Finance Bill: Update on progress

The Public Bill Committee stage for Finance Bill 2025-26 (full name Finance (No.2) Bill 2024-26) kicked off on 27 January 2026 and, as usual, the Committee met on Tuesdays and Thursdays to scrutinise all parts of the Bill that were not covered by the Committee of the whole House.

On 21 and 23 January, a number of government amendments were tabled on a variety of measures and updated explanatory notes have also been published to take account of some of these amendments. The government amendments are to the following parts of the Bill:

• Pillar Two (Schedule 8) – mainly to extend the deadline for making both long term and annual multinational top-up tax elections from the date the information return or overseas return notification for the period is due, to one year from that date. This extended deadline only applies to elections that are made in respect of accounting periods that end before 31 December 2025;
  
• Umbrella companies (clause 24) – mainly to allow disclosure to parties jointly and severally liable to pay PAYE under the umbrella company rules;
• Loan charge (clauses 25 and 27) – mainly to clarify the parameters of the loan charge settlement scheme such that where a settlement offer is made to a person who is not an individual, the calculation of the settlement amount can be adapted;
• Vaping products duty (clause 138) – amendments to the commencement and transitional provisions, mainly to clarify that criminal offences can apply to vaping products produced or imported before the Act is passed or regulations are made;
  
• Carbon border adjustment mechanism (CBAM) (clause 146) – to clarify that scheme years in which there were no sectoral emissions should be ignored when determining the baseline free allocation percentage in relation to a CBAM sector; and
  
• Tax adviser registration (clause 225 and Schedule 21) - the amendments confirm that tax agent eligibility conditions would only be breached where a penalty for non-disclosure under the Disclosure of Tax Avoidance Schemes (DoTAS) or Disclosure of Avoidance Schemes for VAT and Other Indirect Taxes (DASVOIT) regimes remains unpaid by the due date, rather than on the imposition of the non-disclosure penalty.