Last week the Institute responded to the HM Treasury ‘Call for Evidence: Tax Supports for Entrepreneurs’, which was launched on Autumn Budget Day last November. We thank members for their feedback on this important issue. In our submission, the Institute highlights how the draft Finance (No. 2) Bill clauses which implement the Autumn Budget 2025 changes to the various scheme limits for several of the UK’s tax advantaged venture capital schemes exclude specified Northern Ireland (NI) companies due to EU State Aid rules. The submission also highlights that there is a need for a wider review of how the UK tax system could better support all entrepreneurs, and not just those investing in high growth companies.
A specified NI company is currently defined in the Finance (No. 2) Bill as a company that has its registered office in NI which carries on a trade involving a trade in goods, or the generation, transmission, distribution, supply, wholesale trade, or cross-border exchange of electricity. As a result, these NI companies will be unable to benefit from the increased limits to these schemes from April 2026.
This divergence in UK tax policy means that companies in NI who are excluded are disadvantaged when seeking external finance compared to their competitors across the remainder of the UK for no objective reason other than their location. To level the playing field, the Government needs to take the necessary steps to resolve this issue and enable the April 2026 changes to apply to all companies in NI via the discussions through the existing UK-EU structures which underpin the Windsor Framework, followed by an application for State Aid approval.
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