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Finance (No. 2) Bill - Sitting 1

16 May 2023

Proposing MP
Tatton
Type
Public Bill Committee

At a Glance

Issue Summary

The discussion revolves around the procedure and limitations set forth in a Finance Bill's program motion, specifically concerning the lack of oral evidence sessions. The statement discusses clauses in the Finance Bill related to income tax rates and thresholds for 2023-24, including main rates, savings rates, and starting rate limits. Angela Eagle discusses the impact of freezing income tax thresholds until 2028, which is expected to increase the number of people paying higher levels of income tax. Angela Eagle discusses concerns over fiscal drag and frozen tax thresholds leading to high marginal tax rates for certain individuals. The statement addresses the personal allowance threshold for taxation and national insurance, highlighting efforts to support individuals through the cost-of-living crisis. The statement discusses changes to two tax-advantaged employee share schemes, CSOP and EMI, aimed at supporting business growth and talent retention. The statement discusses changes to the company share option plan (CSOP) and enterprise management incentives (EMI) options as part of the Finance (No. 2) Bill. The statement discusses clarifying that payments made under the Welsh Government's Jobs Growth Wales Plus scheme are exempt from income tax with retrospective effect from April 2022. The statement addresses changes to qualifying care relief thresholds for foster carers, increasing the income tax relief available to them. The statement discusses amendments to the Finance (No. 2) Bill that aim to simplify tax administration for trusts and estates. The statement addresses amendments and clarifications related to the taxation of estates in administration and trusts under clause 29 of the Finance (No. 2) Bill. The statement addresses amendments to tax rules concerning long-term insurance business (BLAGAB) and the financial consequences of court-ordered write-downs for insurers in distress. The statement addresses technical amendments and clarifications in the Finance (No. 2) Bill related to tax treatment for reinsured businesses and annuities. The statement addresses amendments to corporate interest restriction rules and tax regimes for investment vehicles in the Finance (No. 2) Bill. The statement discusses changes to corporate interest restriction rules and the establishment of an external working group to address issues identified by HMRC, businesses, and their advisers.

Action Requested

While no specific action is proposed by the minister, she emphasizes that extensive pre-legislative consultation with tax experts and public consultations are conducted prior to introducing draft clauses. She also highlights the thorough scrutiny provided by the Committee of the whole House and Public Bill Committee.

Key Facts

  • The Finance Bill's program motion does not allow for oral evidence sessions.
  • Part of a Finance Bill is considered by the whole House, with another part scrutinized in Public Bill Committee.
  • Pre-legislative consultation includes publishing more than 250 pages of draft clauses before introducing the Bill to Parliament.
  • Clause 1 legislates the charge for income tax for 2023-24.
  • Clauses 2 sets main rates at 20% (basic), 40% (higher), and 45% (additional).
  • Clause 3 sets savings rates for UK taxpayers.
  • The starting rate limit for savings is maintained at £5,000 for individuals with low earned income of less than £17,570.
  • Approximately £268 billion is expected to be raised from income tax in 2023-24.
  • Around 95% of savers pay no tax on their savings income due to various tax reliefs.
  • The thresholds have been frozen until 2028, dragging many more people into paying higher levels of income tax.
  • 8 million people will be affected by fiscal drag in 2027-28.
  • One in four teachers and one in eight nurses will become higher-rate taxpayers by 2027.
  • The Prime Minister pays an effective rate of 22% on earnings.
  • People face marginal tax rates of up to 60% due to fiscal drag.
  • The Treasury Committee is conducting an inquiry into spiky marginal tax rates and cliff edges.
  • The personal allowance threshold is set at £12,570 per year.
  • More than 3 million people will be taken out of tax by 2023-24 due to increased thresholds.
  • About 30% of individuals do not pay tax as a result of the personal allowance increase.
  • The UK higher rate threshold is £50,270, protecting most from paying the higher rate of income tax.
  • Average median earnings for an employee are £28,000 per year.
  • The Office for Budget Responsibility (OBR) forecasts that frozen thresholds will drag 2.1 million people into the higher rate of tax.
  • CSOP limit increased from £30,000 to £60,000.
  • Changes allow future adjustments by regulations.
  • EMI scheme administrative requirements are simplified.
  • Changes support an estimated 4,700 SMEs and 45,000 employees annually.
  • Clauses apply to schemes granted on or after April 6, 2023.
  • CSOP limit is doubled from £30,000 to £60,000.
  • Removal of the “worth having” condition for CSOP.
  • Changes to CSOP rules announced by previous Chancellor in September 2022.
  • Additional compliance work cost expected to be £570,000.
  • Clause 17 removes requirements for employer companies when granting EMI options.
  • The clause clarifies income tax exemption for payments made under the Jobs Growth Wales Plus scheme.
  • The scheme was introduced by the Welsh Government to replace traineeships and Jobs Growth Wales programmes.
  • Participants receive training allowances of up to £30 a week, £55 a week, or national minimum wage depending on the strand.
  • Qualifying care relief thresholds are being increased from £10,000 to £18,140 annually for foster carers.
  • An additional £375 to £450 per week is provided for each person cared for.
  • The measure benefits more than 33,000 individuals who look after an estimated 58,000 foster children.
  • Trustees and personal representatives do not have individual tax allowances.
  • HMRC operates a narrow concession to avoid reporting small amounts of untaxed savings income.
  • Amendment introduces a £500 tax-free amount for trusts with income up to £500, affecting about one in seven estates.
  • For groups of trusts, the limit is reduced to a minimum of £100 per trust.
  • The changes will take around 8,000 trusts and estates out of income tax and reporting.
  • The clause implements the Government’s response to the “Income tax: Low income trusts and estates” consultation conducted by HMRC between April and July 2022.
  • The amendment clarifies that property comprised in a settlement cannot be held for pension purposes under Schedule 1C to TCGA 1992.
  • CIOT raised concerns about the administrative burden on beneficiaries receiving modest amounts of income from trusts.
  • Clauses 30 and 31 were announced on 15 December 2022.
  • Clause 30 will increase receipts by £50 million to £60 million per annum.
  • Clause 31 amends section 92 of the Finance Act 2012.
  • Clause 32 prevents additional tax charges when an insurer's liabilities are written down.
  • Clause 33 extends circumstances for annuity reductions without incurring unauthorised payments charges.
  • Clause 30 addresses a possible tax mismatch in BLAGAB reinsurance rules.
  • Clause 31 resolves uncertainty regarding the scope of section 92 of the Finance Act 2012 for life insurance companies.
  • The Exchequer impact is estimated at £15 million for 2022-23, increasing to £55 million annually from 2024-25.
  • The corporate interest restriction rules have increased corporation tax receipts by over £1 billion annually since April 2017.
  • Five changes protect the Exchequer's position, including preventing groups from reallocating disallowed financing costs and ensuring charities cannot benefit from tax relief for finance costs incurred in exempt activities.
  • Amendment 5 concerns the definition of an insurance company for corporate interest restriction rules, supported by the Association of British Insurers.
  • HMRC, businesses and their advisers have identified issues with current rules.
  • Changes are made to protect the Exchequer and reduce unfair outcomes and administrative burdens on affected businesses.
  • The amendment inserts a new definition in section 494 of TIOPA 2010 regarding insurance companies under foreign laws similar to UK regulations.
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