advisers etc

Monitoring of registration conditions and suspension of registration

231 Monitoring of registration conditions

232 Suspension of registration

Compliance notice

233 Compliance notice

Financial penalties

234 Financial penalties for prohibited interaction with HMRC

235 Financial penalties for prohibited interaction with HMRC: liability of relevant individuals

Ineligibility orders

236 Tax advisers: ineligibility orders

237 Relevant individuals: ineligibility orders

Requirement for tax adviser to notify clients of suspension or ineligibility orders

238 Requirement for tax adviser to notify clients of suspension or ineligibility orders

Reasonable excuse

239 Reasonable excuse

Extension of period for making representations

240 Extension of period for making representations

Assessment of financial penalties etc

241 Assessment of financial penalties

242 Time limits and treatment of financial penalties

243 Double jeopardy

Reviews and appeals

244 Reviews and appeals

Disclosure of information

245 Disclosure of information

Power to publish information

246 Power to publish information

Power to amend Schedule 20 (exceptions)

247 Power to amend Schedule 20 (exceptions)

248 Interpretation of Chapter

249 Commencement

Chapter 2 Conduct etc

Conduct of tax advisers

250 Conduct of tax advisers

Power to publish information about tax advisers etc

251 Power to publish information

252 Power to publish information: change of circumstances

253 Power to publish information: interpretation and commencement

Part 8
Miscellaneous and final

254 Fiscal mandate assessments prepared by the Office for Budget Responsibility

255 Data-gathering

256 Persons on whom digital reporting requirements may be imposed

257 Exemptions from digital reporting requirements

258 Returns to be delivered by electronic communications etc.

259 Penalties: amendments consequential on section 258 etc

260 Powers relating to electronic communications: directions

261 Power to require digital contact details

262 Penalty points and late submission penalties (power to cancel etc)

263 Assessments of late payment penalties etc.

264 Penalties for failure to pay tax due on further appeal

265 Failure to deliver company tax returns

267 Binding effect

269 Modification

270 Information

271 Misrepresentation

272 Commissioners notice

274 Interpretation

275 Cryptoasset reporting: users and controlling persons resident in the UK

276 International cryptoasset reporting framework: connected matters

277 Stamp duty: piloting of digital service etc

278 Oversight of HMRC tax enforcement functions in Northern Ireland

279 Repeal of obsolete provision in FA 1925 concerning Dominion Governments

280 Repeal of other obsolete provisions and correction of wrong cross-references

281 Interpretation

282 Short title

SCHEDULES

Schedule 1 Property and savings rates of income tax: consequential amendments

Schedule 2 Scottish and Welsh property income rates

Schedule 3 Non-resident, and previously non-domiciled individuals

Schedule 4 PAYE for treaty non-residents etc

Schedule 5 Unassessed transfer pricing profits

Schedule 6 Transfer pricing

Schedule 7 Permanent establishments

Schedule 8 Pillar Two

Schedule 9 Tainted charity donations

Schedule 10 Winter fuel payment charge

Schedule 11 Tax treatment of carried interest

Schedule 12 Reform of reliefs for business property and agricultural property

Schedule 13 Abolition of bingo duty: consequential and transitional provision

Schedule 14 Aggregates levy: amendments relating to disapplication of levy to Scotland

Schedule 15 Vaping products duty: amendments of other enactments

Schedule 16 CBAM Goods

Schedule 17 Administration of CBAM

Schedule 18 Offences relating to CBAM

Schedule 19 Supplementary amendments relating to CBAM

Schedule 20 Registration of tax advisers: exceptions

Schedule 21 Registration of tax advisers: reviews and appeals

Schedule 22 Conduct of tax advisers

Schedule 23 Data-gathering

Which version?
Latest available (Revised)
Original (As enacted)

Changes to legislation:

Finance Act 2026, Section 40 is up to date with all changes known to be in force on or before 18 April 2026. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.

Changes to Legislation

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Part 1Income tax, capital gains tax and corporate taxes

Chargeable gains

40Non-residents: cell companies

(1)

Part 4 of Schedule 1A to TCGA 1992 (anti-avoidance relating to assets deriving 75% of value from UK land) is amended as follows.

(2)

For the heading of the Part substitute “Cell companies and anti-avoidance”.

(3)

Before paragraph 11 insert—

“Cell companies

10A

(1)

In the application of this Schedule in relation to the disposal of an asset consisting of a right or an interest in a cell company, each cell of the company is to be treated as if it were an individual company.

(2)

For the purposes of this paragraph—

(a)

a company is a “cell company” if under the law under which the company is formed, under the company’s articles of association or other document regulating the company or under arrangements entered into by or in relation to the company—

(i)

some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and

(ii)

some or all of the members of the company, and some or all of its creditors, have rights primarily, or only, in relation to particular assets of the company;

(b)

“cell”, in relation a cell company, means an identifiable part of the company that carries on distinct business activities and to which particular assets and liabilities of the company are primarily or wholly attributable.

Anti-avoidance”.

(4)

The amendments made by this section have effect in relation to disposals made on or after 26 November 2025.