Key Facts

• Clause 23 extends the time limit for payment of capital gains tax to 60 days.
• It affects disposals with completion dates on or after October 27, 2021.
• The change will impact an estimated 75,000 individuals annually.
• The Office for Budget Responsibility expects £80 million to be delayed in revenue due to this measure.
• Clause 25 reforms the tonnage tax regime from April 2022.
• The lock-in period for companies participating in the tonnage tax regime will be reduced from 10 to 8 years.
• HMRC will update guidance to encourage use of the UK flag by making it a significant factor in assessing company value to the UK.
• Clause 26 makes changes to corporation tax rules for hybrids and mismatches involving transparent entities.
• The UK implemented anti-hybrid rules in 2017, following OECD recommendations.
• A consultation was launched at Budget 2020 on this area of legislation.
• Clause 29 allows the Government to lay regulations before Parliament in connection with IFRS 17.
• IFRS 17 is expected to become mandatory for accounting periods starting on or after 1 January 2023, subject to UK endorsement.
• The requirement for life insurers writing basic life assurance and general annuity business to spread acquisition expenses over seven years will be revoked.
• Clause 30 amends corporate loss relief rules to ensure companies in financial distress can access full relief for carried-forward losses during lease renegotiations.
• The clause introduces schedule 6, supporting expansion of the dormant assets scheme to include pensions, insurance, investments and securities sectors.
• Transferred assets into the scheme would not trigger capital gains tax unless an individual later claims ownership.
• Schedule 6 will commence only upon the making of a Treasury order following the passage of the Dormant Assets Bill.