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Reeves sets out tax commitments and confirms October Budget

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Chancellor Rachel Reeves has confirmed that she will deliver her first Budget on 30 October 2024.

In her speech to the House of Commons on 29 July 2024, reporting on the Treasury’s recent assessment of the state of public spending, the Chancellor also set out a number of tax commitments, including the following:

Draft Finance Bill legislation

Draft legislation was published on:

  • Removal of private schools from the VAT exemption from 1 January 2025 (with all fees paid from 29 July 2024 ‘pertaining to the term starting in January 2025 onwards’ – i.e. prepayments – subject to VAT). Private school eligibility for charitable business rates relief in England will also be removed. HM Treasury is consulting on various policy design questions until 15 September 2024. HMRC have also published an accompanying Revenue & Customs Brief (8/24).
  • Abolition of the furnished holiday lettings regime from April 2025 (comments are invited on the draft legislation by 15 September 2024).
  • Introduction of Pillar Two transitional country-by-country reporting safe harbour anti-arbitrage rules, having effect from 14 March 2024 (the date on which the measure was originally announced by the previous Exchequer Secretary to the Treasury). The Undertaxed Profits Rule (UTPR) will also be introduced for accounting periods beginning on or after 31 December 2024, the government has confirmed.

Policy announcements

There were policy announcements on:

  • Replacement of the remittance basis from 6 April 2025, moving to a new four-year foreign income and gains regime based on the Conservative Spring 2024 Budget proposals, but with some changes. A new residence-based system will also be introduced for IHT from 6 April 2025. The policy paper indicates that ‘separate engagement sessions’ on IHT and overseas workday relief are to be published on Gov.uk.
  • Energy profits levy (oil and gas) to be increased to 38% from 1 November 2024, with the levy extended to 31 March 2030 and the main investment allowance removed.

Consultations

A call for evidence was announced on the reform of the tax treatment of carried interest. The government is particularly interested in feedback on: (i) how the tax treatment of carried interest can most appropriately reflect its economic characteristics; (ii) what different structures and market practices there are with respect to carried interest; and (iii) what lessons that can be learned from approaches taken in other countries. The call for evidence closes on 30 August 2024.

    Other announcements included:

    • a commitment to a ‘single major fiscal event a year’ (perhaps with emphasis on ‘major’, given the statement was accompanied by several tax and spending announcements, including draft Finance Bill legislation);
    • spending reviews to be conducted every two years, looking at a three-year period (giving a one-year overlap each time), with ‘enhanced’ transparency over in-year spending and more information being provided to the Office for Budget Responsibility; and
    • a new Office of Value for Money to be established, with remit to ‘provide targeted interventions ... so that value for money governs every decision government makes’ and to ‘recommend system reforms to ensure any changes support the government’s missions and deliver value for money’.

    The Treasury’s Fixing the foundations: public spending audit 2024/25 publication sets out details of immediate changes in response to the government’s initial public spending audit and also notes the following general commitments: ‘The government is committed to tackling tax non-compliance, including from fraud and tax avoidance, to ensure everyone pays their fair share. The government will increase HMRC’s compliance staff, invest in HMRC’s resources and technology infrastructure, and make legislative changes to tackle tax non-compliance and raise revenue.’

    In a written statement summarising the tax changes, James Murray, Exchequer Secretary to the Treasury, also sets expectations for a bumper Budget in October: ‘The government will take a comprehensive approach to tackling the tax gap and making sure more of the tax revenues that are owed are correctly paid.

    ‘The government will invest in HMRC’s compliance work, hiring around 5,000 additional staff to recover more tax revenues. HMRC has already started the process of recruiting additional staff into compliance roles. The government will also invest in HMRC’s technology infrastructure, helping to make HMRC more efficient and improve taxpayers’ experience of interacting with HMRC.

    ‘‘The government will reform the tax system by making policy changes to simplify tax, close loopholes and reduce non-compliance, designing out non-compliance before it happens. At the Budget, the government will provide an update on the implementation and development of measures that form its plan to close the tax gap.

    Both Houses of Parliament rose for the summer recess at the end of business on 30 July, and will return on Monday 2 September.

    State of public spending

    The Chancellor began her speech by explaining this was to be a statement on the state of public spending, and the position inherited from the previous government which, according to Reeves, included a projected overspend of £22bn and was ‘money they were spending this year and had no ability to pay for’. Reeves also contends that some projected spending had not been declared to the Office for Budget Responsibility. The OBR is to conduct a review into the information it was given ahead of the Spring 2024 Budget, and perhaps the Public Accounts Committee will have its interest piqued.

    One of the headline announcements and ‘difficult decisions’ taken to mitigate against the in-year shortfall was to restrict the pensioner winter fuel payment to those in receipt of pension credit. ‘Not a decision I wanted to make,’ the Chancellor said.

    Commenting on the Chancellor’s statement, Paul Johnson, Director of the Institute for Fiscal Studies, proposes that, although more money was always going to have to be found for Labour’s plans for public services, the extent of the in-year funding pressures seemed genuinely to be greater than could have been expected. Some of those pressures on public finances would already have been clear, however – for example, the likelihood of public sector pay awards needing to exceed the 2% that had been budgeted for.

    But Johnson highlights a difficult question for the previous government: if the scale of overspend had been apparent last Spring, why did the then Chancellor proceed with a £10bn cut to NICs? ‘The new Chancellor is right to be cross’, Johnson said.

    Issue: 1674
    Categories: News
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