2025 UK Budget

A range of other measures also featured, included increases in certain stamp duty land tax rates from 31 October 2024. Stamp duty land tax (SDLT) The SDLT surcharge on acquisition of an additional dwelling increased from 3 percent to 5 percent from 31 October 2024. The 15 percent rate of SDLT that is charged on the purchase of dwellings costing more than £500,000 by corporate bodies increased by 2 percentage points to 17 percent from the same date. Those who exchanged contracts prior to 31 October 2024 are not affected by these rate increases. Van fuel and benefit charge and car fuel benefit Both of these will increase by the CPI from 6 April 2025. Plastic packaging tax To incentivise businesses to use recycled instead of new plastic in packaging, the Plastic Packaging Tax (PPT) rate for 2025/26 will increase in line with CPI inflation. To support the use of and investment in advanced chemical recycling technologies, businesses will be permitted to use a mass balance approach to evidence recycled content in chemically recycled plastic for the PPT. Landfill tax rates The previously announced adjustment to landfill tax rates from 1 April 2025, which maintains the incentive to manage waste more sustainably, will be implemented in order to maintain the real-terms value of landfill tax rates. To ensure they reflect up-to-date market and economic conditions, the Government will announce future landfill tax rates at the fiscal event immediately before, so that those applicable from 1 April 2026 will be announced at Budget 2025. Land remediation relief A consultation will be launched in Spring 2025 to review the effectiveness of land remediation relief and will consider whether the relief is still meeting its objectives and is good value for money. Rollover of 2021 business tariff suspensions Following feedback from businesses, the Government will maintain tariff-free imports to avoid unnecessary costs for UK businesses. This measure will extend, until June 2026, tariff suspensions on goods ranging from aluminium frames used by UK bicycle manufacturers to ingredients used by UK food producers. Alternative finance tax rules  Alternative finance tax rules will be amended to put certain tax consequences of alternative and conventional financing arrangements on a level playing field. This follows a consultation on tax simplification for alternative finance which the previous Government published a summary of responses to earlier in 2024. The changes apply UK-wide from 30 October 2024 and will be legislated for in Finance Bill 2024/25. Annual Tax on Enveloped Dwellings (ATED) The annual chargeable amounts for the ATED will increase by the September 2024 CPI figure of 1.7 percent in 2025/2026. This will be implemented via a Treasury Order. Private intermittent securities and capital exchange system - stamp taxes exemption The Government is committed to delivering the private intermittent securities and capital exchange system (PISCES), a new innovative market for trading private company shares. In line with that commitment, the Government announced that PISCES transactions will be exempt from Stamp Duty and Stamp Duty Reserve Tax. This exemption will be introduced via a similar timeline to the legislation which will establish the PISCES regulatory framework. Energy profits levy From 1 November 2024, the Energy Profits Levy (EPL) increased by 3 percentage points to 38 percent, the investment allowance was abolished, and the rate of the decarbonisation allowance was set at 66 percent, so that its cash value is maintained. To provide certainty and to support a stable energy transition, the Government will make no additional changes to tax relief available within the EPL regime and the levy will end on 31 March 2030. The Government will legislate for these measures in Finance Bill 2024/25. To support long-term stability and predictability in the oil and gas fiscal regime, the Government also plans to publish a consultation in early 2025 on how the taxation of oil and gas profits will respond to price shocks after the EPL ends. It will also continue to have regular engagement with the sector to understand the evolving context of oil and gas investment, supported by bi-annual fiscal forums. Relief for payments made into a carbon capture usage and storage decommissioning fund The Government will legislate in Finance Bill 2024/25 to provide relief for payments oil and gas companies make into decommissioning funds in relation to assets sold for use in carbon capture usage and storage, maintaining the tax treatment had these assets instead been decommissioned. This legislation will also remove receipts from the sale of these assets from the scope of the EPL. Consultation on scope 3 emissions The Government is consulting on new environmental guidance for assessing end use emissions related to oil and gas projects. This consultation seeks to provide stability for the oil and gas industry, support investment, protect jobs and ensure a fair, orderly and prosperous transition in the North Sea in line with climate and legal obligations. Climate change levy 2026/27  The main rates of the climate change levy (CCL) for gas, electricity, and solid fuels will increase in line with the Retail Price Index in 2026/27. The main rate for liquefied petroleum gas will continue to be frozen and the reduced rates of the CCL will remain at an unchanged fixed percentage of the main rates. Carbon price support 2026/27  Carbon price support rates in Great Britain will remain at a level equivalent to £18 per tonne of CO2 in 2026/27. Advance tax certainty for major projects A consultation will be launched in Spring 2025 to develop a new process that will give investors in major projects increased tax certainty in advance.  

Last week’s Autumn Budget and the first for new Chancellor of the Exchequer Rachel Reeves featured £40 billion in tax rises and was announced with the objective of repairing public finances because of £22 billion of “in-year pressures” whilst at the same time establishing a robust foundation for economic growth. However, the April 2025 changes in employer National Insurance Contributions (NICs) will increase the cost of employment for many businesses when combined with the increase in the national minimum and living wage. Smaller employers will be somewhat protected as a result of changes from the same date to the employer NICs employment allowance. The rates of capital gains tax were also increased from Budget Day with the Office for Budget Responsibility (OBR) estimating that this will raise an additional £2.5 billion. And buried in the Budget publications was the news that Making Tax Digital (MTD) for income tax will be extended to unincorporated businesses and landlords with turnover over £20,000 by the end of the current Parliament the precise timing for which will be set out at a future fiscal event. Chartered Accountants Ireland will be challenging the Government on this reduction in the MTD exemption limit. A range of changes to inheritance tax (IHT) were also announced with the aim of ensuring that the wealthiest estates will bear the greatest burden with the scope of agricultural and business property relief to be limited and the news that unused pension funds and death benefits payable from a pension into a person’s estate will be within the scope of IHT in future. The rate of stamp duty land tax on acquisitions of certain residential property in England and Northern Ireland was also increased from 31 October 2024. On the business side, the publication of the previously announced Corporate Tax Roadmap should provide businesses with more certainty and once again confirms that no changes will be made to the current rates of corporation tax, amongst other business taxes areas. The UK’s CT rate is currently the lowest in the G7. A response was also published to the consultation on potential regulation of tax advisers which the Institute responded to earlier this year. The consultation response sets out that from April 2026 the Government will mandate registration of tax advisers who interact with HMRC on behalf of clients. A further consultation will also be published on tackling rogue tax advisers. However, the consultation response is silent on any new measures to regulate the UK tax agent market. HMRC has sent a more detailed email setting out information on the consultation response and is planning a round table meeting later this month to discuss the way forward in more detail. Chartered Accountants Ireland will be in attendance. And finally, the Northern Ireland Executive will receive an additional £1.5 billion in funding in 2025/26 through the operation of the Barnett formula. Read the Institute’s Press Release reacting to the Autumn Budget 2024. The analysis herein is based on the publications of HMRC and HM Treasury. A more detailed analysis of the tax announcements features in the remainder of today’s UK section and will continue in next Monday’s edition of Chartered Accountants Tax News. The Institute’s UK Autumn Budget 2024 page also contains a range of resources. HMRC has also sent an email on the Budget announcements and one specifically for agents. An overview of all the tax legislation and rates announced has also been published.

Some capital gains tax (CGT) rates were increased from Budget Day and the rate of both Business Asset Disposal Relief (BADR), and Investors’ Relief (IR) will be increased in two stages starting from April 2025. A range of significant changes will also be made to inheritance tax (IHT) which will see IHT extended to death benefits payable from a pension into a deceased’s estate, in addition to changes to both business property relief (BPR) and agricultural property relief (APR). Previously announced changes, including the abolition of the CGT and income tax non-domicile regime from 6 April 2025 which will be replaced with a new residence-based regime, were also confirmed.  The territoriality of IHT will also move to a residence-based regime as planned. CGT rate increases For disposals made on or after 30 October 2024, the lower rate of CGT increased from 10 percent to 18 percent, whilst the higher rate increased from 20 percent to 24 percent.  These new rates align with the residential property CGT rates which remain unchanged. Carried interest is a performance-related reward received by a small population of fund management executives. From April 2026, carried interest will be taxed fully within the income tax framework, with bespoke rules to reflect its unique characteristics and a 72.5 percent multiplier applied to qualifying carried interest that is brought within charge. As an interim step, the two CGT rates for carried interest will both increase to 32 percent from 6 April 2025. The Government will also consult on introducing further conditions of access into the regime. CGT BADR and IR As a result of the newly increased rates of CGT, BADR and IR will both increase from 10 percent to 14 percent from 6 April 2025 and to 18 percent from 6 April 2026 to allow business owners time to adjust to the changes. The lifetime limit (LL) for BADR will remain at £1 million. In contrast, the LL for IR reduced from £10 million to £1 million for all qualifying disposals made on or after 30 October 2024. Chartered Accountants Ireland has previously questioned the policy need for IR and its high lifetime limit. The Government has also stated that it is committed to creating a positive environment for entrepreneurship and will work with leading entrepreneurs and venture capital firms on how policy supports that, including the role of existing tax schemes. A commitment was also made to make it easier for start‑ups and scale‑ups to access external sources of financial support. This includes, as already legislated for, extending the Enterprise Investment Scheme and Venture Capital Trust schemes to 2035. Non-UK domiciled status As previously announced, the non-UK domiciled regime, and thus the remittance basis of taxation for CGT and income tax, is being abolished from 6 April 2025. The remittance basis will be replaced with a residence-based regime. Individuals who opt-in to the regime will not pay UK tax on foreign income and gains (FIG) for the first four years of tax residence. Current and past remittance basis users will be able to rebase personally held foreign assets to the assets 5 April 2017 market value on a disposal, subject to certain conditions. Overseas Workday Relief will be retained and reformed, with the relief extended to a four-year period and the need to keep the income offshore removed. The amount claimed annually will be limited to the lower of £300,000 or 30 percent of the employee’s net employment income. The Temporary Repatriation Facility (TRF) is being extended from two to three years until 5 April 2028, expanding the scope to offshore structures, and simplifying the mixed fund rules to encourage individuals to spend and invest their FIG in the UK. The TRF will enable the individual to designate and remit at a reduced rate of tax any foreign income and gains which arose prior to 6 April 2025. This includes unattributed foreign income and gains held within trust structures IHT measures and reliefs IHT thresholds (£325,000 nil rate band, £175,000 residence nil rate band, and the £2 million residence nil rate band taper) will remain frozen at their current levels for a further two years beyond April 2028 until April 2030. Significant reforms to both APR and BPR were also announced. From April 2026, the first £1 million of combined qualifying agricultural and business assets will be entitled to 100 percent relief from IHT with the rate of relief reduced to 50 percent for amounts in excess of £1 million. The rate of BPR will also be reduced to 50 percent for shares designated as “not listed” on the markets of a recognised stock exchange, such as AIM. However, from 6 April 2025 the scope of APR will be extended to land managed under an environmental agreement with, or on behalf of, the UK government, devolved governments, public bodies, local authorities, or approved responsible bodies. As previously announced, the new IHT residence-based regime will commence from 6 April 2025. This includes ending the use of offshore trusts to shelter assets from IHT and scrapping the planned 50 percent tax reduction for foreign income in the first year of the new regime. From 6 April 2027 unused pension funds and death benefits payable from a pension into a person’s estate will be subject to IHT purposes. In doing so the Government aims to restore the principle that pensions should not be a vehicle for the accumulation of capital sums for the purposes of inheritance. £52 million is also being invested to digitalise the IHT service from 2027/28 with the aim of providing a modern, easy-to-use system for making returns and paying IHT.