Finance Bill 2024
The Autumn Finance Bill was published on 29 November 2023
The Autumn Finance Bill was published on 29 November 2023
Finance Bill 2024 (official title ‘Finance Bill 2023-24’ and widely referred to as the Autumn Finance Bill) was published on 29 November 2023. Second reading of the Bill in parliament is scheduled for 13 December but, at the time of writing no date had been published for the commencement of the committee stage so we do not yet have any detail on the timetable for the Bill’s remaining passage through parliament. This article provides an overview of the key measures in the Bill, many of which were featured in the Chancellor’s recent Autumn Statement. It should be noted that the National Insurance changes announced at the Autumn Statement will not be legislated via the Finance Bill. They are included in the National Insurance Contributions (Reduction in Rates) Bill which has already completed its passage through the House of Commons and all final stages in the Lords are scheduled for 12 December 2023.
The Finance Bill was, as usual, accompanied by explanatory notes. Some of the more notable measures were covered in the last edition of Tax Matters Digest including ‘full expensing’ being made permanent, the move to a merged R&D tax relief regime and amendments to creative sector tax reliefs.
In this edition of Tax Matters Digest you can find articles on the following Finance Bill measures:
- Amendments to the UK Pillar Two legislation;
- Pensions changes;
- Reforms to the Construction Industry Scheme; and
- Confirmation of the Off-Payroll Working offset
Another measure of note in the Finance Bill relates to Real Estate Investment Trusts (REITs). Two new proposed changes to the REIT rules were announced as part of the documents published for the Autumn Statement and are now included in the Finance Bill. These are in addition to the draft REIT clauses published on L-Day:
- Changing the definition of Holders of Excessive Rights (HoERs), so that investors taxed at a particular rate (or not at all) on Property Income Distributions (PIDs) under the terms of a double tax treaty where that rate is not dependent on the size of holding are not included; and
- Adding Co-ownership Authorised Contractual Schemes (CoACS) that meet the genuine diversity of ownership (GDO) condition or the non-close condition to the list of institutional investors (for the non-close condition).
The first change above will be extremely helpful as it will avoid the need for many overseas investors to fragment their holdings in UK REITs which should provide significant operational cost savings.
