Key changes relate to non-dom tax status, capital gain tax, tax for landlords, energy profits levy (so-called oil and gas windfall tax), Islamic finance, global minimum tax, OECD crypto asset reporting framework (CARF), overseas pension transfers.
Applies from Royal Assent, start of 2025 tax year (Apr. 6, 2025), and other dates.
On Dec. 19, UK HMRC published amendments to finance bill 2024-25.
UK HMRC published explanatory notes for two UK GVT amendments in the Public Bill Committee, for the Finance Bill 2024-25, on changes to the taxation rules proposed.
This measure amends the Finance (No.2) Act 2023 implementing the Income Inclusion Rule (IIR) and Qualifying Domestic Minimum Top-Up Tax (QDMTT) in line with agreed approach with international partners made through OECD/G20 Inclusive Framework.
Measure also implements a package of amendments to the Finance (No.2) Act 2023 identified from stakeholder feedback, as well as all those that are necessary to ensure that UK legislation remains consistent with the OECD’s Commentary to the GloBE rules.
This clause and schedule amend the Parts and schedules of Finance (No.2) Act 2023 that implement the Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT).
Part 2 of the Schedule introduces the undertaxed profits rule (UTPR) to UK legislation.
Part 3 makes amendments to the MTT and DTT legislation in Finance (No.2) Act 2023.
The legislation that is to be introduced in Part 2 of Schedule 4, implementing the UTPR, will now take effect for all the accounting periods beginning on or after Dec. 31, 2024.
Haulage Vehicles
This new clause sets out the updated rate of Vehicle Excise Duty (VED) for the general haulage vehicle tax class (tax class 55), other than Showman’s Vehicles for 2025/26.
This new clause provides for an increase in the rate of vehicle excise duty applicable to haulage vehicles from £350 to £365, which was omitted from Finance Bill 2024-25.
The increase will take effect in relation to licenses taken out on or after Apr. 1. 2025.
Jan. 2025 New Explanatory Notes
On Jan. 23, 2025, UK HMRC confirmed the Finance Bill 2024-25: Public Bill Committee has been updated with 9 new explanatory notes, to provide more detailed information.
Jan. 27, 2025 Updated Explanatory Notes
On Jan. 27, 2025, UK HMRC updated the titles of the eleven (11) explanatory notes on amendments connected to Finance Bill 2024-25: Public Bill Committee.
Jan. 30, 2025 UKP Treasury Letters
On Jan. 30, 2025, UKP issued letters of Jan. 24, 2025 from James Murray to David Mundell and Valerie Vaz re Finance Bill 2024-25: summary of clauses with powers to make secondary legislation and amendments tabled ahead of Public Bill Committee.
First letter provides info on secondary legislation under the bill, sets out detail on each power being taken; summary provided on powers contained in cl 7, 19, 26, 56, 81.
Clause 7 and Sch 1 on main rates of CGT for gains other than carried interest gains. Para 9(2) of Sch 1 inserts into FA 2019, Sch 2 new paragraphs 16A to 16H.
These paragraphs reproduce what was schedule 1B to the TCGA 1992 and define residential property gains for the purpose of Schedule 2 to the FA 2019.
Schedule 4 contains a number of amendments to the FA (No.2) 2023 provisions implementing the OECD pillar two initiative.
Clause 81 modifies Section 349 of FA (No. 2) 2023 (international information exchange), allowing UK Treasury to regulate the implementation of the OECD CARF.
Future regs under amended power will impose reporting/due diligence obligations on crypto-asset service providers to ensure CARF compliance, penalties for not complying.
Any regulations made under the amended power will be subject to negative procedure.
Feb. 2025 Report Stage Amendments
On Feb. 25, 2025, UK HMRC published explanatory notes for the UK GVT amendments in Report Stage of Finance Bill 2024-25, on a variety of matters, relating to taxation.
These changes concern Amendments 1 to 4 to Clause 26: Additional relief for visual effects, and the Amendments 5 to 8 to Clause 37: Claim for relief on foreign income.
Also the Amendments 9 and 10 to Clause 38: Claim for relief on foreign employment income as well as Amendments 11 to 15 to Clause 39: Claim for relief on foreign gains.
Additionally affect the Amendments 16 and 17 and 21 to 27 to Clause 40 and Schedule 9: Remittance basis not available after tax year 2024-2025 as well as the Amendments 18 to 20 to Schedule 3: Decommissioning of carbon storage installations, as changed.
Some Amendments 28 to 49 to Schedule 10: Temporary Repatriation Facility Charge.
There are also some changes made through the Amendments 50 to 55 to Schedule 12: Trusts: connected amendments, transitional provision etc., as well as the Amendments 56 to 66 to Schedule 13: Consequential, connected and transitional provision, texts.
Feb. 26, 2025 Updated Document Names
On Feb. 26, 2025, UK HMRC updated page to reflect changes to document names.
Names of documents are listed as set out in Feb. 25, 2025 version of this update.
Feb. 28, 2025 UKP Treasury Letter
On Feb. 28, 2025, UKP issued letter from James Murray MP to Gareth Davies MP and James Wild MP re questions raised during public committee stage of Finance Bill.
This covers application of PAYE re treaty non-resident cases; expenditure on zero-emission cars and charge points, how man businesses claim these allowances.
Removal of the exclusion from overseas transfer charge (OTC) of transfers to qualified pension schemes in EEA and Gibraltar, revenue raised by OTC since introduced 2017.
Excluded property, and concerns regarding individuals who, having departed UK before the new residence-based inheritance tax regime starts on Apr. 6, 2025, will nonetheless be considered long-term residents when the legislation takes effect.
Rates of climate change levy among energy-intensive businesses, including chemicals.
Document dated Feb. 28, 2025, received from UKP Mar. 12, summarized on Mar. 17.
Mar. 2025 Royal Assent
On Mar. 20, 2025, UKP Finance Act 2025 (FA 2025 (UK)) received Royal Assent.
Key changes relate to non-dom tax status, capital gain tax, tax for landlords, energy profits levy (so-called oil and gas windfall tax), Islamic finance, global minimum tax, OECD crypto asset reporting framework (CARF), overseas pension transfers.
Applies from Royal Assent, start of 2025 tax year (Apr. 6, 2025), and other dates.
