Finance (No. 2) Act 2023

1. Introductory Text

2. Part 1 Income tax, corporation tax and capital gains tax

   1. Income tax charge, rates etc

      1. 1. Income tax charge for tax year 2023-24

      2. 2. Main rates of income tax for tax year 2023-24

      3. 3. Default and savings rates of income tax for tax year 2023-24

      4. 4. Freezing starting rate limit for savings for tax year 2023-24

   2. Corporation tax charge and rates

      1. 5. Charge and main rate for financial year 2024

      2. 6. Standard small profits rate and fraction for financial year 2024

   3. Capital allowances

      1. 7. Temporary full expensing etc for expenditure on plant or machinery

      2. 8. Annual investment allowance to remain at £1M beyond temporary period

      3. 9. First-year allowance for expenditure on electric vehicle charge points

   4. Other reliefs relating to businesses

      1. 10. Relief for research and development

      2. 11. Treatment of profits from patents etc: small profits rate of corporation tax

      3. 12. Energy (oil and gas) profits levy: de-carbonisation allowance

      4. 13. Museums and galleries exhibition tax relief: extension of sunset date

      5. 14. Extension of the temporary increase in theatre tax credit etc

      6. 15. Seed enterprise investment scheme: increase of limits etc.

   5. Reliefs for employees

      1. 16. CSOP schemes: share value limit and share class

      2. 17. Enterprise management incentives: restricted shares and declarations

   6. Pensions

      1. 18. Lifetime allowance charge abolished

      2. 19. Certain lump sums to be taxed at marginal rate

      3. 20. Annual allowance increased

      4. 21. Money purchase annual allowance

      5. 22. Annual allowance: tapering

      6. 23. Modification of certain existing transitional protections

      7. 24. Collective money purchase arrangements

      8. 25. Relief relating to net pay arrangements

   7. Social security

      1. 26. Payments under Jobs Growth Wales Plus

      2. 27. Power to clarify tax treatment of devolved social security benefits

   8. Foster carers etc

      1. 28. Qualifying care relief: increase in individual’s limit

   9. Estates in administration and trusts

      1. 29. Estates in administration and trusts

   10. Provisions relating to insurance

       1. 30. Transfer of basic life assurance and general annuity business

       2. 31. Certain re-insurance sums not to count as deemed I-E receipts

       3. 32. Insurers in difficulties: write-down orders for corporation tax purposes

       4. 33. Insurers in difficulties: write-down orders in case of pension schemes

   11. Miscellaneous corporation tax matters

       1. 34. Corporate interest restriction

       2. 35. Investment vehicles

   12. International matters

       1. 36. Share exchanges involving non-UK incorporated close companies

       2. 37. Records relating to transfer pricing

       3. 38. Double taxation relief: foreign nominal rates

   13. Chargeable gains

       1. 39. Payments to farmers under the lump sum exit scheme etc

       2. 40. Contracts completed after ordinary notification period

       3. 41. Separated spouses and civil partners

       4. 42. Carried interest: election to pay tax as scheme profits arise

       5. 43. Relief on disposal of joint interests in land

3. Part 2 Alcohol Duty

   1. Chapter 1 Charge to alcohol duty

      1. Alcoholic products

         1. 44. Meaning of “alcoholic product”

         2. 45. Alcoholic strength

         3. 46. Categories of alcoholic products: regulations

      2. Charge and rates

         1. 47. Alcohol duty: charge

         2. 48. Rates

         3. 49. Excise duty point and payment

   2. Chapter 2 Draught relief

      1. 50. Qualifying draught products: reduced rates

      2. 51. Alcoholic products qualifying for draught relief

      3. 52. Repackaging qualifying draught products

      4. 53. Repackaging in contravention of section 52 (2)

   3. Chapter 3 Small producer relief

      1. Main provisions

         1. 54. Small producer relief: discounted rates

         2. 55. Small producer alcoholic products

         3. 56. Small production premises

         4. 57. “Alcohol production amount” etc

         5. 58. Exclusions

         6. 59. Duty discount for small producer alcoholic products

         7. 60. Assessments where incorrectly low rate of alcohol duty applied

      2. Mergers and demergers

         1. 61. Mergers: general provisions

         2. 62. Modified “small production premises” test

         3. 63. Modified duty discount

         4. 64. Adjusted post-merger amount

         5. 65. Early termination of merger transition period

         6. 66. Subsequent mergers

         7. 67. Simultaneous mergers

         8. 68. Demergers

      3. Interpretation of Chapter 3

         1. 69. “Producer”, “production premises”, “group premises” etc

         2. 70. Connected persons

         3. 71. Index of defined expressions: Chapter 3

   4. Chapter 4 Other reliefs and exemptions

      1. General

         1. 72. Exemption: production for personal consumption

         2. 73. Research and experiments

         3. 74. Spoilt alcoholic products

         4. 75. Alcoholic ingredients

      2. Spirits

         1. 76. Imported medical articles

         2. 77. Flavourings

         3. 78. Authorised use for certain purposes

         4. 79. Imported goods not for human consumption

         5. 80. Restrictions on use of certain articles

      3. Remission and repayment

         1. 81. Further provision about remission and repayment

   5. Chapter 5 Regulated activities and approvals

      1. 82. Approval requirement: producers

      2. 83. Supplementary provision about approvals

      3. 84. Exemption: production for personal consumption

      4. 85. Exemption: research and experiments

      5. 86. Mixing alcoholic products

      6. 87. Post-duty point dilution of alcoholic products

      7. 88. Alcoholic products regulations

      8. 89. Penalties and forfeiture

   6. Chapter 6 Denatured alcohol

      1. 90. Denatured alcohol

      2. 91. Licence to manufacture and deal wholesale in denatured alcohol

      3. 92. Regulations relating to denatured alcohol

      4. 93. Penalties and forfeiture

      5. 94. Defaults in respect of denatured alcohol: possession of excess alcoholic products

      6. 95. Defaults in respect of denatured alcohol: supply and use of denatured alcohol

      7. 96. Inspection of premises etc

      8. 97. Prohibition of use of denatured alcohol etc as beverage or medicine

   7. Chapter 7 Wholesaling of controlled alcoholic products

      1. 98. Definitions

      2. 99. Further provision relating to definitions

      3. 100. Approval to carry on controlled activity

      4. 101. The register of approved wholesalers

      5. 102. Regulations relating to approval, registration and controlled activities

      6. 103. Restriction on buying controlled alcoholic products wholesale

      7. 104. Offences

      8. 105. Penalties

      9. 106. Groups

      10. 107. Index of defined expressions: Chapter 7

   8. Chapter 8 Supplementary

      1. 108. Reviews and appeals

      2. 109. Forfeiture: supplementary provision

      3. 110. Removal of goods: application of section 95 of CEMA 1979

      4. 111. Drawback

      5. 112. Duty stamps

   9. Chapter 9 repeals, further amendments and transitional provisions

      1. Repeals and further amendments

         1. 113. Repeals

         2. 114. Minor and consequential amendments

      2. Transitional provision

         1. 115. Temporary provision: wine

         2. 116. Temporary provision: cider

   10. Chapter 10 Final provisions

       1. 117. Interpretation of this Part

       2. 118. Regulations: supplementary and general

       3. 119. Regulations: procedure

       4. 120. Commencement

4. Part 3 Multinational top-up tax

   1. Chapter 1 Introduction and charge

      1. 121. Introduction to multinational top-up tax

      2. 122. Chargeable persons

      3. 123. Amount charged by reference to “top-up amounts”

      4. 124. How to calculate top-up amounts and attribute them

      5. 125. Administration of multinational top-up tax

   2. Chapter 2 Qualifying multinational groups and their members

      1. Multinational groups

         1. 126. Meaning of “multinational group” and “ultimate parent”

         2. 127. Excluded entities

      2. Responsible members

         1. 128. Responsible members

      3. Qualifying multinational groups

         1. 129. Qualifying multinational groups

         2. 130. Change in composition of multinational group

         3. 131. Whether de-merged groups meet the revenue threshold

   3. Chapter 3 Effective tax rate of members of a multinational group in a territory

      1. 132. Effective tax rate

   4. Chapter 4 Calculation of adjusted profits of members of a multinational group

      1. Adjusted profits of a member of a multinational group

         1. 133. Adjusted profits of a member of a multinational group

         2. 134. Underlying profits as determined for statements of ultimate parent

         3. 135. Underlying profits of permanent establishments

         4. 136. Underlying profits accounts

         5. 137. No amounts outside of profit and loss account to be included

      2. Adjustments of underlying profits

         1. 138. Profits adjusted to be before tax

         2. 139. Profits adjusted to be profits before consolidation adjustments to eliminate intragroup transactions

         3. 140. Profits adjusted to be profits before certain purchase accounting adjustments

         4. 141. General exclusion of dividends

         5. 142. Excluded equity gain or loss

         6. 143. Included revaluation method gain or loss

         7. 144. Adjustments for asymmetric foreign currency income and losses

         8. 145. Exclusion of expenses for illegal payments, fines and penalties

         9. 146. Adjustment for changes in accounting policies and prior period errors

         10. 147. Accrued pension expense

         11. 148. Treatment of qualifying refundable tax credits

         12. 149. Arm’s length requirement for certain transactions

         13. 150. Transactions between members of a multinational group: differences with accounting for tax

         14. 151. Adjustments for companies in distress

         15. 152. Adjustments where life assurance business carried on

         16. 153. Exclusion of certain insurance reserve movement expense

         17. 154. Exclusion of qualifying intra-group financing arrangement expenses

         18. 155. Qualifying tier one capital

         19. 156. Exclusion of international shipping profits

         20. 157. Core international shipping profits

         21. 158. Ancillary international shipping profits

      3. Adjustments only applicable to permanent establishments

         1. 159. Permanent establishment income and expense attribution

         2. 160. Attribution of losses between permanent establishment and main entity

      4. Elections to treat certain amounts differently

         1. 161. Election to use realisation principle

         2. 162. Election to reflect deductions for stock-based compensation

         3. 163. Election to spread certain capital gains over five years

         4. 164. Election to exclude intra-group transactions

         5. 165. Election to have excluded equity gains and losses included

         6. 166. Election in relation to hedging currency risk in ownership interests

      5. Dealing with transparency and entities subject to qualifying dividend regime

         1. 167. Underlying profits of hybrids

         2. 168. Underlying profits of transparent and reverse hybrid entities

         3. 169. Certain non tax resident entities to be treated as flow-through entities

         4. 170. Adjustments for ultimate parent that is a flow-through entity

         5. 171. Ultimate parent subject to qualifying dividend regime

         6. 172. Application of section 171 to members in the same territory as the ultimate parent

   5. Chapter 5 Covered tax balance

      1. Amount of covered taxes

         1. 173. Covered taxes

         2. 174. Amount of covered tax balance

         3. 175. Amounts excluded from covered tax balance

         4. 176. Amounts to be reflected in covered tax balance

      2. Allocation of covered taxes

         1. 177. Permanent establishments

         2. 178. Reallocation of tax expense

         3. 179. Controlled foreign company tax regimes

         4. 180. Blended CFC regimes

         5. 181. Distributions from other members of a group

      3. Dealing with deferred tax assets etc

         1. 182. Total deferred tax adjustment amount

         2. 183. Qualifying foreign tax credits (substitute loss carry forward assets)

         3. 184. Recaptured deferred tax liabilities

         4. 185. Inclusion of existing deferred tax assets and liabilities on entry into regime

         5. 186. Deferred tax assets recorded at less than minimum rate

         6. 187. Election for losses to be treated as special loss deferred tax assets

         7. 188. Further provision about elections under section 187

      4. Eligible distribution tax systems: deemed taxes

         1. 189. Deemed distribution tax election

         2. 190. Deemed distribution tax amount

         3. 191. Reduction of recapture amount

         4. 192. Recalculation where member leaves the group

   6. Chapter 6 Calculation of top-up amounts

      1. 193. Calculation of top-up amounts

      2. 194. Total top-up amount for a territory

      3. 195. Substance based income exclusion

      4. 196. Eligible payroll costs

      5. 197. Eligible tangible asset amount

      6. 198. Eligible payroll costs and eligible tangible asset amount: permanent establishments and flow-through entities

      7. 199. Election to treat total top-up amount as nil

   7. Chapter 7 Allocating top-up amounts to responsible members

      1. 200. Top-up amounts multiplied by inclusion ratio

      2. 201. Inclusion ratio

   8. Chapter 8 Further adjustments

      1. Covered taxes less than nil

         1. 202. Covered taxes balance less than nil when members in a territory have a profit

         2. 203. Additional top-up amounts where covered taxes less than expected

         3. 204. Allocation of collective additional amount under section 203 to members

         4. 205. Election to carry forward and reduce collective additional amount

      2. Additional top-up amounts on recalculations

         1. 206. Additional top-up amounts where recalculations required

         2. 207. Allocation of collective additional amounts under section 206 to members

      3. Restructuring of groups

         1. 208. Member joining or leaving multinational group

         2. 209. When transfer of controlling interest treated as acquisition of assets and liabilities

         3. 210. Transfer of assets or liabilities from a member of a multinational group

         4. 211. Transfer of assets or liabilities to a member of a multinational group

         5. 212. Meaning of “qualifying reorganisation”

      4. Elections in relation to investment entities

         1. 213. Investment entity tax transparency election

         2. 214. Taxable distribution method election

         3. 215. Undistributed income amount

      5. Other adjustments

         1. 216. Election where assets and liabilities adjusted to fair value for tax purposes

         2. 217. Post filing adjustments of covered taxes

         3. 218. Effect of rate changes to deferred tax expense

         4. 219. Adjustment where covered taxes not paid

   9. Chapter 9 Special provision for investment entities, joint venture groups and minority-owned members

      1. Investment entities

         1. 220. Top-up amount of investment entity

         2. 221. Substance based income exclusion for investment entity

         3. 222. Investment entity effective tax rate

         4. 223. Adjustments

         5. 224. Additional top-up amounts of investment entities

         6. 225. Attribution of top-up amounts and additional top-up amounts to responsible member

      2. Joint venture group

         1. 226. Joint venture group

         2. 227. Application of Part to joint venture groups

      3. Minority owned members

         1. 228. Minority owned members

      4. Application to multi-parent groups

         1. 229. Multi-parent groups

   10. Chapter 10 Definitions etc

       1. Introduction

          1. 230. Meaning of terms and concepts used in this Part

       2. Meaning of “entity” etc

          1. 231. Meaning of entity

          2. 232. Permanent establishments treated as entities

          3. 233. Treatment of protected cell companies

          4. 234. Governmental, international and non-profit entities

          5. 235. Pension funds and pension services entities

          6. 236. Investment funds and investment entities

          7. 237. Intermediate and partially-owned parent members

          8. 238. Tax transparency of entities

       3. Provision relating to location of entities

          1. 239. Location of entities

          2. 240. Location of flow-through entities and permanent establishments

          3. 241. Pillar Two territories

       4. Ownership of entities

          1. 242. Ownership interests and controlling interests

          2. 243. Calculating percentage ownership interests of a specific entity or individual

          3. 244. Calculating percentage ownership interests of a class

          4. 245. Calculating percentage ownership interests: excluded entities

          5. 246. Calculating percentage direct and indirect ownership interests

          6. 247. Timing of transfers of interests

          7. 248. Exclusion of indirect interests held through ultimate parent

       5. Financial statements and accounting period

          1. 249. Consolidated financial statements

          2. 250. Acceptable accounting standards

          3. 251. Accounting periods

       6. Miscellaneous

          1. 252. Application to sovereign wealth funds

          2. 253. Disqualified and qualified refundable imputation taxes

          3. 254. Use of currency

          4. 255. Pillar Two rules

          5. 256. Qualifying domestic top-up tax

          6. 257. Qualifying undertaxed profits tax

          7. 258. Meaning of “connected”

          8. 259. Other definitions

   11. Chapter 11 General and miscellaneous provision

       1. 260. Transitional provision

       2. 261. Index of defined expressions

       3. 262. Power to amend to ensure consistency with Pillar Two

       4. 263. Regulations

       5. 264. Multinational top-up tax to apply from 31 December 2023

5. Part 4 Domestic top-up tax

   1. Chapter 1 Introduction

      1. 265. Introduction to domestic top-up tax

      2. 266. Qualifying entities

      3. 267. DTT excluded entities

      4. 268. Permanent establishments

   2. Chapter 2 Charge to domestic top-up tax

      1. 269. Chargeable persons

      2. 270. Amount charged

      3. 271. Election to make one member of a group liable for amounts charged

   3. Chapter 3 Application of multinational top-up tax provisions

      1. 272. Determining top-up amounts of entity that is a member of a group

      2. 273. Determining top-up amounts of entity that is not a member of a group

      3. 274. Application of section 262

      4. 275. Application of Schedule 14

      5. 276. Application of transitional provision

      6. 277. Index of defined expressions

      7. 278. Domestic top-up tax to apply from 31 December 2023

6. Part 5 Electricity generator levy

   1. Introduction and charge

      1. 279. Charge on exceptional generation receipts

      2. 280. Key concepts (generating undertaking etc)

      3. 281. Benchmark amount

   2. Calculation of exceptional generation receipts

      1. 282. Attribution of generation

      2. 283. Generation receipts

      3. 284. Allowable costs

      4. 285. Exceptional generation fuel costs

      5. 286. Exceptional revenue sharing costs

   3. Groups, partnerships and joint ventures

      1. 287. Groups

      2. 288. Lead member of a group and its qualifying periods

      3. 289. Liability of members of groups

      4. 290. Election for members with significant minority shareholding to pay levy

      5. 291. Qualifying partnerships

      6. 292. Qualifying joint ventures

   4. Attribution and surrender of amounts: joint ventures and significant minority shareholders

      1. 293. Non-chargeable amounts of joint venture to be attributed to participants

      2. 294. Generation acquired and supplied by JV participants

      3. 295. Arrangements that reflect receipts (JV participants)

      4. 296. Generation acquired and supplied by significant minority shareholders

      5. 297. Arrangements that reflect receipts (significant minority shareholders)

      6. 298. Surrender of shortfalls

      7. 299. Amount that may be surrendered and use of that amount

   5. Treatment of company as transparent as alternative to attribution and surrender

      1. 300. Election to treat certain companies as transparent

      2. 301. Effect of company being transparent

   6. Management and administration

      1. 302. General application of corporation tax administration

      2. 303. Company tax returns

      3. 304. Requirement to provide information about payments

      4. 305. Claims to shortfall amounts

      5. 306. Application of Part 5A of TMA 1970 and Instalment Payments Regulations

   7. Supplemental

      1. 307. Application of Part 5 of CTA 2010 for the purposes of determining interests

      2. 308. Anti-avoidance

      3. 309. Information sharing

      4. 310. Interaction of electricity generator levy with corporation tax

      5. 311. Regulations under this Part

      6. 312. Minor definitions relating to electricity market

      7. 313. Definitions in this Part

7. Part 6 Other taxes

   1. Stamp duty land tax

      1. 314. Transactions funded with the assistance of a public subsidy

   2. Value added tax

      1. 315. Deposit schemes

   3. Import duty

      1. 316. Dumping, subsidisation and safeguarding remedies

      2. 317. Rulings as to method of valuation of goods

      3. 318. Discharging goods from free-circulation procedure subject to guarantee

   4. Fuel duties

      1. 319. Excepted machines etc

   5. Tobacco products duty

      1. 320. Rates of tobacco products duty

   6. Soft drinks industry levy

      1. 321. Flavour concentrates

   7. Air passenger duty

      1. 322. New bands and rates

      2. 323. Northern Ireland rates

   8. Vehicle taxes

      1. 324. Rates of vehicle excise duty

      2. 325. Reform of HGV road user levy

      3. 326. End of exempt period for HGV road user levy

   9. Environmental taxes

      1. 327. Rates of landfill tax

      2. 328. Rates of climate change levy

      3. 329. Rate of plastic packaging tax

      4. 330. Aggregates levy: exemptions and exploitation

8. Part 7 Miscellaneous and final

   1. Freeports and investment zones

      1. 331. Designation of sites

      2. 332. Sunset date for reliefs

   2. Administration

      1. 333. Right to repayment of income tax to be inalienable

      2. 334. Late payment interest on value added tax

      3. 335. Penalties for failure to pay value added tax

      4. 336. VAT credits: repayment interest due where evidence not provided

      5. 337. Insurance premium tax: power to make regulations about notifications

      6. 338. Penalties for failure to make payments of plastic packaging tax on time

   3. Management of customs and excise

      1. 339. Approval of aerodromes

      2. 340. Approved aerodromes: minor and consequential amendments

      3. 341. Temporary approvals etc

   4. Conditionality

      1. 342. Licensing authorities: requirements to give or obtain tax information

      2. 343. Section 342: consequential amendments

   5. Charities and community amateur sports clubs

      1. 344. Definition of “charity” restricted to UK charities

      2. 345. Definition of “community amateur sports club” restricted to UK clubs

   6. Homes for Ukraine Sponsorship Scheme

      1. 346. Exemptions from tax

   7. Office of Tax Simplification

      1. 347. Abolition of the Office of Tax Simplification

   8. The dormant assets scheme

      1. 348. Pension benefits and inheritance tax

   9. Other

      1. 349. International arrangements for exchanging information

      2. 350. Payment of unclaimed money in court into the Consolidated Fund

      3. 351. Financial sanctions regulations: prohibition on certain payments by HMRC

      4. 352. Communications data

   10. Final

       1. 353. Interpretation

       2. 354. Short title

9. Schedules

   1. Schedule 1

      Relief for research and development

      1. Part 1 Claim notifications

         1. 1. Requirement to make claim notifications in relation to certain R&D claims

         2. 2. (1) Part 13 of CTA 2009 (additional relief for expenditure...

      2. Part 2 R&D expenditure on data and cloud computing

         1. 3. Relief for R&D expenditure on data and cloud computing

         2. 4. Relief for R&D expenditure on data and cloud computing: consequential amendments

         3. 5. In Chapter 6A of Part 3 (trade profits: R&D expenditure...

         4. 6. In Part 13 (additional relief for expenditure on R&D)—

         5. 7. In Schedule 2 (transitionals and savings), in Part 15 (research...

         6. 8. In Schedule 4 (index of defined expressions), in both places...

         7. 9. In section 357BLB of CTA 2010 (qualifying expenditure on relevant...

      3. Part 3 Amendments to Schedule 18 to FA 1998

         1. 10. Introduction

         2. 11. Power of HMRC to collect overpaid R&D tax relief or expenditure credit

         3. 12. Time limits for R&D claims

         4. 13. Requirement to provide additional information in relation to R&D claims

         5. 14. Power of HMRC to remove R&D claims made in error from return

      4. Part 4 Miscellaneous amendments

         1. 15. Amendment of CTA 2009

         2. 16. R&D tax relief: circumstances in which enterprises are treated as SMEs

         3. 17. Accounts treated as prepared on going concern basis

         4. 18. Meaning of expenditure incurred on payments

      5. Part 5 Commencement

         1. 19. The amendment made by paragraph 13 of this Schedule has...

         2. 20. The amendments made by the remaining provisions of this Schedule...

   2. Schedule 2

      Estates in administration and trusts

      1. Part 1 Estates in administration

         1. Chapter 1 Income tax

            1. 1. The applicable rate for grossing up basic amounts of estate income

            2. 2. The applicable rate for grossing up for determining shares in an estate in the final tax year

            3. 3. Income from stock dividends etc treated as bearing income tax at 0%

            4. 4. Income treated as dividend income and savings income

            5. 5. Order in which basic amounts are treated as paid from aggregate income

         2. Chapter 2 Corporation tax

            1. 6. The applicable rate for grossing up basic amounts of estate income

            2. 7. The applicable rate for grossing up for determining shares in an estate in the final tax year

            3. 8. Income from stock dividends etc treated as bearing income tax at 0%

            4. 9. Order in which basic amounts are treated as paid from aggregate income

      2. Part 2 Low income trusts and estates

         1. Chapter 1 Income tax

            1. 10. Low income estates and trusts: tax liability of personal representatives and trustees

            2. 11. Low income estates: tax liability of beneficiaries

         2. Chapter 2 Corporation tax

            1. 12. Low income estates: tax liability of beneficiaries

      3. Part 3 Rate of tax charged on trustees’ first slice of trust rate income: income tax

         1. 13. (1) ITA 2007 is amended as follows.

      4. Part 4 Commencement

         1. 14. (1) The amendments made by this Schedule have effect as...

   3. Schedule 3

      Corporate interest restriction etc.

      1. Part 1 Amendments to TIOPA 2010

         1. 1. Introduction

         2. 2. Tax-interest expense amounts of a company: charities

         3. 3. First period of account where new holding company

         4. 4. In section 400A (carry forward of excess debt cap: new...

         5. 5. Amounts not brought into account in determining a company’s tax-EBITDA

         6. 6. “Relevant expense amount” and “relevant income amount”

         7. 7. In section 412 (interpretation of section 411), in subsection (7),...

         8. 8. Adjusted net group-interest expense: debits referable to times before UK property business etc carried on

         9. 9. Adjusted net group-interest expense: debits in respect of pre-trading expenditure

         10. 10. Qualifying net group-interest expense: meaning of “equity notes”

         11. 11. In section 415 (qualifying net group-interest expense: interpretation), for subsection...

         12. 12. Capitalised interest brought into account for tax purposes in accordance with GAAP

         13. 13. Interest allowance (non-consolidated investment) election: “non-consolidated associate”

         14. 14. Public infrastructure

         15. 15. (1) Section 436 (meaning of “qualifying infrastructure activity”) is amended...

         16. 16. After section 438 insert— Application of section 438: certain creditors...

         17. 17. Partnerships and other transparent entities

         18. 18. Investments held by investment managers

         19. 19. Determining the worldwide group: “non-consolidated subsidiary” and “consolidated subsidiary”

         20. 20. Appointment of a reporting company by Revenue and Customs

         21. 21. Revised interest restriction return

         22. 22. (1) Paragraph 29 of Schedule 7A (penalty for failure to...

         23. 23. Enquiry into interest restriction return

         24. 24. Determinations by officers of Revenue and Customs

         25. 25. Consequential claims to company tax returns

      2. Part 2 Other amendments

         1. 26. Penalties for errors: CIR alterations to be ignored in calculating potential lost revenue

         2. 27. Disapplication of carry forward rule for deficits

         3. 28. Defined expressions used in Part 10 of TIOPA 2010: “insurance company”

         4. 29. Determining the worldwide group: consequential amendment

      3. Part 3 Parts 1 and 2: commencement and transitional provision

         1. 30. Except as provided in paragraphs 31 to 35, the amendments...

         2. 31. The amendments made by paragraph 5(1) and (3) have effect...

         3. 32. (1) The amendments made by paragraph 8 have effect for...

         4. 33. The amendments made by paragraph 9 have effect for periods...

         5. 34. The amendments made by paragraphs 2, 14 to 16, and...

         6. 35. The amendment made by paragraph 20 has effect in relation...

         7. 36. References in this Part of this Schedule to periods of...

      4. Part 4 Tax treatment of financing costs and income

         1. 37. This Part of this Schedule applies if—

         2. 38. (1) Part 7 of TIOPA 2010 has effect in relation...

         3. 39. For the purposes of this Part (and of the application...

         4. 40. (1) References in this Part to any provision of Part...

   4. Schedule 4

      Investment vehicles

      1. Part 1 UK property rich collective investment vehicles etc

         1. 1. Genuine diversity of ownership

      2. Part 2 Real estate investment trusts

         1. 2. Amendment of CTA 2010

         2. 3. REITs involving single commercial property

         3. 4. 3-year development rule

         4. 5. Genuine diversity of ownership

         5. 6. Amendment of the Real Estate Investment Trusts (Assessment and Recovery of Tax) Regulations 2006

      3. Part 3 Qualifying asset holding companies

         1. 7. Amendment of Schedule 2 to FA 2022

         2. 8. Securitisation companies unable to be QAHCs

         3. 9. Beneficial entitlement held only through QAHCs

         4. 10. Determining relevant interests

         5. 11. Dealing with bodies corporate without share capital

         6. 12. Genuine diversity of ownership

         7. 13. Investment strategy condition

         8. 14. Disposal of derivatives where underlying subject matter is shares

         9. 15. Alternative finance arrangements

   5. Schedule 5

      Records relating to transfer pricing

      1. Part 1 Amendments relating to corporation tax

         1. 1. Records to be kept for the purposes of corporation tax

         2. 2. Assessments relating to corporation tax

      2. Part 2 Amendments relating to income tax

         1. 3. Records to be kept for the purposes of income tax

         2. 4. Assessments relating to income tax

      3. Part 3 Amendments relating to corporation tax and income tax

         1. 5. Penalties for errors

         2. 6. Information and inspection powers

      4. Part 4 Commencement

         1. 7. Regulations made under— (a) paragraph 21 of Schedule 18 to...

   6. Schedule 6

      Categories of alcoholic products: interpretation

      1. 1. Spirits

      2. 2. The extraction of spirits absorbed in a wooden cask is...

      3. 3. Beer

      4. 4. (1) A qualifying beer-based beverage is treated as beer for...

      5. 5. Cider

      6. 6. In paragraph 5, “permitted substance” means a substance that—

      7. 7. (1) For the purposes of paragraph 5, the juice content...

      8. 8. (1) “Sparkling cider” means cider which— (a) if it is...

      9. 9. Rendering cider sparkling, at any time after the excise duty...

      10. 10. “Still cider” means cider that is not sparkling cider.

      11. 11. Wine

      12. 12. Other fermented products

   7. Schedule 7

      Rates of alcohol duty

   8. Schedule 8

      Qualifying draught products: reduced rates

   9. Schedule 9

      Small producer alcoholic products: duty discount

      1. Part 1 Alcoholic products, other than qualifying draught products, of an alcoholic strength of less than 8.5%

      2. Part 2 Qualifying draught products of an alcoholic strength of less than 8.5%

   10. Schedule 10

       Penalties for contraventions of alcohol wholesaling provisions

       1. 1. Liability to penalty

       2. 2. Amount of penalty

       3. 3. Reductions for disclosure

       4. 4. (1) Where P discloses a contravention, the Commissioners must reduce...

       5. 5. Special reduction

       6. 6. Assessment

       7. 7. Reasonable excuse

       8. 8. Companies: officer’s liability

       9. 9. Double jeopardy

       10. 10. The maximum amount

       11. 11. Appeal tribunal

   11. Schedule 11

       Alcohol duty: reviews and appeals

       1. 1. (1) Section 13A(2) of FA 1994 (meaning of “relevant decision”)...

       2. 2. In Schedule 5 to FA 1994 (decisions subject to review...

   12. Schedule 12

       Alcohol duty: duty stamps

       1. 1. Retail containers to be stamped

       2. 2. Power to alter alcoholic products, and capacity of containers, to which this Schedule applies

       3. 3. Acquisition of, and payment for, duty stamps

       4. 4. Regulations

       5. 5. Offences of possession, sale etc of unstamped containers

       6. 6. Offence of using premises for sale of alcoholic products in or from unstamped containers

       7. 7. Alcohol sales ban following conviction for an offence under paragraph 6

       8. 8. Penalty for altering duty stamps

       9. 9. Penalty for affixing wrong, altered or forged stamps, or over-labelling

       10. 10. Penalty for failing to comply with regulations

       11. 11. Forfeiture of forged, altered or stolen duty stamps

       12. 12. Interpretation

   13. Schedule 13

       Alcohol duty: minor and consequential amendments

       1. Part 1 General

          1. 1. CEMA 1979

          2. 2. (1) Section 1 (interpretation) is amended as follows.

          3. 3. In section 112 (power of entry upon premises, etc of...

          4. 4. (1) Section 114 (power to prohibit use of certain substances...

          5. 5. In section 163A (power to search articles), in subsection (2),...

          6. 6. Customs and Excise Duties (General Reliefs) Act 1979

          7. 7. Excise Duties (Surcharges or Rebates) Act 1979

          8. 8. FA 1994

          9. 9. In section 12 (assessments to excise duty), in subsection (2)(ca),...

          10. 10. In section 12A (other assessments relating to excise duty matters),...

          11. 11. (1) Section 12B (section 12A: supplementary provisions) is amended as...

          12. 12. In section 16 (appeals to a tribunal), in subsection (3A),...

          13. 13. In section 16A (temporary approvals etc. pending review or appeal),...

          14. 14. In Schedule 5 (decisions subject to review and appeal)—

          15. 15. VATA 1994

          16. 16. FA 2001

          17. 17. FA 2007

          18. 18. FA 2008

          19. 19. TCTA 2018

          20. 20. Taxation (Post-transition Period) Act 2020

       2. Part 2 Approvals etc.

          1. 21. CEMA 1979

          2. 22. (1) Section 1(1) (interpretation:defined terms) is amended as follows.

          3. 23. (1) Section 112 (power of entry upon premises, etc of...

          4. 24. In section 113 (power to search for concealed pipes etc),...

          5. 25. In section 136 (offences in connection with claims for drawback...

          6. 26. (1) Section 160 (power to take samples) is amended as...

          7. 27. In section 178 (citation) in subsection (2), omit “the Alcoholic...

          8. 28. FA 1994

          9. 29. FA 2007

          10. 30. FA 2008

          11. 31. FA 2009

          12. 32. (1) In Schedule 55 (penalty for failure to make returns...

          13. 33. (1) In Schedule 56 (penalty for failure to make payments...

   14. Schedule 14

       Administration of multinational top-up tax

       1. Part 1 Overview

          1. 1. (1) The Commissioners for His Majesty’s Revenue and Customs are...

       2. Part 2 Meaning of “filing member”

          1. 2. (1) The filing member of a multinational group is the...

          2. 3. (1) This paragraph applies where— (a) the filing member of...

          3. 4. (1) The obligations of a filing member of a multinational...

          4. 5. (1) This paragraph applies if at any time (“the relevant...

       3. Part 3 Registration

          1. 6. (1) The filing member of a multinational group must register...

          2. 7. (1) This paragraph applies where the filing member of a...

          3. 8. (1) This paragraph applies where the filing member of a...

          4. 9. (1) The filing member of a registered group must notify...

       4. Part 4 Information returns

          1. 10. (1) The filing member of a registered group must submit...

          2. 11. (1) The filing member may amend a return submitted under...

          3. 12. HMRC may take into account an information return in performing...

       5. Part 5 Self-assessment returns

          1. 13. (1) The filing member of a registered group must submit...

          2. 14. (1) The filing member may amend a return submitted under...

       6. Part 6 Enquiries into a self-assessment return

          1. 15. (1) This Part of this Schedule applies if the filing...

          2. 16. (1) An officer of Revenue and Customs may enquire into...

          3. 17. (1) An enquiry may extend to anything contained in the...

          4. 18. (1) For the purposes of this Part an enquiry is...

          5. 19. (1) If at a time when an enquiry is in...

          6. 20. (1) This paragraph applies if a return is amended at...

          7. 21. (1) At any time when an enquiry is in progress...

          8. 22. (1) Any matter to which an enquiry into a return...

          9. 23. (1) The filing member may apply to the tribunal for...

       7. Part 7 Determinations where self-assessment return not submitted

          1. 24. This Part of this Schedule applies if the filing member...

          2. 25. (1) An officer of Revenue and Customs may make a...

          3. 26. (1) If, after a determination has been made—

       8. Part 8 Discovery assessments

          1. 27. (1) If, in respect of an accounting period, an officer...

          2. 28. (1) This paragraph applies where the filing member of the...

          3. 29. (1) The general rule is that no discovery assessment may...

          4. 30. (1) The officer of Revenue and Customs must give notice...

       9. Part 9 Record-keeping requirements

          1. 31. (1) The filing member of the group must—

       10. Part 10 Payments of multinational top-up tax

           1. 32. Timing of payments

           2. 33. (1) Interest is to accrue on amounts payable under paragraph...

           3. 34. Group payment notices

           4. 35. (1) Where the multinational group contains ring-fenced entities, a group...

           5. 36. (1) The effect of a group payment notice being issued...

           6. 37. Effect of group payment for tax purposes

           7. 38. Recovery

           8. 39. Power to make regulations

       11. Part 11 Penalties

           1. 40. Penalties payable in connection with this Schedule

           2. 41. In paragraph 1 of Schedule 41 to FA 2008 (penalties...

           3. 42. (1) A penalty is payable if the filing member fails...

           4. 43. (1) A penalty is payable if the filing member fails...

           5. 44. (1) This paragraph applies if the filing member satisfies HMRC...

           6. 45. In paragraph 1 of Schedule 24 to FA 2007 (penalties...

           7. 46. (1) A penalty is payable if— (a) the member breaches...

           8. 47. Penalties under paragraphs 42, 43 and 46: administration and supplemental provision

           9. 48. (1) HMRC must— (a) assess the penalty, and

           10. 49. (1) If HMRC thinks it right because of special circumstances,...

           11. 50. Multiple penalties in respect of same accounting period

       12. Part 12 Appeals and claims

           1. 51. Claims in relation to overpaid tax

           2. 52. (1) This paragraph applies where one or more of Cases...

           3. 53. (1) An officer of Revenue and Customs may enquire into...

           4. 54. (1) This paragraph applies where— (a) an amount has been...

           5. 55. Appeals of decisions: general

           6. 56. (1) The effect of a notice of appeal being given...

           7. 57. Reviews by HMRC

           8. 58. (1) The review is to be conducted as follows.

           9. 59. (1) The review may conclude that HMRC's view of the...

           10. 60. (1) In paragraphs 57 to 59, a reference to the...

           11. 61. Settlement agreements

           12. 62. Determination by tribunal

           13. 63. Postponement of payment pending appeal

           14. 64. (1) The appellant may apply to HMRC for a determination...

           15. 65. (1) The appellant may apply to the tribunal for a...

           16. 66. (1) HMRC and the appellant may agree that payment of...

           17. 67. Special provisions as to penalties

       13. Part 13 Other amendments

           1. 68. (1) In section 1(1) of the Provisional Collection of Taxes...

   15. Schedule 15

       Multinational top-up tax: elections

       1. 1. Long term elections

       2. 2. Annual elections

   16. Schedule 16

       Multinational top-up tax: transitional provision

       1. Part 1 General transitional measures

          1. 1. Transitional relief for substance-based income exclusion

          2. 2. Intra-group transfers before entry into regime

       2. Part 2 Transitional safe harbour

          1. Chapter 1 Transitional safe harbour election

             1. 3. Election

             2. 4. Qualified financial statements and basis of calculations

             3. 5. Qualifying income tax expense

             4. 6. Adjustments

             5. 7. Threshold test

             6. 8. Simplified effective tax rate test

             7. 9. Routine profits test

          2. Chapter 2 Application to joint ventures etc

             1. 10. Application in the case of joint venture group

             2. 11. Application to investment entities in same territory as owners

             3. 12. Minority owned members

   17. Schedule 17

       Index of expressions defined or explained in Parts 3 and 4

   18. Schedule 18

       Administration of domestic top-up tax

       1. 1. Introduction

       2. 2. Meaning of “filing member”

       3. 3. Registration

       4. 4. Other administrative provisions

       5. 5. (1) In Part 11 of Schedule 14 (penalties), only paragraphs...

       6. 6. Amendments: penalties

       7. 7. Other amendments

   19. Schedule 19

       Dumping, subsidisation and safeguarding remedies

       1. Part 1 Dumping and subsidisation remedies

          1. 1. Introduction

          2. 2. Notification etc

          3. 3. Provisional remedies

          4. 4. Definitive remedies

          5. 5. Reviews etc

          6. 6. Revocation in the public interest

          7. 7. Power to request assistance etc

       2. Part 2 Safeguarding remedies

          1. 8. Introduction

          2. 9. Notification etc

          3. 10. Provisional remedies

          4. 11. Definitive remedies

          5. 12. Reviews etc

          6. 13. Revocation in the public interest

          7. 14. Power to request assistance etc

       3. Part 3 Consequential and related provision

          1. 15. In section 13 of TCTA 2018 (dumping of goods, foreign...

          2. 16. (1) The Treasury or the Secretary of State may by...

       4. Part 4 Commencement

          1. 17. (1) Any power to make regulations under or by virtue...

   20. Schedule 20

       Bilateral safeguarding remedies

       1. Part 1 Amendments to TCTA 2018

          1. 1. (1) Section 13 of TCTA 2018 is amended as follows....

          2. 2. After Schedule 5 of that Act insert— Schedule 5A Increase...

       2. Part 2 Commencement

          1. 3. (1) Any power to make regulations under or by virtue...

   21. Schedule 21

       Soft drinks industry levy: flavour concentrates

       1. 1. Introduction

       2. 2. Meaning of “soft drink” and “package”

       3. 3. Meaning of “prepared drinks”

       4. 4. Sugar content condition

       5. 5. Exempt soft drinks

       6. 6. Levy rates

       7. 7. Tax credits

       8. 8. Commencement

   22. Schedule 22

       Reforms of HGV road user levy

       1. 1. The HGV Road User Levy Act 2013 is amended as...

       2. 2. In section 1(1) (charge to HGV road user levy), for...

       3. 3. (1) Section 3 (roads to which this Act applies) is...

       4. 4. In section 5(7) (payment of levy for UK heavy goods...

       5. 5. (1) Section 6 (payment of levy for non-UK heavy goods...

       6. 6. In section 7(2) (rebate of levy), for paragraph (c) substitute—...

       7. 7. In section 11 (offence of using or keeping heavy goods...

       8. 8. (1) Section 14 (register of levy paid or due to...

       9. 9. In section 19 (interpretation), in subsection (1), in the definition...

       10. 10. (1) Schedule 1 (rates of HGV road user levy) is...

       11. 11. (1) In consequence of the amendments made by paragraph 10,...

       12. 12. The amendments made by this Schedule come into force on...

   23. Schedule 23

       Freeports and investment zones: consequential amendments

       1. 1. FA 2003

       2. 2. In section 61A— (a) in subsection (1), for “freeport tax...

       3. 3. In section 81— (a) in subsection (1A)(aa), for “freeport tax sites”...

       4. 4. In section 81ZA— (a) in subsection (1), for “freeport tax...

       5. 5. In section 85(3), for “freeport tax sites” substitute “special tax...

       6. 6. In section 86(2)(zb) and (2A), for “freeport tax sites” substitute...

       7. 7. In section 87(3)(azaa) and (azab), for “freeport tax sites” substitute...

       8. 8. In Schedule 6C— (a) for paragraph 2 and the italic...

       9. 9. CAA 2001

       10. 10. In section 3— (a) in subsection (2ZZA), for “freeport tax...

       11. 11. In the following provisions of Part 2 (plant and machinery...

       12. 12. In section 45Q— (a) in subsection (1)(b), for “the “non-freeport...

       13. 13. In the following provisions of Part 2A (structures and building...

       14. 14. In the following provisions of that Part—

       15. 15. For section 573A substitute— Special tax sites In this Act “special tax site” means an area for...

       16. 16. In Part 2 of Schedule 1— (a) omit the definition...

       17. 17. FA 2021

       18. 18. In the italic heading before section 113 at the end...

       19. 19. In the heading for section 113 (designation of freeport tax...

       20. 20. National Insurance Contributions Act 2022

       21. 21. In the italic heading before section 1, for “Freeports” substitute...

       22. 22. In section 1— (a) in subsections (1)(b) and (6), for...

       23. 23. In section 2— (a) in subsection (1)—

       24. 24. In section 3— (a) omit subsection (1),

       25. 25. In section 5, in the heading, for “freeport tax sites”...

       26. 26. In section 12(2), omit paragraph (a).

       27. 27. In section 13(2)— (a) omit the definition of “freeport tax...

   24. Schedule 24

       Homes for Ukraine Sponsorship Scheme: exemptions from tax

       1. 1. Income tax and corporation tax

       2. 2. Annual tax on enveloped dwellings

       3. 3. Stamp duty land tax

       4. 4. Regulations