Décision No 1243 du Conseil permanent
S. 44 not in force at Royal Assent, see s. 120(2) S. 44 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 45 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 45 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 46 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 46 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 47 not in force at Royal Assent, see s. 120(2) S. 47 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 48 not in force at Royal Assent, see s. 120(2) S. 48 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 49 not in force at Royal Assent, see s. 120(2) S. 49 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 50 not in force at Royal Assent, see s. 120(2) S. 50 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 51 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 51 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 52 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 52 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 53 not in force at Royal Assent, see s. s. 120(2) S. 53 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 54 not in force at Royal Assent, see s. 120(2) S. 54 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 55 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 55 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 56 not in force at Royal Assent, see s. 120(2) S. 56 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 57 not in force at Royal Assent, see s. 120(2) S. 57 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 58 not in force at Royal Assent, see s. 120(2) S. 58 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 59 not in force at Royal Assent, see s. 120(2) S. 59 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 60 not in force at Royal Assent, see s. 120(2) S. 60 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 61 not in force at Royal Assent, see s. 120(2) S. 61 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 62 not in force at Royal Assent, see s. 120(2) S. 62 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 63 not in force at Royal Assent, see s. 120(2) S. 63 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 64 not in force at Royal Assent, see s. 120(2) S. 64 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 65 not in force at Royal Assent, see s. 120(2) S. 65 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 66 not in force at Royal Assent, see s. 120(2) S. 66 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 67 not in force at Royal Assent, see s. 120(2) S. 67 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 68 not in force at Royal Assent, see s. 120(2) S. 68 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 69 not in force at Royal Assent, see s. 120(2) S. 69 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 70 not in force at Royal Assent, see s. 120(2) S. 70 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 71 not in force at Royal Assent, see s. 120(2) S. 71 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) S. 72 not in force at Royal Assent, see s. 120(2) S. 72 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 73 not in force at Royal Assent, see s. 120(2) S. 73 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 74 not in force at Royal Assent, see s. 120(2) S. 74 in force at 1.2.2025 by S.I. 2025/96, reg. 2(a) (with reg. 3) S. 75 not in force at Royal Assent, see s. 120(2) S. 75 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 76 not in force at Royal Assent, see s. 120(2) S. 76 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 77 not in force at Royal Assent, see s. 120(2) S. 77 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 78 not in force at Royal Assent, see s. 120(2) S. 78 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 79 not in force at Royal Assent, see s. 120(2) S. 79 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 80 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 80 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 81 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 81 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(b) (with reg. 10) S. 82 not in force at Royal Assent, see s. 120(2) S. 82 in force at 1.2.2025 by S.I. 2025/96, reg. 2(b) (with reg. 3) S. 83 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 83 in force at 1.2.2025 in so far as not already in force by S.I. 2025/96, reg. 2(b) (with reg. 3) S. 84 not in force at Royal Assent, see s. 120(2) S. 84 in force at 1.2.2025 by S.I. 2025/96, reg. 2(b) (with reg. 3) S. 85 not in force at Royal Assent, see s. 120(2) S. 85 in force at 1.2.2025 by S.I. 2025/96, reg. 2(b) (with reg. 3) S. 86 not in force at Royal Assent, see s. 120(2) S. 86 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(c) (with reg. 10) S. 87 not in force at Royal Assent, see s. 120(2) S. 87 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(c) (with reg. 10) S. 88 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 88 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(c) (with reg. 10) S. 89 not in force at Royal Assent, see s. 120(2) S. 89 in force at 1.8.2023 for specified purposes by S.I. 2023/884, reg. 2(1)(d) (with reg. 10) S. 89 in force at 1.2.2025 in so far as not already in force by S.I. 2025/96, reg. 2(c) (with reg. 3) S. 90 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 90 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 91 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 91 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 92 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 92 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 93 not in force at Royal Assent, see s. 120(2) S. 93 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 94 not in force at Royal Assent, see s. 120(2) S. 94 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 95 not in force at Royal Assent, see s. 120(2) S. 95 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 96 not in force at Royal Assent, see s. 120(2) S. 96 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 97 not in force at Royal Assent, see s. 120(2) S. 97 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 98 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 98 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 99 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 99 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 100 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 100 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 101 not in force at Royal Assent, see s. 120(2) S. 101 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 102 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 102 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 103 not in force at Royal Assent, see s. 120(2) S. 103 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 104 not in force at Royal Assent, see s. 120(2) S. 104 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 105 in force at Royal Assent for specified purposes, see s. 120(1)(b) S. 105 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 106 not in force at Royal Assent, see s. 120(2) S. 106 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 107 not in force at Royal Assent, see s. 120(2) S. 107 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) S. 108 not in force at Royal Assent, see s. 120(2) S. 108 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(f) (with reg. 3(2)-(4), 10) S. 109 not in force at Royal Assent, see s. 120(2) S. 109 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(g) (with reg. 10) S. 110 not in force at Royal Assent, see s. 120(2) S. 110 in force at 1.2.2025 by S.I. 2025/96, reg. 2(d) (with reg. 3) S. 111 not in force at Royal Assent, see s. 120(2) S. 111 in force at 1.2.2025 by S.I. 2025/96, reg. 2(d) (with reg. 3) S. 113 not in force at Royal Assent, see s. 120(2) S. 113 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(i) (with regs. 3(1), 4, 9, 10) S. 114 not in force at Royal Assent, see s. 120(2) S. 114 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) S. 115 not in force at Royal Assent, see s. 120(2) S. 115 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(k) (with reg. 10) S. 116 not in force at Royal Assent, see s. 120(2) S. 116 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(k) (with reg. 10) S. 117 in force at Royal Assent, see s. 120(1)(a) S. 118 in force at Royal Assent, see s. 120(1)(a) S. 119 in force at Royal Assent, see s. 120(1)(a) S. 120 in force at Royal Assent, see s. 120(1)(a) S. 334 in force in accordance with s. 334(5) Sch. 6 para. 1 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 1 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 2 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 2 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 3 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 3 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 4 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 4 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 5 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 5 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 6 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 6 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 7 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 7 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 8 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 8 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 9 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 9 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 10 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 10 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 11 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 11 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 6 para. 12 not in force at Royal Assent, see s. 120(2) Sch. 6 para. 12 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(a) (with reg. 10) Sch. 10 para. 1 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 1 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 2 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 2 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 3 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 3 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 4 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 4 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 5 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 5 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 6 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 6 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 7 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 7 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 8 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 8 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 9 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 9 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 10 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 10 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 10 para. 11 in force at Royal Assent for specified purposes, see s. 120(1)(b) Sch. 10 para. 11 in force at 1.8.2023 in so far as not already in force by S.I. 2023/884, reg. 2(1)(e) (with reg. 10) Sch. 11 para. 1 not in force at Royal Assent, see s. 120(2) Sch. 11 para. 1 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(f) (with reg. 3(2)-(4), 10) Sch. 11 para. 2 not in force at Royal Assent, see s. 120(2) Sch. 11 para. 2 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(f) (with reg. 3(2)-(4), 10) Sch. 13 para. 1 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 1 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 2 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 2 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 3 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 3 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 4 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 4 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 5 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 5 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 6 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 6 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 7 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 7 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 8 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 8 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 10 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 10 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 11 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 11 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 12 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 12 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 13 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 13 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 14 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 14 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 15 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 15 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 16 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 16 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 17 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 17 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 18 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 18 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 19 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 19 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 20 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 20 in force at 1.8.2023 by S.I. 2023/884, reg. 2(1)(j) (with reg. 10) Sch. 13 para. 21 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 21 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 22 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 22 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 23 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 23 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 24 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 24 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 25 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 25 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 26 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 26 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 27 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 27 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 28 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 28 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 29 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 29 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 30 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 30 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 31 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 31 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 32 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 32 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 13 para. 33 not in force at Royal Assent, see s. 120(2) Sch. 13 para. 33 in force at 1.2.2025 by S.I. 2025/96, reg. 2(e) (with reg. 3) Sch. 19 para. 1 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 1 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 2 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 2 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 3 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 3 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 4 in force at Royal Assent for specified purposes, see Sch. 19 para. 17(1) Sch. 19 para. 4 in force at 25.8.2023 in so far as not already in force by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 5 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 5 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 6 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 6 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 7 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 7 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 8 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 8 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 9 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 9 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 10 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 10 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 11 in force at Royal Assent for specified purposes, see Sch. 19 para. 17(1) Sch. 19 para. 11 in force at 25.8.2023 in so far as not already in force by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 12 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 12 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 13 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 13 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 14 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 14 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 15 not in force at Royal Assent, see Sch. 19 para. 17(2) Sch. 19 para. 15 in force at 25.8.2023 by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 16 in force at Royal Assent for specified purposes, see Sch. 19 para. 17(1) Sch. 19 para. 16 in force at 25.8.2023 in so far as not already in force by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 19 para. 17 in force at Royal Assent for specified purposes, see Sch. 19 para. 17(1) Sch. 19 para. 17 in force at 25.8.2023 in so far as not already in force by S.I. 2023/918, reg. 2 (with reg. 3) Sch. 20 para. 1 not in force at Royal Assent, see Sch. 20 para. 3(2) Sch. 20 para. 1 in force at 13.5.2024 by S.I. 2024/522, reg. 2 Sch. 20 para. 2 in force at Royal Assent for specified purposes, see Sch. 20 para. 3(1) Sch. 20 para. 2 in force at 13.5.2024 in so far as not already in force by S.I. 2024/522, reg. 2 Sch. 20 para. 3 in force at Royal Assent for specified purposes, see Sch. 20 para. 3(1) Sch. 20 para. 3 in force at 13.5.2024 in so far as not already in force by S.I. 2024/522, reg. 2 Words in s. 7(1) substituted (22.2.2024) by Finance Act 2024 (c. 3), s. 1(2)(b) Words in s. 7(3) omitted (22.2.2024) by virtue of Finance Act 2024 (c. 3), s. 1(1) Word in s. 7(6) omitted (22.2.2024) by virtue of Finance Act 2024 (c. 3), s. 1(2)(b) S. 18 repealed (22.2.2024) by Finance Act 2024 (c. 3), s. 14(3) S. 19 repealed (22.2.2024) by Finance Act 2024 (c. 3), s. 14(3) S. 112 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(1)(4) (with s. 64(5)(6)) S. 119(4) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(i)(4) (with s. 64(5)(6)) Words in s. 119(5) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(ii)(4) (with s. 64(5)(6)) Words in s. 119(8)(a) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(ii)(4) (with s. 64(5)(6)) Words in s. 121(1) substituted (n relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 2(2), 10 S. 121(5)(e) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 2(3), 10 Word in s. 122(1) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(2), 10 Words in s. 122(1)(a)(ii) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(a) Word in s. 122(2) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(3), 10 Words in s. 122(2)(c)(ii) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(b) Word in s. 122(3)(a) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(4), 10 S. 122(4)-(6) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(c) Word in s. 122(7) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(5), 10 S. 123 substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(1), 10 Word in s. 124 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(2)(a), 10 S. 124(8A) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(2)(b), 10 Words in s. 127(5)(a) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 11, 72(1)(a) S. 127(5)(b) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 3(a) S. 127(5)(c) and word omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 3(b) Words in s. 127(6)(a) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 11, 72(1)(a) Words in s. 127(7)(a) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 11, 72(1)(a) Words in s. 127(12) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(1) Words in s. 128(2) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(2)(a)(i) Words in s. 128(2) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(2)(a)(ii) S. 128(3)(c) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 4(2) Words in s. 128(4) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 4(3) Word in s. 128(4)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 2(a), 53(5)-(13) S. 128(4)(c) and word inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 2(b), 53(5)-(13) S. 128(5)(b) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 4(4) Words in s. 128(6) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 4(5) Word in s. 128(6)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 2(a), 53(5)-(13) S. 128(6)(c) and word inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 2(b), 53(5)-(13) Words in s. 128(7) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(2)(b)(i) Words in s. 128(7)(a) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(2)(b)(ii) Words in s. 128(7)(b)(i) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 7(1)(a), 10 Words in s. 128(7)(b)(i) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(2)(b)(iii) S. 128(7A) inserted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 4, 53(1) S. 128(8) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 7(1)(b), 10 Words in s. 130(5) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(3)(a) Words in s. 130(5) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 48(3)(b) Word in s. 131(1) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 5(2) S. 131(2)(3) substituted for s. 131(2) (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 5(3) Words in s. 131(3)(b) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 40, 53(5)-(13) Words in s. 132(1) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 41, 53(5)-(13) Word in s. 132(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 49(1) Words in s. 135(1)(a) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 6(a), 53(5)-(13) Words in s. 135(1)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 6(b), 53(5)-(13) S. 137A inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 12(1), 72(4) Word in s. 138(1) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 50(1) Words in s. 140(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(2)(a) Words in s. 140(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(2)(b)(i) Words in s. 140(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(2)(b)(ii) S. 141(9)(b) and word omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 53, 72(4) Words in s. 142(2)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 50(3) Word in s. 144(4)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 42, 53(5)-(13) Words in s. 146(b) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 6 S. 147 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 7 S. 147A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(1) Word in s. 148 heading substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(2)(a) S. 148(1) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 8(2)(b) Word in s. 148(4)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 8(2)(c) Ss. 148A-148C inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(3) Words in s. 148A(5)(a)(i) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 54(a), 72(4) Words in s. 148A(5)(a)(ii) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 54(b), 72(4) Words in s. 149(6) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(4) Words in s. 150(6)(a) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(5)(a)(i) Words in s. 150(6)(b) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(5)(a)(ii) S. 150(6A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(5)(b) S. 150A inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 10, 53(5)-(13) Words in s. 151(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(2)(a) Word in s. 151(1) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 9(2)(b) S. 151(1)(aa) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(2)(c) S. 151(1)(c) and word inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(2)(d) Words in s. 151(6)(c) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(3) S. 151(6A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(4) S. 151(7) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(5) S. 151(8) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 9(6) Words in s. 152(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 10(2) S. 152(4) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 10(3) Words in s. 153(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 11 Word in s. 155(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 47(4), 72(2) S. 159(1)(a)(b) substituted for words (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 12(2) S. 159(2)(a)(b) substituted for words (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 12(3) S. 159(3)(a)(b) substituted for words (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 12(4) S. 159(4) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 12(5) S. 159(5) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 7, 53(5)-(13) Words in s. 163(1) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 13(2) Words in s. 163(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 13(3)(a) Words in s. 163(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 13(3)(b) Word in s. 163(3) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 13(4) Words in s. 165(2) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(6)(a) S. 165(2)(a)(b) become s. 165(2)(a)(i)(ii) (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(6)(b) S. 165(2)(b) and word inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 50(6)(c) Words in s. 168 heading omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(2), 72(4) Words in s. 168(2)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(2) S. 168(2A)-(2C) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(3), 72(4) Words in s. 168(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(4), 72(4) Word in s. 168(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(5)(a), 72(4) Word in s. 168(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(5)(b), 72(4) Words in s. 168(4) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(5)(c), 72(4) S. 168(5)(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(6), 72(4) S. 168(7) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(7), 72(4) S. 168(9)(9A) substituted for s. 168(9) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(8), 72(4) Words in s. 168(10) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(9), 72(4) S. 168(10ZA) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 11, 53(5)-(13) S. 168(10A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 13(10), 72(4) S. 168(11) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(11), 72(4) S. 168(12) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 13(11), 72(4) Word in s. 169(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(a), 72(4) Words in s. 169(2)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(b)(i), 72(4) Words in s. 169(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(b)(ii), 72(4) Words in s. 170(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(2), 53(5)-(13) Words in s. 170(2) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(3)(a), 53(5)-(13) Words in s. 170(2)(a) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(3)(b), 53(5)-(13) Words in s. 170(2) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(9)(a) S. 170(2A) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(4), 53(5)-(13) Words in s. 170(3) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(5), 53(5)-(13) S. 170(5A)-(5C) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 12(6), 53(5)-(13) Words in s. 170(9)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 55, 72(4) Word in s. 171(2)(b) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 56(a), 72(4) Word in s. 171(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 56(b), 72(4) Words in s. 173(1)(c) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 15 Words in s. 174(1) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 18, 72(3)(a) Words in s. 174(5) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 13(2), 53(5)-(13) S. 174(6) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 13(3), 53(5)-(13) Words in s. 175 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 19, 72(3)(a) Words in s. 175(2)(c) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(4) S. 175(3) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 16, 53(5)-(13) Words in s. 176 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 19, 72(3)(a) Words in s. 176(2)(d)(i) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(5)(a) Words in s. 176(2)(e) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(5)(b) Words in s. 176(2)(i) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 14, 53(5)-(13) Ss. 176A-176C and cross-heading inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(6) Words in s. 176B(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 57, 72(4) Word in s. 176C(4)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 58(a), 72(4) Word in s. 176C(5)(a)(ii) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 58(b), 72(4) Word in s. 176C(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 58(c), 72(4) Ss. 176D-176F and cross-heading inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 16(1) Words in s. 176D(1) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(2), 72(3)(a) S. 176D(2) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(3), 72(3)(a) Word in s. 176D(3)(b) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(4)(a), 72(3)(a) Words in s. 176D(3)(b) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(4)(b), 72(3)(a) Words in s. 176D(7) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(5), 72(3)(a) Words in s. 176D(10) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 59, 72(4) S. 176D(11)(12) substituted for s. 176D(11) (20.3.2025 in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 20(6), 72(3)(a) (with Sch. 4 para. 20(7)(8)) Words in s. 176E(1) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 21(2)(a), 72(3)(a) Words in s. 176E(1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 21(2)(b), 72(3)(a) Words in s. 176E(1) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 21(3), 72(3)(a) Words in s. 176E(2) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 21(4), 72(3)(a) S. 176E(3)-(6) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 21(5), 72(3)(a) Words in s. 176F substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 22(2), 72(3)(a) Words in s. 176F substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 22(3), 72(3)(a) S. 176G inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 23, 72(3)(a) S. 176G(4)(5) substituted for s. 176G(4) (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 18, 53(5)-(13) Words in s. 177(1) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(1) Words in s. 178(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 16(2), 72(4) Word in s. 178(1) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(3) S. 178(1A)(1B) inserted ( with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(4) S. 178(1C)(1D) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 16(3), 72(4) Words in s. 178(2) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(5) Words in s. 178(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 16(4), 72(4) S. 178(5)(6) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(6) Words in s. 179(1)(b) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 18(2) S. 179(1A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(7)(a) S. 179(3A)(3B) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 17(7)(b) Words in s. 179(4) inserted ( with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 18(3) Word in s. 180(2)(b) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(a) Words in s. 180(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 26, 72(4) Word in s. 180(4) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(b) Word in s. 180(5) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(c)(i) Words in s. 180(5)(a) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 19(2) Word in s. 180(5)(b) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(c)(ii) Word in s. 180(6)(a) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(d) Words in s. 180(7) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 19(3)(a) Words in s. 180(7) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 19(3)(b) Word in s. 180(8) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(e)(i) Words in s. 180(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(a), 72(4) S. 180(8)(aa)(ab) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(b), 72(4) Words in s. 180(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(c)(i), 72(4) Word in s. 180(8)(b) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(e)(ii) S. 180(8)(b)(ii)(iia) substituted for s. 180(8)(b)(ii) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 19(4) Words in s. 180(8)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(c)(ii), 72(4) S. 180(10) omitted ( with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 18(4)(f) S. 180A inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(3), 72(4) S. 181A inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 27, 72(4) S. 181B and cross-heading inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 28, 72(4) Words in s. 181B(5) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 19, 53(5)-(13) Words in s. 182(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 15(2), 53(5)-(13) Words in s. 182(2)(a) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 17, 53(5)-(13) S. 182(2A) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 15(3), 53(5)-(13) Words in s. 182(8) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 15(4), 53(5)-(13) Words in s. 183(3)(b) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 20(2) Word in s. 183(4) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 20(3) Words in s. 183(5) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 20(4) Words in s. 183(5) renumbered as s. 183(5)(a) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(a)(i), 72(4) S. 183(5)(b) and word inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(a)(ii), 72(4) S. 183(6)(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(b), 72(4) S. 183A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 20(5) S. 184(5)-(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 30, 72(4) Words in s. 185(1) substituted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 20(2), 53(2) Words in s. 185(2)(a) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 51(1) Word in s. 185(6) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 20(3)(a), 53(2) S. 185(6)(a) substituted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 20(3)(b), 53(2) S. 185(7A)-(7D) inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 20(4), 53(2) S. 185(8)(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 31, 72(4) Word in s. 185(8) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 20(5), 53(2) S. 186(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 51(2)(a) S. 186(8) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 51(2)(b) S. 187(6)(b) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 51(3)(a) Words in s. 187(6) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 51(3)(b) Words in s. 194(3) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 35(2) Word in s. 194(3) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 52(1) S. 195(2) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(1), 72(1)(c) S. 195(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(1), 72(1)(c) S. 195(7A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 25(1) S. 195(8)(9) substituted for s. 195(8) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 32, 72(4) S. 196(1)(b) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 36(a), 72(4) Words in s. 196(1)(c) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 21(1)(a) Word in s. 196(1) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 22(1)(a) S. 196(1)(e) and words inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 22(1)(b) S. 196(1A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 21(1)(b) Words in s. 196(3) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 52(2) Words in s. 196(3)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 36(b), 72(4) S. 196(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 34, 72(4) S. 197(1) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 52(3)(a) S. 197(2) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 52(3)(b) Word in s. 197(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 12(2)(a), 72(4) Words in s. 197(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 12(2)(b), 72(4) Word in s. 197(4) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 23(a) S. 197(4)(d)(e) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 23(b) Words in s. 197(5) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 22(2)(a) Words in s. 197(5)(a) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 22(2)(b) Word in s. 197(5) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 22(2)(c) Words in s. 197(5)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 22(2)(d) S. 197(5)(c) and word inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 22(2)(e) S. 197(6A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 21(2) S. 197(7A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 24 S. 197(10) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 35, 72(4) S. 197A inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 25(2) Word in s. 197A(2) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 43, 53(5)-(13) Word in s. 197A(3) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 43, 53(5)-(13) Ss. 198-198ZC substituted for s. 198 (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 33, 72(4) S. 198A inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 26 Words in s. 199 heading substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(d), 72(4) Words in s. 199(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(a)(i), 72(4) Word in s. 199(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(a)(ii), 72(4) Word in s. 199(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4) S. 199(2A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(c), 72(4) Word in s. 199(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4) Word in s. 199(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4) Word in s. 199(6)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4) Word in s. 199(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4) Words in s. 201(1) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 53(2) Words in s. 201(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 49(2), 72(4) Words in s. 201(2) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 53(3)(a) Words in s. 201(2) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 53(3)(b) S. 201(4) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 49(3), 72(4) Words in s. 203(4)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4) Words in s. 203(5)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4) Words in s. 203(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4) Words in s. 203(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4) Words in s. 205(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 54(1)(a) Words in s. 205(2)(a) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 54(1)(b)(i) Words in s. 205(2)(a) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 54(1)(b)(ii) Words in s. 205(2)(b) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 54(1)(c) Words in s. 205(3) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 54(1)(d) Words in s. 206(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(2)(a), 72(4) Word in s. 206(1)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(2)(b), 72(4) Words in s. 206(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(3)(a), 72(4) Word in s. 206(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(3)(b), 72(4) Words in s. 206(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(a), 72(4) Words in s. 206(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(b), 72(4) Word in s. 206(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(c)(i), 72(4) Words in s. 206(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(c)(ii), 72(4) Words in s. 206(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(5)(a), 72(4) Words in s. 206(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(5)(b), 72(4) Word in s. 206(5)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(a)(i), 72(4) Word in s. 206(5)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(a)(ii), 72(4) Words in s. 206(5)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(b), 72(4) Words in s. 206(5)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(c), 72(4) Word in s. 206(6)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(a)(i), 72(4) Word in s. 206(6)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(a)(ii), 72(4) Words in s. 206(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(b), 72(4) Words in s. 206(6)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(c), 72(4) Word in s. 206(7)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(i), 72(4) Word in s. 206(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(ii), 72(4) Words in s. 206(7)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(iii), 72(4) Words in s. 206(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(b)(i), 72(4) Words in s. 206(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(b)(ii), 72(4) Word in s. 206(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(a)(i), 72(4) Words in s. 206(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(a)(ii), 72(4) Words in s. 206(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(b)(i), 72(4) Words in s. 206(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(b)(ii), 72(4) Words in s. 206(8) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(c), 72(4) S. 206(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(10), 72(4) Word in s. 210(2) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 44, 53(5)-(13) S. 211(1)-(1C) substituted for s. 211(1) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 27(a) Words in s. 211(2)(a) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 27(b) Word in s. 211(2) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 60(a)(i), 72(4) S. 211(2)(ba) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 60(a)(ii), 72(4) S. 211(5) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 60(b), 72(4) Words in s. 212(4) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 61, 72(4) S. 213(6A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 28 Words in s. 215(2)(c) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 62, 72(4) Words in s. 216(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 63, 72(4) S. 217(1A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 64, 72(4) Words in s. 217(2)(a) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(2), 53(5)-(13) Words in s. 217(2)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(2), 53(5)-(13) Words in s. 217(3) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(2), 53(5)-(13) Words in s. 217(4) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(3), 53(5)-(13) Words in s. 217(5)(a) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(4), 53(5)-(13) Words in s. 217(5)(b) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(4), 53(5)-(13) Words in s. 217(5)(c) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(4), 53(5)-(13) S. 217(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 65, 72(4) Words in s. 217(8)(a) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(5), 53(5)-(13) S. 217(9) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 23(6), 53(5)-(13) Words in s. 220(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 66(a)(i), 72(1)(f) S. 220(1) Step 9 inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 66(a)(ii), 72(1)(f) S. 220(2) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 66(b), 72(1)(f) Words in s. 220(3) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 55(1) Words in s. 221(4) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 55(2) Words in s. 222 substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 67, 72(4) Words in s. 223(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(a), 72(4) Word in s. 223(7)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(b), 72(4) Words in s. 223(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(c), 72(4) Words in s. 223(8)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(3)(a), 72(4) Words in s. 223(8) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(3)(b), 72(4) Words in s. 223(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(4), 72(4) Words in s. 226(2) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(a), 72(3)(b) Words in s. 226(2)(a) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(b), 72(3)(b) Words in s. 226(2)(b) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(c), 72(3)(b) Words in s. 226(2)(c) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(d), 72(1)(b) Words in s. 226(2)(f) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(e), 72(4) Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(i), 72(4) Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(ii), 72(4) Words in s. 227(1) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(2) Words in s. 227(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(iii), 72(4) Words in s. 227(1)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(b), 72(4) Words in s. 227(2) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(3), 72(4) Words in s. 227(2) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 30 Words in s. 227(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(a), 72(4) Words in s. 227(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(b), 72(4) S. 228(5) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(2), 72(4) Words in s. 229(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 55(3) Pt. 3 Ch. 9A inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 5, 10 Word in s. 229C(3)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 24(a), 53(5)-(13) S. 229C(3)(c) and word inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 24(b), 53(5)-(13) Word in s. 231(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(1)(a) S. 231(1)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 56(1)(b) S. 231(1)(c) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 56(1)(b) Word in s. 231(1)(d) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 56(1)(c)(i) Words in s. 231(1)(d) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(1)(c)(ii) Words in s. 232 heading omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 8(2), 53(5)-(13) Word in s. 232(1) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 8(3)(a), 53(5)-(13) Words in s. 232(1)(a) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(3)(b), 53(5)-(13) Words in s. 232(1)(a) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(2) Word in s. 232(1)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 8(3)(c), 53(5)-(13) S. 232(1)(aa) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(3)(c), 53(5)-(13) Word in s. 232(1)(b) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(3)(d), 53(5)-(13) Words in s. 232(2)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(4)(a), 53(5)-(13) Words in s. 232(2)(c) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(4)(a), 53(5)-(13) S. 232(2)(d)(ii) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(4)(b), 53(5)-(13) S. 232(2A) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(5), 53(5)-(13) S. 232(3A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 4(6) S. 232(6) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 8(6), 53(5)-(13) S. 232ZA inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 9, 53(5)-(13) S. 232A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(2) Words in s. 235(1)(b) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(3) S. 236(2)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 31(2)(a) S. 236(2)(c) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 31(2)(b) S. 236(2)(e) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 31(2)(c) S. 236(2A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 31(3) S. 237(1)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 3(2), 53(5)-(13) S. 237(2)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 3(3), 53(5)-(13) Words in s. 238 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(10)(a) Word in s. 238 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(10)(b) Words in s. 239(6)(c) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 32(1)(a) Words in s. 239(6) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 32(1)(b) S. 239(7)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 26(a), 53(5)-(13) S. 239(8) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 26(b), 53(5)-(13) S. 240(1) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 32(2) Words in s. 240(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 17(a), 72(4) Words in s. 240(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 17(b), 72(4) Words in s. 241(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(a), 72(1)(d) S. 241(1A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(b), 72(1)(d) Words in s. 241(2) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(i), 72(1)(d) Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(ii), 72(1)(d) Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 8, 10 S. 241(2A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(d), 72(1)(d) Word in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(i), 72(1)(d) Word in s. 241(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(ii), 72(1)(d) Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iii), 72(1)(d) Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iv), 72(1)(d) S. 241(4) omitted (in relation to accounting periods beginning on or after 31.12.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 28, 53(1) S. 242(2)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 33, 53(5)-(13) Word in s. 242(5)(a) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 68, 72(4) Words in s. 244(2)(a) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(4) Words in s. 245(2) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(5) Word in s. 246(1)(b)(ii) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(6) Words in s. 247(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 45, 53(5)-(13) Words in s. 248 inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(7) Word in s. 249(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(8)(a) Words in s. 249(2) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(8)(b) S. 251A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 29(1) Word in s. 252(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(9) Words in s. 253(1)(a)(i) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(10)(a)(b) Words in s. 253(2)(b)(v) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(10)(c)(i) Word in s. 253(2)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 56(10)(c)(ii) S. 253(2)(b)(va) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(10)(c)(iii) S. 254 substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 33(1) Words in s. 254(4) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(3), 10 S. 255(2A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(1)(a) Words in s. 255(3) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(1)(b)(i) Words in s. 255(3)(a) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(1)(b)(ii) Words in s. 255(3)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(1)(b)(iii) S. 255(4)-(6) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(1)(c) Words in s. 255(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 69, 72(4) Words in s. 256(1)(b) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(a), 72(1)(d) S. 256(1A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(b), 72(1)(d) Words in s. 256(2) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(c)(i), 72(1)(d) Words in s. 256(2) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(c)(ii), 72(1)(d) S. 256(2A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(d), 72(1)(d) Word in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(i), 72(1)(d) Word in s. 256(4) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(ii), 72(1)(d) Words in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(iii), 72(1)(d) Words in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(iv), 72(1)(d) S. 256(5) omitted (in relation to accounting periods beginning on or after 31.12.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 29, 53(1) S. 256A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 35(1) Words in s. 257(1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 7(2), 10 S. 257(1A) inserted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 30(2), 53(1) Words in s. 257(2) substituted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 30(3), 53(1) Words in s. 259(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(11)(a) Words in s. 259(1) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(3) Words in s. 259(1) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 56(11)(b) S. 260 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(3) Words in s. 262(1)(a) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 47(1)(a) Words in s. 262(1)(b) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 47(1)(b) S. 262(1A)-(1D) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 36 Words in s. 266(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 41(2), 72(4) Words in s. 266(1) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 43(2) S. 266(1A)(1B) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 41(3), 72(4) S. 267(1A) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 34, 53(5)-(13) Words in s. 267(2) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 43(1)(a) S. 267(3ZA) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 44, 72(4) S. 267(3A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 42(1)(a) S. 267(3B)-(3D) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 43(1)(b) Words in s. 267(3C) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 46(2)(a), 53(5)-(13) Words in s. 267(3C)(a) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 46(2)(b), 53(5)-(13) Word in s. 267(3C)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 46(2)(c), 53(5)-(13) Word in s. 267(3D)(c) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 46(3)(a), 53(5)-(13) Words in s. 267(3D)(c) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 46(3)(b), 53(5)-(13) Words in s. 267(4) reordered (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 42(1)(b)(i) Words in s. 267(4) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 42(1)(b)(ii) S. 267A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 42(2) S. 268A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(4) Words in s. 269(1)(a) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(5)(a)(i) Words in s. 269(1)(b) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(5)(a)(ii) S. 269(4)-(6) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(5)(b) S. 270(A1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(2), 72(4) Words in s. 270(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(3)(a), 72(4) Words in s. 270(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(3)(b), 72(4) S. 270(4) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 35, 53(5)-(13) Word in s. 271(1) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(1)(a) Word in s. 271(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(1)(b) Word in s. 271(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(1)(c) S. 272(3A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 43(2), 72(4) S. 272(4)(c) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(3), 10 S. 272(8)(aa)(ab) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 37(a), 53(5)-(13) Words in s. 272(8)(c)(i) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(2) S. 272(8)(d) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 38, 53(5)-(13) S. 272(8)(da) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 44(1) Words in s. 272(8)(da) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 47(a), 53(5)-(13) S. 272(8)(e) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 43(3), 72(4) S. 272(8)(f) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 37(b), 53(5)-(13) S. 272(9)-(11) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 43(3)(b) Word in s. 272(10)(a) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 47(b), 53(5)-(13) S. 272A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 42(3) Word in s. 273(2) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 48(a), 53(5)-(13) Words in s. 273(2) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 48(b), 53(5)-(13) S. 273(3)(ba) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 44(2) Word in s. 273(4) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(3)(a) Words in s. 273(4)(e) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(3)(b) S. 273(4)(pa) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 57(3)(c) S. 273(4)(z1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(4), 10 Ss. 273A, 273B inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 45(1) S. 273C inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 46 S. 274 omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 47(2) S. 276(aa) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 45(2)(a) Words in s. 276(b)(i) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 29(3) S. 276(c)(iiia) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 45(2)(b) Word in s. 279(1) substituted (for qualifying periods beginning on or after 1.7.2026) by Taxation (Energy and Vehicles) Act 2026 (c. 26), s. 1(1)(2) (with s. 1(3)-(6)) Word in s. 280(1) omitted (22.2.2024) by virtue of Finance Act 2024 (c. 3), s. 21(2)(a) Words in s. 280(1) inserted (22.2.2024) by Finance Act 2024 (c. 3), s. 21(2)(b) S. 311A inserted (22.2.2024) by Finance Act 2024 (c. 3), s. 21(3) Words in s. 313 Table inserted (22.2.2024) by Finance Act 2024 (c. 3), s. 21(4) S. 349(2)(fa) inserted (20.3.2025) by Finance Act 2025 (c. 8), s. 82(a) Word in s. 349(2)(g) substituted (20.3.2025) by Finance Act 2025 (c. 8), s. 82(b) Sch. 7 substituted (1.2.2026) by Finance Act 2026 (c. 11), s. 89(2)(6) Sch. 8 substituted (1.2.2026) by Finance Act 2026 (c. 11), s. 89(3)(6) Sch. 9 substituted (1.2.2026) by Finance Act 2026 (c. 11), s. 89(4)(6) Sch. 11 para. 1(4) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(e)(4) (with s. 64(5)(6)) Sch. 12 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(1)(4) (with s. 64(5)(6)) Sch. 13 para. 9 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(2)(f)(4) (with s. 64(5)(6)) Word in Sch. 14 para. 2(12) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 70(a), 72(4) Words in Sch. 14 para. 3(2)(a) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(a)(i) Sch. 14 para. 3(2)(c) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(a)(ii) Sch. 14 para. 3(3)-(5) substituted for Sch. 14 para. 3(3) (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(a)(iii) Sch. 14 para. 6(1A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(a) Words in Sch. 14 para. 7(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 70(b), 72(4) Sch. 14 para. 10(12) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(2), 72(1)(e) Sch. 14 para. 13(11) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(3), 72(1)(e) Sch. 14 para. 32(3A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(4), 72(1)(e) Sch. 14 para. 33A inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 37(3) Words in Sch. 14 para. 34(2) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(b)(i) Sch. 14 para. 34(2A) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(b)(ii) Words in Sch. 14 para. 35(1) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(c) Words in Sch. 14 para. 36(3) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(d) Words in Sch. 14 para. 37(4)(b) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(e)(i) Word in Sch. 14 para. 37(6) substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(1)(e)(ii) Sch. 14 paras. 37A, 37B and cross-headings inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(b) Word in Sch. 14 para. 39(1)(a) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(c)(i) Sch. 14 para. 39(1)(aa) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(c)(ii) Sch. 14 para. 39(2)(aa) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(6)(c)(iii) Word in Sch. 14 para. 50 cross-heading inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 49(a), 53(5)-(13) Words in Sch. 14 para. 50(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 49(b)(i), 53(5)-(13) Words in Sch. 14 para. 50(2) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 49(b)(ii), 53(5)-(13) Words in Sch. 14 para. 50(2) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 49(b)(iii), 53(5)-(13) Words in Sch. 14 para. 51(5) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 37(2)(a)(i) Words in Sch. 14 para. 51(5) inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 37(2)(a)(ii) Sch. 14 para. 51(6) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 37(2)(b) Sch. 14 para. 51(7) omitted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 37(2)(b) Words in Sch. 15 para. 1(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 50, 53(5)-(13) Sch. 15 para. 1(1)(aa) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(2)(a) Words in Sch. 15 para. 2(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 50, 53(5)-(13) Sch. 15 para. 2(1)(za) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 24, 72(3)(a) Sch. 15 para. 2(1)(e) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(2), 72(1)(c) Sch. 15 para. 2(1)(ea) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(2)(b)(i) Sch. 15 para. 2(1)(fa) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(2)(b)(ii) Sch. 15 para. 2(1)(ha) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(2), 10 Sch. 15 para. 2(1)(k) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 40(2) Sch. 15 para. 2(1)(l) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(4) Sch. 16 para. 2(1)(b)(ba) substituted for Sch. 16 para. 2(1)(b) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(a) Word in Sch. 16 para. 2(3)(a) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 21(2)(a), 53(2) Words in Sch. 16 para. 2(3)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(2) Sch. 16 para. 2(3)(c) and word inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 21(2)(b), 53(2) Sch. 16 para. 2(3A) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(3) Words in Sch. 16 para. 2(4)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(b)(i) Sch. 16 para. 2(4)(b)(i)(ii) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(b)(ii) Words in Sch. 16 para. 2(5)(b) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(4) Words in Sch. 16 para. 2(6) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(c) Sch. 16 para. 2(7) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(5) Words in Sch. 16 para. 2(9) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(6)(a) Words in Sch. 16 para. 2(9) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(6)(b) Words in Sch. 16 para. 2(9) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 38(6)(c) Words in Sch. 16 para. 2(11) renumbered as Sch. 16 para. 2(11)(a) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(d)(i) Words in Sch. 16 para. 2(11) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(7) Sch. 16 para. 2(11)(b) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(2)(d)(ii) Sch. 16 para. 2(12)(13) inserted ( with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 38(8) Sch. 16 para. 2A and cross-heading inserted (in relation to accounting periods beginning on or after 31.12.2023) by Finance Act 2026 (c. 11), Sch. 8 paras. 51, 53(4) Words in Sch. 16 Pt. 2 Ch. 1 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(2), 10 Sch. 16 para. 3(1)(1A) substituted for Sch. 16 para. 3(1) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 39(2) Words in Sch. 16 para. 3(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(a), 72(4) Words in Sch. 16 para. 3(2)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(b), 72(4) Words in Sch. 16 para. 3(2)(c)(ii) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 34(3)(a) Sch. 16 para. 3(4) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 34(3)(b) Sch. 16 para. 3(7)-(9) substituted for Sch. 16 para. 3(7)(8) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 29(2) Words in Sch. 16 para. 3(7) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(c), 72(4) Sch. 16 para. 3(7A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(d), 72(4) Sch. 16 para. 3(10) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(e), 72(4) Word in Sch. 16 para. 4(1)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(a)(i), 72(4) Words in Sch. 16 para. 4(1)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(a)(ii), 72(4) Sch. 16 para. 4(1)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(b), 72(4) Sch. 16 para. 4(1A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(4), 72(4) Word in Sch. 16 para. 4(3) omitted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by virtue of Finance Act 2024 (c. 3), Sch. 12 para. 39(3)(a)(i) Sch. 16 para. 4(3)(d) and word inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 39(3)(a)(ii) Word in Sch. 16 para. 4(3)(d) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(5), 72(4) Words in Sch. 16 para. 4(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 47(3), 72(2) Word in Sch. 16 para. 4(5) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 39(3)(b) Sch. 16 para. 4A and cross-heading inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(6), 72(4) Sch. 16 para. 5 renumbered as Sch. 16 para. 5(1) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(7)(a), 72(4) Word in Sch. 16 para. 5(1) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 21(3)(a)(i), 53(2) Sch. 16 para. 5(1)(c) and word inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 21(3)(a)(ii), 53(2) Sch. 16 para. 5(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(7)(b), 72(4) Word in Sch. 16 para. 6(6) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 39(4) Sch. 16 paras. 6A, 6B and cross-headings inserted (in relation to accounting periods commencing on or after 31.12.2023 (subject to sub-paragraph (2) of the amending paragraph)) by Finance Act 2025 (c. 8), Sch. 4 para. 47(1)(2), 72(2) Words in Sch. 16 Pt. 2 Ch. 2 heading inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(3), 10 Sch. 16 para. 10 renumbered as Sch. 16 para. 10(1) (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(3)(a) Words in Sch. 16 para. 10(1) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(3)(b)(i) Words in Sch. 16 para. 10(1) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(3)(b)(ii) Word in Sch. 16 para. 10(1)(a) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(3)(c) Sch. 16 para. 10(2)(3) inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(3)(d) Sch. 16 Pt. 2A inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(4), 10 Sch. 16 Pt. 3 inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 40(1) Sch. 16 Pt. 4 inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 21(4), 53(2) Sch. 16A inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(1) Words in Sch. 16A para. 1(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(i), 72(1)(d) Word in Sch. 16A para. 1(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(ii), 72(1)(d) Sch. 16A para. 1(3)(ba) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(iii), 72(1)(d) Sch. 16A para. 1(5) inserted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 5, 53(1) Sch. 16A para. 2 renumbered as Sch. 16A para. 2(1) (7.11.2024) by Finance Act 2025 (c. 8), Sch. 4 para. 51(3)(b)(i)(4) Words in Sch. 16A para. 2(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(b)(ii), 72(1)(d) Sch. 16A para. 2(1A)-(1C) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(b)(iii), 72(1)(d) Sch. 16A para. 2(2) omitted (in relation to accounting periods beginning on or after 31.12.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 31, 53(1) Sch. 16A para. 2(3) omitted (in relation to accounting periods beginning on or after 31.12.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 31, 53(1) Words in Sch. 16A para. 3(1) substituted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(2)(a), 53(2) Sch. 16A para. 3(7)(8) inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(2)(b), 53(2) Sch. 16A para. 3(9) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 25, 53(5)-(13) Sch. 16A para. 4(1)(a) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 22(3)(a), 53(2) Words in Sch. 16A para. 4(1)(b) substituted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(3)(b)(i), 53(2) Sch. 16A para. 4(1)(b): the inserted sub-paragraph (7) becomes an inserted unnumbered sub-paragraph (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(3)(b)(ii), 53(2) Words in Sch. 16A para. 4(1)(b) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 71, 72(4) Sch. 16A para. 5(1)(b)(i) omitted (in relation to accounting periods ending on or after 21.7.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 22(4)(a), 53(2) Words in Sch. 16A para. 5(1)(b)(ii) substituted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(4)(b)(i), 53(2) Sch. 16A para. 5(1)(b)(ii): the inserted sub-paragraph (7) becomes an inserted unnumbered sub-paragraph (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 22(4)(b)(ii), 53(2) Sch. 16A Pt. 2 inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(5), 10 Sch. 16A para. 7(6) inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 27, 53(5)-(13) Sch. 16A Pt. 3 inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 39, 53(5)-(13) Words in Sch. 17 Table inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 18(5) Words in Sch. 17 Table inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(4)(c) Words in Sch. 17 Table inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 2(7) Word in Sch. 17 Table substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(4)(a) Word in Sch. 17 Table substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 58(4)(b) Words in Sch. 17 Table inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(1), 10 Words in Sch. 17 Table inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 47(5), 72(2) S. 51(2) modified (31.7.2023) by The Finance (No. 2) Act 2023, Part 2 (Alcohol Duty) (Appointed Day, Savings, Consequential Amendments and Transitional Provisions) Regulations 2023 (S.I. 2023/884), reg. 6 S. 52(3)(b) modified (31.7.2023) by The Finance (No. 2) Act 2023, Part 2 (Alcohol Duty) (Appointed Day, Savings, Consequential Amendments and Transitional Provisions) Regulations 2023 (S.I. 2023/884), reg. 6 S. 58(b) modified (31.7.2023) by The Finance (No. 2) Act 2023, Part 2 (Alcohol Duty) (Appointed Day, Savings, Consequential Amendments and Transitional Provisions) Regulations 2023 (S.I. 2023/884), reg. 6 S. 78(4)(b) modified (31.7.2023) by The Finance (No. 2) Act 2023, Part 2 (Alcohol Duty) (Appointed Day, Savings, Consequential Amendments and Transitional Provisions) Regulations 2023 (S.I. 2023/884), reg. 6 S. 86(2)(a)(i) modified (31.7.2023) by The Finance (No. 2) Act 2023, Part 2 (Alcohol Duty) (Appointed Day, Savings, Consequential Amendments and Transitional Provisions) Regulations 2023 (S.I. 2023/884), reg. 6 Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3) S. 349 power extended (18.3.2026) by Finance Act 2026 (c. 11), s. 276 An Act to make provision in connection with finance. Most Gracious Sovereign We , Your Majesty’s most dutiful and loyal subjects, the Commons of the United Kingdom in Parliament assembled, towards raising the necessary supplies to defray Your Majesty’s public expenses, and making an addition to the public revenue, have freely and voluntarily resolved to give and to grant unto Your Majesty the several duties hereinafter mentioned; and do therefore most humbly beseech Your Majesty that it may be enacted, and be it enacted by the King’s most Excellent Majesty, by and with the advice and consent of the Lords Spiritual and Temporal, and Commons, in this present Parliament assembled, and by the authority of the same, as follows:—
Income tax is charged for the tax year 2023-24.
For the tax year 2023-24 the main rates of income tax are as follows—
the basic rate is 20%,
the higher rate is 40%, and
the additional rate is 45%.
For the tax year 2023-24 the default rates of income tax are as follows—
the default basic rate is 20%,
the default higher rate is 40%, and
the default additional rate is 45%.
For the tax year 2023-24 the savings rates of income tax are as follows—
the savings basic rate is 20%,
the savings higher rate is 40%, and
the savings additional rate is 45%.
For the tax year 2023-24 the amount specified in section 12(3) of ITA 2007 (the starting rate limit for savings) is “£5,000”.
Accordingly, section 21 of that Act (indexation) does not apply in relation to the starting rate limit for savings for that tax year.
Corporation tax is charged for the financial year 2024.
The main rate of corporation tax for that year is 25%.
For the purposes of Part 3A of CTA 2010, for the financial year 2024—
the standard small profits rate is 19%, and
the standard marginal relief fraction is 3/200ths.
Part 2 of CAA 2001 (plant and machinery allowances) has effect as if the following amendments were made.
section 45S expenditure on plant or machinery in other cases
Chapter 4 has effect as if after section 45R there were inserted—
Section 46 (general exclusions) has effect as if—
section 45S expenditure on plant or machinery in other cases
after subsection (4) there were inserted—
Expenditure qualifying under section 45S (expenditure on plant or machinery in other cases) which is not special rate expenditure 100% Expenditure qualifying under section 45S (expenditure on plant or machinery in other cases) which is special rate expenditure 50%
Chapter 5 has effect as if after section 59 there were inserted—
The amount of £1,000,000 which is specified in section 51A(5) of CAA 2001 as the maximum allowance in relation to expenditure incurred in the period beginning with 1 January 2019 and ending with 31 March 2023 is to be the amount of the maximum allowance in relation to expenditure incurred on or after 1 April 2023 (as well as in relation to expenditure incurred in that period).
Accordingly—
in section 51A of CAA 2001, for the amount specified in subsection (5) as the maximum allowance (which in the absence of this section would be £200,000 in relation to expenditure incurred on or after 1 April 2023) substitute “£1,000,000”, and
the temporary AIA transitional provisions cease to have effect in relation to chargeable periods beginning before 1 April 2023 and ending on or after that date.
For this purpose “the temporary AIA transitional provisions” means—
paragraphs 2 and 3 of Schedule 13 to FA 2019, and
section 32 of FA 2019, section 15 of FA 2021 and section 12 of FA 2022 so far as relating to those paragraphs.
In section 45EA of CAA 2001 (expenditure on plant or machinery for electric vehicle charging point), in subsection (3) (the relevant period), in paragraphs (a) and (b), for “2023” substitute “2025”.
Schedule 1 makes provision in relation to the corporation tax relief contained in Chapter 6A of Part 3 of CTA 2009 (trade profits: R&D expenditure credits) and Part 13 of CTA 2009 (additional relief for expenditure on research and development)—
conferring relief in respect of expenditure on data and cloud computing services,
about the administration and management of claims for relief,
about the circumstances in which an enterprise counts as a small or medium-sized enterprise and in which accounts are to be treated as prepared on a going concern basis, and
limiting relief for expenditure incurred on payments to expenditure incurred on payments made before the making of a claim for the relief.
In section 357A of CTA 2010 (election for special treatment of profits from patents etc), in subsection (3)—
in the formula, in both places it occurs, for “MR” substitute “AR”;
for the definition of “MR” substitute—
The amendments made by subsection (1) have effect in relation to accounting periods beginning on or after 1 April 2023.
The Energy (Oil and Gas) Profits Levy Act 2022 is amended as follows.
In section 2 (additional expenditure treated as incurred for purposes of section 1), for subsection (3) substitute—
In that section, after subsection (4) insert—
After that section insert—
In section 3 (section 2: meaning of “operating expenditure”), for subsection (5) substitute—
In section 18(1) (interpretation)—
after the definition of “energy (oil and gas) profits levy” insert—, and
omit the “and” before the definition of “ring fence trade” and after that definition insert—
The amendments made by subsections (2) to (4) have effect in relation to expenditure incurred on or after 1 January 2023 and the amendments made by subsections (5) and (6) have effect in relation to expenditure incurred on or after 26 May 2022.
In section 1218ZCG(1)(c) of CTA 2009 (date before which qualifying expenditure must be incurred), for “2024” substitute “2026”.
In each of the following provisions of FA 2022— for “2023” substitute “2025”.
section 17(2) (temporary increase in amount of theatre tax credit),
section 19(2) (corresponding provision for orchestra tax credit), and
section 21(2) (corresponding provision for museums and galleries exhibition tax credit),
In each of the following provisions of that Act (which provide for an increase in the amount of those credits for a further year but at a lower rate than that provided for by sections 17(2), 19(2) and 21(2))— for “2023” substitute “2025” and for “2024” substitute “2026”.
section 17(3),
section 19(3), and
section 21(3),
In each of the following provisions of that Act (which deal with straddling periods for those credits)— for “2023” substitute “2025” and for “2024” substitute “2026”.
section 17(4),
section 19(4), and
section 21(4),
Part 5A of ITA 2007 (seed enterprise investment scheme) is amended in accordance with subsections (2) to (5).
In section 257AB (form and amount of SEIS relief), in subsection (2)(b), for “£100,000” substitute “£200,000”.
In section 257DI (the gross assets requirement)—
in subsection (1), for “£200,000” substitute “£350,000”;
in subsection (2), for “£200,000” substitute “£350,000”.
In section 257DL (the amount raised through the SEIS), in each of the following provisions, for “£150,000” substitute “£250,000”—
subsection (1);
subsection (4)(a);
subsection (4)(b);
in subsection (6), the definition of “A”.
In section 257HF (meaning of “new qualifying trade”)—
in subsection (1)(a), for “two” substitute “three”;
in subsection (2), for the definition of “two year pre-investment period” substitute—
In Schedule 5BB to TCGA 1992 (seed enterprise investment scheme: re-investment), in paragraph 2—
in sub-paragraph (1), for “£100,000” substitute “£200,000”;
in sub-paragraph (2), in the formula, for “£100,000” substitute “£200,000”.
The amendments made by this section have effect in relation to shares issued on or after 6 April 2023.
Schedule 4 to ITEPA 2003 (CSOP schemes) is amended as follows.
In paragraph 6 (limit on value of shares subject to options)—
in sub-paragraph (1), in the words after paragraph (b), for “£30,000” substitute “£60,000”;
The Treasury may by regulations amend sub-paragraph (1) by substituting a different sum of money for the sum for the time being specified there.
In paragraph 15 (requirements relating to shares that may be subject to share options: introduction), in sub-paragraph (1)—
after the entry for paragraph 17 insert “, and”;
omit the entry for paragraph 20 and the “, and” before it.
Omit paragraph 20 (requirements as to other shareholdings).
In paragraph 27 (requirement about share options granted in exchange), in sub-paragraph (4)(a), for “20” substitute “18”.
The amendments made by subsection (2) have effect for the purposes of determining whether a share option may be granted to an individual on or after 6 April 2023 (“the commencement day”).
The amendments made by subsections (3) and (4) have effect in relation to—
share options granted on or after the commencement day, and
shares acquired by the exercise of share options on or after the commencement day (regardless of when those share options were granted).
The amendment made by subsection (5) has effect in relation to share options granted on or after the commencement day.
A CSOP scheme which was approved by, or notified to, His Majesty’s Revenue and Customs before the commencement day has effect on and after the commencement day with any modifications needed to reflect the amendments made by this section.
In particular, such a CSOP scheme has effect from the commencement day with—
the substitution of “£60,000” for “£30,000” in any provision required by paragraph 6 of Schedule 4 to ITEPA 2003;
the omission of any provision that (before the amendments made by this section) was required by paragraph 20 of that Schedule by virtue of paragraph 15(1) of that Schedule.
In this section, “CSOP scheme” and “share option” have the same meaning as in the CSOP code (see paragraph 37 of Schedule 4 to ITEPA 2003).
Schedule 5 to ITEPA 2003 (enterprise management incentives) is amended as follows.
In Part 5 (requirements relating to options), in paragraph 37 (terms of option to be agreed in writing) omit sub-paragraphs (4) and (5).
In Part 7 (notification of option to HMRC), in paragraph 44 (notice of option to be given to HMRC)—
in sub-paragraph (5)—
after paragraph (a) insert “and”;
omit paragraph (c) and the “, and” immediately before it;
omit sub-paragraphs (5A) and (6).
In Part 8 (supplementary provisions) omit paragraph 57A (penalty for non-compliance with paragraph 44(5A)).
The amendments made by this section have effect in relation to—
share options granted on or after 6 April 2023, or
share options granted before 6 April 2023 which are capable of being exercised on or after that date (“relevant options”).
But if— the employer company must, on or before the relevant day, make arrangements for determining which of the relevant options, or the extent to which those options, are to take the benefit of subsection (5)(b) without a relevant requirement not being met in relation to any share options granted before 6 April 2023.
an employer company has granted relevant options to persons by reason of their employment with the company, and
the effect of subsection (5)(b) would otherwise be that a relevant requirement would not be met in relation to one or more share options granted before 6 April 2023,
The arrangements must—
set out the criteria by reference to which the determination will be made, and
be made available to persons who may be affected by the determination.
If the employer company fails to make arrangements in accordance with subsection (7) in a case where it is required to do so by subsection (6), which relevant options, or the extent to which those options, take the benefit of subsection (5)(b) is to be determined in the chronological order in which those options were granted (and where two or more relevant options were granted at the same time, the extent to which those options take the benefit of subsection (5)(b) is, where necessary, to be apportioned between those options).
In this section—
“third currency” means any currency which is neither the accounting currency nor the tax currency of the member;
the “lump sum exit scheme” means the Agriculture (Lump Sum Payment) (England) Regulations 2022 (S.I. 2022/390);
“relevant requirement” means any of the requirements in paragraphs 5(1), 6(2) or (4) or 7(1) of Schedule 5 to ITEPA 2003;
“share option” and “employer company” have the same meaning as in the EMI code (see paragraph 59 of Schedule 5 to ITEPA 2003).
No lifetime allowance charge arises for the tax year 2023-24 or any subsequent tax year.
Subsection (1) does not affect the continued operation of any provision of Part 4 of FA 2004 (pension schemes etc) so far as it has effect for purposes other than that of determining a person’s liability for the lifetime allowance charge.
Subsection (2) applies to any relevant lump sum, or any part of a relevant lump sum, that—
is paid under a registered pension scheme, and
would, disregarding section 18, have been chargeable to income tax under sections 214 to 226 of FA 2004 (lifetime allowance charge).
Section 579A of ITEPA 2003 (pensions under registered pension schemes) applies in relation to the relevant lump sum or part of the relevant lump sum as it applies to any pension under a registered pension scheme.
Subsection (4) applies to any lump sum, or any part of a lump sum, that—
is paid under a relieved non-UK pension scheme,
would have been a relevant lump sum within subsection (5)(a), (c) or (d) if it had been paid under a registered pension scheme, and
would, disregarding section 18, have been chargeable to income tax under sections 214 to 226 of FA 2004 (as applied by paragraphs 13 to 19 of Schedule 34 to FA 2004 (application of lifetime allowance charge to non-UK schemes)).
Section 573 of ITEPA 2003 (foreign pensions) applies in relation to the lump sum or part of the lump sum as it applies to any pension paid by or on behalf of a person who is outside the United Kingdom to a person who is resident in the United Kingdom.
In this section “relevant lump sum” means—
a serious ill-health lump sum,
a lifetime allowance excess lump sum,
a defined benefits lump sum death benefit, or
an uncrystallised funds lump sum death benefit;
Expressions used in subsection (5) have the same meaning as in Part 4 of FA 2004 (see Schedule 29 to that Act).
In this section—
“registered pension scheme” has the same meaning as in Part 4 of FA 2004 (see section 150(2) of that Act);
“food and drink flavourings” means any qualifying flavourings which are for use in—
a member of a multinational group is a “low tax member” in an accounting period if the effective tax rate for the standard members of the group located in the member’s territory for that period would, ignoring intra-group financing arrangements, be less than 15%;
the preparation of any beverage of an alcoholic strength not exceeding 1.2%;
This section has effect for the tax year 2023-24 and subsequent tax years.
In Part 4 of FA 2004 (pension schemes etc), section 228 (annual allowance) is amended as follows.
For subsection (1) substitute—
In subsection (2) for “2014-15” substitute “2023-24”.
Part 4 of FA 2004 (pension schemes etc) is amended as follows.
In the following provisions, for “£4,000” substitute “£10,000”—
section 227ZA(1)(b);
section 227B(1)(b) and (2);
in section 227D(4), Steps 4 and 5.
In consequence of the amendments made by this section, in F(No.2)A 2017, omit section 7.
The amendments made by this section have effect for the tax year 2023-24 and subsequent tax years.
In Part 4 of FA 2004 (pension schemes etc), section 228ZA (tapered reduction of annual allowance) is amended as follows.
In subsection (1)—
for “£4,000” substitute “£10,000”;
for “£240,000” substitute “£260,000”.
In subsection (3)(a) and (b), for “£240,000” substitute “£260,000”.
The amendments made by this section have effect for the tax year 2023-24 and subsequent tax years.
In Part 4 of FA 2004 (pension schemes etc), Schedule 36 (transitional provisions) is amended in accordance with subsections (2) and (3).
In paragraph 12 (enhanced protection), in sub-paragraph (2), after “ceases to apply if” insert “the notice under sub-paragraph (1) is given on or after 15 March 2023 and”.
In paragraph 27 (enhanced protection: modifications of paragraph 2 of Schedule 29), in sub-paragraph (3), in the substituted sub-paragraph (5) of paragraph 2, for the words after “the permitted maximum is” substitute the lower of—
In the Taxation of Pension Schemes (Transitional Provisions) Order 2006 (S.I. 2006/572), in article 25C (payment of stand-alone lump sums: tax consequences), for paragraph (3) substitute—
In FA 2011, in Schedule 18, in paragraph 14 (fixed protection 2012) in sub-paragraph (4), after “ceases to apply if” insert “the notice under sub-paragraph (1) or (as the case may be) sub-paragraph (1A) is given on or after 15 March 2023 and,”.
In FA 2013, in Schedule 22, in paragraph 1 (fixed protection 2014), in sub-paragraph (3), after “ceases to apply if” insert “the notice under sub-paragraph (1) is given on or after 15 March 2023 and,”.
In FA 2016, in Schedule 4, in Part 1 (fixed protection 2016), in paragraph 3, after “There is a protection-cessation event if” insert “the reference number for the purposes of paragraph 1(2) was issued pursuant to an application made on or after 15 March 2023 and”.
The amendments made by this section have effect for the tax year 2023-24 and subsequent tax years.
Part 4 of FA 2004 (pension schemes) is amended in accordance with subsections (2) to (8).
In section 152 (meaning of arrangement), in subsection (5A)—
the words after “means benefits that are” become paragraph (a);
at the end of that paragraph insert “, or”;
after that paragraph insert—
In section 169 (recognised transfers), after subsection (1E) insert—
In section 279 (other definitions), after subsection (1E) insert—
CMP-derived drawdown pension section 279(1F)” CMP periodic income section 279(1G)
Where, immediately before the member’s death, the member is actually or prospectively entitled to CMP periodic income, any CMP periodic income that is at any later time payable to a dependant of the member is to be ignored for the purposes of paragraphs 16AA to 16B.
A lump sum is an excluded lump sum if the pension in connection with which the member becomes entitled to it is a CMP-derived drawdown pension.
In Schedule 32 (benefit crystallisation events - supplementary), for paragraph 2B substitute—
In consequence of the amendments made by the preceding provisions of this section, the following provisions of Schedule 5 to FA 2021 are omitted—
paragraph 21(2)(b);
paragraph 22(2).
The Registered Pension Schemes (Transfer of Sums and Assets) Regulations 2006 (S.I. 2006/499) are amended in accordance with subsections (11) and (12).
In regulation 3 (scheme pension payable by registered pension scheme - recognised transfers), at the end insert—
In regulation 5 (term and reduction in rate of scheme pension), in paragraph (1), in the opening words, for “3 or 4” substitute “3(1) or (2) or regulation 4,”.
In FA 2004, in Part 4 (pension schemes etc), in Chapter 4 (certain tax reliefs and exemptions), after section 193 (relief under net pay arrangements) insert—
After section 776 of ITTOIA 2005 insert—
The amendment made by this section has effect in relation to payments made on or after 1 April 2022.
The Treasury may by regulations amend Chapter 3 of Part 10 of ITEPA 2003 (taxable UK social security benefits) so as to provide that a specified devolved social security benefit is chargeable to income tax.
A “specified devolved social security benefit” means a social security benefit which is—
payable under or by virtue of a post-commencement devolved enactment, and
specified in regulations under this section.
A “post-commencement devolved enactment” means an enactment which is—
contained in, or in an instrument made under—
an Act of the Scottish Parliament;
an Act of Senedd Cymru;
Northern Ireland legislation, and
passed or made on or after the day on which this Act is passed.
Regulations under this section may make—
different provision for different cases;
incidental, supplementary or consequential provision (which may include provision amending any provision made by or under the Income Tax Acts).
section 27 of F(No. 2)A 2023 (power to clarify tax treatment of devolved social security benefits).
Chapter 2 of Part 7 of ITTOIA 2005 (qualifying care relief) is amended as follows.
In section 808 (the individual’s limit)—
in subsection (2), for “£10,000” substitute “£18,140”, and
omit subsection (3) (which confers a power to amend that amount).
In section 811 (the amount per adult or child)—
in subsection (1A) (weekly amount for adult), for “£250” substitute “£450”,
in subsection (2)(a) (weekly amount for children under 11 years old), for “£200” substitute “£375”,
in subsection (2)(b) (weekly amount for older children), for “£250” substitute “£450”, and
omit subsection (3) (which confers a power to amend those amounts).
After section 828 insert—
In section 873(3) (orders made by Treasury etc not subject to negative resolution procedure), after paragraph (c) (but before the “or” at the end) insert—.
The amendments made by this section have effect for the tax year 2023-24 and subsequent tax years.
Schedule 2 contains amendments relating to estates in administration and trusts.
In Part 2 of FA 2012 (insurance companies carrying on long-term business), after section 130 insert—
The amendment made by this section is treated as having come into force on 15 December 2022 and applies to the re-insurance of basic life assurance and general annuity business whenever the arrangements for that re-insurance were made.
Where, on or after 15 December 2022, a re-insurer adopts IFRS 17 in relation to one or more accounting periods that commence before that date, the amendment made by this section has effect, in relation to that re-insurer, for those accounting periods.
In subsection (3) “IFRS 17” means International Financial Reporting Standard 17 (insurance contracts) issued by the International Accounting Standards Board.
Section 92 of FA 2012 (certain BLAGAB trading receipts to count as deemed I-E receipts) is amended as follows.
In subsection (5)—
after paragraph (a) insert—, and
in paragraph (b), after “sums” insert “, other than sums falling within paragraph (aa),”.
In subsection (6), in the words before paragraph (a), after “contract” insert “, other than a sum falling within paragraph (aa),”.
The amendments made by this section have effect for accounting periods ending on or after 15 December 2022.
In Part 3 of CTA 2009 (trading income), after section 130 insert—
Part 5 of CTA 2009 (loan relationships) is amended as follows.
After section 323A insert—
In section 465B (“tax-adjusted carrying value”), in subsection (9), after paragraph (d) insert—.
In Part 4 of FA 2004 (pension schemes), Schedule 28 (registered pension schemes: authorised pensions - supplementary) is amended as follows.
In paragraph 3 (definition of “lifetime annuity”), in sub-paragraph (2A)—
the words after “by reason of the operation of” become paragraph (a);
at the end of that paragraph insert “, or”;
after that paragraph insert—
In paragraph 17 (definition of “dependants’ annuity”), in sub-paragraph (2)—
the words after “by reason of the operation of” become paragraph (a);
at the end of that paragraph insert “, or”;
after that paragraph insert—
Schedule 3 makes provision about corporate interest restriction and the tax treatment of financing costs and income.
Schedule 4 makes amendments to—
Schedule 5AAA to TCGA 1992 (UK property rich collective investment vehicles etc),
Part 12 of CTA 2010 (Real Estate Investment Trusts) and the Real Estate Investment Trusts (Assessment and Recovery of Tax) Regulations 2006 (S.I. 2006/2867), and
Schedule 2 to FA 2022 (qualifying asset holding companies).
TCGA 1992 is amended in accordance with subsections (2) and (3).
After section 138 (exchange of securities and schemes of reconstruction: procedure for clearance in advance) insert—
In section 288 (interpretation), in the definition of “close company”, at the end insert “(subject to section 138ZA(6))”.
The amendments made by subsections (2) and (3) have effect in relation to an issue of shares or debentures made on or after 17 November 2022.
In section 830 of ITTOIA 2005 (meaning of “relevant foreign income”), after subsection (3) insert—
The amendment made by subsection (5) is treated as having come into force on 17 November 2022.
Schedule 5 makes provision about the keeping of records for the purposes of Part 4 of TIOPA 2010.
No extended time limit claim may be made on or after 20 July 2022 for a credit calculated by reference to a foreign nominal rate of tax unless subsection (2) or (3) applies in relation to the claim.
This subsection applies in relation to an extended time limit claim if the adjustment in the amount of tax payable that gives rise to the claim—
is not calculated by reference to a foreign nominal rate of tax, and
occurred on or after 21 July 2016 but before 20 July 2022.
This subsection applies in relation to an extended time limit claim if the claim relates to an accounting period that ended before 20 July 2022 (“the relevant accounting period”) and as at that date—
an appeal under section 31 of TMA 1970 against an assessment to tax in relation to the relevant accounting period has been brought but has not been finally determined or withdrawn,
an enquiry under paragraph 5 of Schedule 1A to TMA 1970 into a claim in relation to the relevant accounting period could be opened or is in progress,
an appeal against a conclusion stated in respect of such a claim, or an amendment of such a claim, as a result of an enquiry under that paragraph—
could be brought, or
has been brought but has not been finally determined or withdrawn,
an enquiry under Part 4 of Schedule 18 to FA 1998 into the company tax return for the relevant accounting period could be opened or is in progress, or
an appeal against an amendment of that return as a result of an enquiry under that Part—
could be brought, or
has been brought but has not been finally determined or withdrawn.
An “extended time limit claim” is a claim under—
section 79 of TIOPA 2010 (extended time limits for certain claims), or
section 806(2) of ICTA (extended time limits for certain claims in relation to accounting periods to which section 79 of TIOPA 2010 does not apply).
An amount paid to a person (“P”) under the lump sum exit scheme is—
in a case where P satisfied the eligibility conditions when the payment was made, to be treated as an amount of capital nature that is treated as a chargeable gain accruing to P on the disposal of an asset for the purposes of TCGA 1992;
in a case where P did not satisfy the eligibility conditions when the payment was made, to be treated as an amount of a revenue nature.
Where— the amount is to be treated as an amount of capital nature that is treated as a chargeable gain accruing to P on the disposal of an asset for the purposes of TCGA 1992.
a person (“P”) makes an application for a lump sum under the lump sum exit scheme,
P satisfies the eligibility conditions at any time during the interim period, and
during the interim period, an amount is paid to P under the basic payment scheme,
Where— the amount is to be treated as an amount of a revenue nature.
a person (“P”) makes an application for a lump sum under the lump sum exit scheme,
P does not satisfy the eligibility conditions at any time during the interim period, and
during the interim period, an amount is paid to P under the basic payment scheme,
For the purposes of this section—
the “basic payment scheme” means Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17 December 2013 establishing rules for direct payments to farmers under support schemes within the framework of the common agricultural policy and repealing Council Regulation (EC) No 637/2008 and Council Regulation (EC) No 73/2009;
“property, plant and equipment” has the meaning given, for the time being, by International Accounting Standard 16.
the “scheme end date” has the same meaning as in the lump sum exit scheme (see regulation 2(1) of that scheme).
“accounting currency” means the currency of the main economic environment in which a member of a multinational group operates;
This section has effect in relation to amounts whether paid before or after the coming into force of this Act.
In TCGA 1992, after section 28 (time of disposal and acquisition where asset disposed of under contract) insert—
The amendment made by subsection (1) has effect—
for the purposes of corporation tax, in relation to any disposal and acquisition of an asset under a contract that is entered into on or after 1 April 2023, and
for all other purposes, in relation to any disposal and acquisition of an asset under a contract that is entered into on or after 6 April 2023.
TCGA 1992 is amended in accordance with subsections (2) to (5).
In Part 3 (individuals, partnerships, trusts and collective investment schemes), in Chapter 1 (miscellaneous provisions), in section 58 (spouses and civil partnerships), for subsection (1) substitute—
In section 225B (disposals in connection with divorce etc)—
in subsection (1)(b), after “to” insert “someone other than”;
in subsection (3), after “disposal to” insert “someone other than”.
After section 225B insert—
In Part 8 (supplemental), in section 288 (interpretation), in subsection (3), after “partner” insert “(however expressed)”.
The amendments made by this section apply in relation to disposals made on or after 6 April 2023.
TCGA 1992 is amended as follows.
After section 103KF insert—
In section 1H (the main rates of CGT), in subsection (9)—
omit the “or” at the end of paragraph (a), and
after that paragraph insert—.
The amendments made by this section have effect for the tax year 2022-23 and subsequent tax years.
In section 248A of TCGA 1992 (roll-over relief on disposal of joint interests in land: conditions), at end insert—
In section 248E of TCGA 1992 (relief on disposal of joint interests in private residence), at end insert—
The amendments made by this section have effect in relation to disposals made on or after 6 April 2023.
In this Part, “alcoholic product” means any of the following—
spirits,
beer,
cider,
wine, and
any other fermented product.
But a product listed in subsection (1) is not an alcoholic product if it is of an alcoholic strength of 1.2% or less.
Schedule 6 defines each category of alcoholic product (and makes further provision in connection with the definitions).
The “alcoholic strength” of an alcoholic product is the ratio, expressed as a percentage, of—
the volume of the alcohol contained in the product, to
the volume of the product (inclusive of the alcohol contained in it).
The alcoholic strength of any alcoholic product is to be determined by reference to the product as at 20°C.
The Commissioners may by regulations make provision about the means of ascertaining the alcoholic strength, weight or volume of any alcoholic product or other substance (including products or substances that are not in liquid form at 20°C) for the purposes of this Part.
Regulations under subsection (3) may, in particular, include provision for ascertaining the alcoholic strength, weight or volume of anything contained in a bottle or container by reference to information given on the bottle or container or in documents relating to it.
In this Part, “alcohol” means ethanol.
The Treasury may by regulations—
amend Schedule 6;
provide that a beverage of an alcoholic strength exceeding 1.2%, of a description specified by or under the regulations, is to be treated as being an alcoholic product of a particular category listed in section 44 (whether or not it would otherwise fall within another category listed in that section).
An excise duty (“alcohol duty”) is charged on alcoholic products that are produced in, or imported into, the United Kingdom.
But subsection (1) is subject to the exemptions in Chapters 4 and 6.
Alcohol duty is charged at the rates shown in Schedule 7.
But subsection (1) is subject to—
section 50 (draught relief), and
section 54 (small producer relief).
Alcohol duty is to be paid, and the amount chargeable is to be determined and become due, in accordance with provision made by or under—
section 88;
section 1 of F(No. 2)A 1992.
In this Part, “excise duty point” has the meaning given by section 1 of F(No. 2)A 1992.
Alcohol duty is charged on qualifying draught products at the reduced rates shown in Schedule 8 (instead of at the rates shown in Schedule 7 (the “full rates”)).
But a person liable to pay alcohol duty on qualifying draught products may, for the purposes of section 52(2), elect for duty to be charged at the full rates.
“Qualifying draught products” means alcoholic products that—
are of an alcoholic strength of less than 8.5%, and
at the excise duty point are contained in, or are being transported to a place in the United Kingdom for the purpose of being transferred to, a large draught container.
But alcoholic products that are produced in the United Kingdom by a person otherwise than in accordance with an approval under section 82 are not qualifying draught products.
A “large draught container” means a container which—
is of a capacity of at least 20 litres, and
incorporates, or is designed to connect to, a qualifying system for dispensing individual drinks.
For the purposes of subsection (3)(b), “qualifying system” means—
a pressurised gas delivery system, or
a pump delivery system.
The Commissioners may by regulations—
amend subsection (3)(a) so as to specify a different capacity;
amend subsection (4) so as to add or remove, or to vary the description of, a qualifying system.
For the purposes of this section, qualifying draught products are “repackaged” if—
they are transferred to containers that are not large draught containers, but
are not transferred in the course of serving a beverage for immediate consumption.
A person may not repackage qualifying draught products on any premises in the United Kingdom unless—
the repackaging is authorised, or
alcohol duty was charged on the products at the full rates, in accordance with an election under section 50(2).
Repackaging is “authorised” if it is carried out by a person who is—
approved and registered under section 100G of CEMA 1979 by virtue of regulation 3 of the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 (S.I. 1999/1278), or
approved under section 82 (producers of alcoholic products).
Where the repackaging of qualifying draught products is authorised, an amount equal to the duty shortfall is treated, for the purposes of this Part, as an amount of alcohol duty charged on the repackaged products.
In this section and in section 53, the “duty shortfall” in relation to repackaged qualifying draught products is the difference between—
the alcohol duty payable on the alcoholic products under section 50(1) (draught products: reduced rates), and
the alcohol duty that would have been payable on the alcoholic products under section 48 (rates) if they had not, at the excise duty point, been qualifying draught products.
For the purposes of subsection (2), the Commissioners may by regulations require a person to provide, on the supply to another person of qualifying draught products in respect of which an election under section 50(2) has been made, information or documents, of a description specified by or under the regulations, as evidence that duty has been charged at the full rates.
This section applies if a person repackages qualifying draught products in contravention of section 52(2).
The Commissioners may—
assess as alcohol duty due from the person mentioned in subsection (1) an amount equal to the duty shortfall, and
notify that person or that person’s representative of any assessment under paragraph (a).
The conduct mentioned in subsection (1) attracts a penalty under section 9 of FA 1994, calculated by reference to the amount of duty referred to in section 52(5)(b).
Any alcoholic products, articles (including packaging or equipment) or substances in the person's possession, used (or which may be used) for or in connection with the repackaging, are liable to forfeiture.
Alcohol duty is charged at the discounted rate on small producer alcoholic products produced in a particular production year (the “current year”).
The discounted rate, in relation to small producer alcoholic products, is equal to—
the standard rate, less
the duty discount for those products (determined in accordance with section 59 and Schedule 9).
In subsection (2)(a), the “standard rate”, in relation to alcoholic products, means—
the rate shown for products of that kind in Schedule 7, or
if Schedule 8 applies (and no election has been made under section 50(2)) in relation to the products) the rate shown for products of that kind in that Schedule.
For the purposes of this Chapter—
a “production year” is a period of 12 months beginning with 1 February;
the “previous year”, in relation to alcoholic products, is the production year immediately preceding the current year in relation to those products.
“Small producer alcoholic products” are alcoholic products that—
are of an alcoholic strength of less than 8.5%,
are produced on premises that are small production premises,
are not produced under licence, and
meet such other conditions (if any) as are specified by regulations made by the Commissioners.
Subsection (1) is subject to section 58 (exclusions).
Production premises are “small production premises” in the current year in relation to alcoholic products if—
the production limit condition is met, and
the unlicensed product condition is met.
The “production limit condition” is met in relation to non-group premises if, in relation to those premises, neither of the following amounts exceeds the small production limit—
the alcohol production amount for the previous year;
the estimated alcohol production amount for the current year,
The “production limit condition” is met in relation to group premises if neither of the following amounts exceeds the small production limit—
the aggregate of the alcohol production amount, in relation to every set of premises in the production group, for the previous year;
the aggregate of the estimated alcohol production amount, in relation to every set of premises in the production group, for the current year.
The “small production limit” is 4500 hectolitres.
The “unlicensed product condition” is met—
in relation to non-group premises if the condition in subsection (6) is met in relation to those premises;
in relation to group premises if the condition in subsection (6) is met in relation to every set of premises in the production group.
The condition is that—
less than half of the alcohol production amount (if any), in relation to the premises, for the previous year was contained in alcoholic products produced under licence, and
the producer reasonably estimates that less than half of the alcohol production amount, in relation to the premises, for the current year will be contained in alcoholic products produced under licence.
In relation to production premises—
the “alcohol production amount” for a production year is the total amount of alcohol contained in alcoholic products produced on those premises in that year, and
the “estimated alcohol production amount” for a production year is the producer’s reasonable estimate of the alcohol production amount for those premises in that year.
Subsection (1) is subject to subsections (3) to (6).
The reference in subsection (1) to the alcoholic products produced on a set of premises does not include a reference to any alcoholic products that are—
spoilt or destroyed before the excise duty point, or
produced in the course of producing a different alcoholic product on those premises or on any set of connected premises.
Subsection (5) applies where premises are in use for the purposes of the production of alcoholic products for part only (the “relevant part”) of a production year (including where premises begin to be used for those purposes part-way through a production year).
The alcohol production amount or (as the case may be) the estimated alcohol production amount is treated, for the purposes of this Part, as being the amount given by—
dividing the actual alcohol production amount, or (as the case may be) the estimate of that amount, by the number of days in the relevant part of the production year, and
multiplying the amount given by paragraph (a) by the number of days in the production year.
The Commissioners may, if satisfied that the circumstances are exceptional, agree with a producer that certain alcoholic products, or a certain quantity of alcoholic products, may be disregarded for the purposes of determining— in relation to production premises for any production year.
the alcohol production amount, or
the estimated alcohol production amount,
Alcoholic products produced on any premises are not “small producer alcoholic products” if—
they are exempt from duty under any of sections 72, 76 or 77,
they are produced in the United Kingdom by a person otherwise than in accordance with an approval under section 82,
at the time they are produced, the alcohol production amount attributable to the premises (in the case of non-group premises) or the production group (in the case of group premises) for the current year has exceeded the small production limit, or
they are produced—
in the case of non-group premises, before the producer has estimated (for the purposes of section 57) the alcohol production amount attributable to the premises for the current year, or
in the case of group premises, before the producer in relation to those premises or any connected premises has estimated (for the purposes of section 57) the alcohol production amount attributable to those premises or any connected premises for that year.
The duty discount, in relation to small producer alcoholic products in a discount band, is the amount (in £ per litre of alcohol) given by the formula in subsection (2) and rounded up to the nearest penny.
The formula is— where— C is the cumulative discount for the discount band (in £); M is the marginal discount for the discount band (in £); A is the relevant production amount (in hectolitres); S is the start threshold for the discount band (in hectolitres).
Where the alcoholic products are produced on non-group premises, the “relevant production amount” is—
the alcohol production amount, in relation to those premises, for the previous year, or
if that amount would be nil, the estimated alcohol production amount in relation to those premises for the current year.
Where the alcoholic products are produced on group premises, the “relevant production amount” is —
the aggregate of the alcohol production amount for the previous year, in relation to every set of premises in the production group on which alcoholic products were produced in that year, or
if there are no premises in the production group on which alcoholic products were produced in the previous year, the aggregate of the estimated alcoholic production amount, in relation to every set of premises in the production group, for the current year.
Small producer alcoholic products are in a particular discount band if the relevant production amount in relation to those products—
exceeds the start threshold for that band, but
does not exceed the end threshold for that band.
The start and end thresholds, cumulative discount and marginal discount for a discount band are the figures shown—
in relation to alcoholic products (other than qualifying draught products referred to in paragraph (b)) of a particular description, in the tables in Part 1 of Schedule 9, and
in relation to qualifying draught products (in respect of which no election has been made under section 50(2)) of a particular description, in the tables in Part 2 of Schedule 9.
This section applies if—
alcohol duty is charged on alcoholic products,
it appears at the excise duty point that the alcoholic products are small producer alcoholic products, and
it turns out that the alcoholic products were not small producer alcoholic products (including where circumstances were not as they appeared at the excise duty point or where circumstances subsequently changed).
This section also applies if—
alcohol duty is charged on small producer alcoholic products, and
the discounted rate that at the excise duty point appeared to be the correct rate turns out to be lower than the correct rate (including where circumstances were not as they appeared at the excise duty point or where circumstances subsequently changed).
The Commissioners—
may assess as being alcohol duty due from the liable person an amount equal to the duty shortfall, and
must notify that person or that person’s representative of any assessment under paragraph (a).
In this section “duty shortfall” means the difference between—
the actual amount of alcohol duty chargeable on the alcoholic products, and
the lower amount that, at the excise duty point, appeared to be the amount chargeable.
The reference in subsection (3) to the “liable person” is a reference to the person liable to pay the alcohol duty on the alcoholic products.
This section and sections 62 to 67 apply where a small producer (“SP1”) becomes connected with another small producer (“SP2”).
“Post-merger production group” means the production group that consists of— and references to “post-merger production group premises” are to premises within paragraph (a) or (b).
every set of premises on which SP1 or SP2 produces alcoholic products, and
every set of connected premises,
In relation to the post-merger production group—
“Year 1” means the production year in which SP1 and SP2 become connected with one another,
“Year 2” means the production year immediately following Year 1,
“Year 3” means the production year immediately following Year 2, and
the “pre-merger year” means the production year immediately preceding Year 1.
Each of Year 1, Year 2 and Year 3 is a “merger transition year” in relation to the post-merger production group, unless any of the following apply—
section 65 (early termination of merger transition period),
section 66 (subsequent mergers), or
section 68(8) (demergers in a merger transition year).
This section (instead of section 56) applies in relation to a post-merger production group in a merger transition year.
Post-merger production group premises are “small production premises” in the current year in relation to alcoholic products if—
the adjusted post-merger amount, determined in accordance with section 64 does not exceed the small production limit (within the meaning of section 56(4)), and
in relation to each set of post-merger production group premises, less than half of the alcohol production amount (if any), in relation to those premises, for the previous year was contained in alcoholic products produced under licence.
This section applies in relation to alcoholic products that are produced—
on post-merger production group premises, and
in a merger transition year.
For the purposes of section 59, references to the “relevant production amount” are references to the adjusted post-merger amount (and subsections (3) and (4) of that section do not apply).
Section 58(c) does not apply for the purposes of the application of section 55 or 59 in a merger transition year.
In Year 1, the adjusted post-merger amount is the alcohol production amount in relation to the larger producer’s premises for the pre-merger year, determined in accordance with section 57 (and the alcohol production amount attributable to the smaller producer for the pre-merger year is disregarded).
In Year 2, the adjusted post-merger amount is the total of—
the adjusted post-merger amount in Year 1, and
one-third of the production difference for Year 2.
In Year 3, the adjusted post-merger amount is the total of—
the adjusted post-merger amount in Year 1, and
two-thirds of the production difference for Year 3.
The amount of the “production difference” for a merger transition year is the difference between—
the aggregate of the alcohol production amount, in relation to every set of post-merger production group premises, for the previous year (determined in accordance with section 57), and
the adjusted post-merger amount in Year 1.
If the alcohol production amount attributable to SP1’s premises for the pre-merger year is greater than the alcohol production amount attributable to SP2’s premises for that year— and vice versa.
SP1 is the “larger producer”, and
SP2 is the “smaller producer”,
If the amount mentioned in subsection (5) is equal in relation to both SP1’s premises and SP2’s premises, either SP1 or SP2 may be treated as the “larger producer” for the purposes of this section.
In subsections (1), (5) and (6), references to a person’s premises are references to—
the premises on which the person produces alcoholic products immediately before becoming connected with the other person mentioned in section 61(1), if those premises are (at that time) non-group premises, or
if those premises are group premises, the production group which, at that time, includes those premises (and the reference in subsection (1) to the alcohol production amount in relation to those premises is a reference to the aggregate of the alcohol production amount in relation to those premises and every set of connected premises).
This section applies in relation to a post-merger production group if, in a relevant year, Amount A is less than Amount B.
“Amount A” is the aggregate of the alcohol production amount, in relation to every set of premises in the group, for the production year immediately preceding the relevant year (determined in accordance with section 57).
“Amount B” is the adjusted post-merger amount in the relevant year.
Neither the relevant year, nor any subsequent production year, is a merger transition year in relation to the group.
Each of Year 1, 2 and 3 is a “relevant year” for the purposes of this section.
This section applies if—
a person who produces alcoholic products on group premises which are included in a post-merger production group (the “first post-merger group”) becomes connected with another person who produces alcoholic products (that are not exempt from duty under any of sections 72, 76 or 77), and
the producers mentioned in paragraph (a) become connected with one another in Year 1, 2 or 3 in relation to the first post-merger group.
Neither the production year in which the producers mentioned in subsection (1)(a) become connected with one another, nor any subsequent year, is a merger transition year in relation to the first post-merger group.
But subsection (2) does not prevent the application of sections 61 to 67 in relation to the post-merger production group that includes both of the producers mentioned in subsection (1)(a).
Subsections (2) to (4) apply if, at the same time as SP1 becomes connected with SP2, SP1 also becomes connected with one or more other small producers (who are not already connected with one another).
References in sections 61 and 64 to SP2 include references to the other small producers becoming connected with SP1.
For the purposes of section 64— (and this subsection applies instead of section 64(5)).
the “larger producer” is the producer with a greater alcohol production amount attributable to the producer’s premises for the pre-merger year than any of the other producers mentioned in subsection (1), and
each of the other producers is a “smaller producer”,
If the amount mentioned in subsection (3)(a) is equal in relation to any two or more of the producers mentioned in subsection (1), any one of them may be treated as the “larger producer” for the purposes of section 64.
This section applies if a demerger event occurs in relation to a production group.
A “demerger event” occurs, in relation to a production group, if a group producer (the “demerging producer”) ceases to be connected with at least one other group producer.
A “group producer” in relation to a production group means a person who produces alcoholic products on premises that are (immediately before the demerger event) included in the production group.
For the purposes of the application of sections 56 and 59 in relation to the demerger year, the alcohol production amount for the immediately preceding production year, in relation to production premises that were (immediately before the demerger event) included in the group, is treated as being nil.
If, before the end of the restricted period, the demerging producer becomes connected again with another group producer, none of sections 61 to 67 apply by reference to that connection.
For the purposes of subsection (5), the “restricted period” is the period of 7 years beginning with the date on which the demerger event occurs.
Subsection (8) applies if the demerger event occurs in Year 1, 2 or 3 in relation to a post-merger production group (the “relevant group”).
Neither the production year in which the event occurs, nor any subsequent year, is a merger transition year in relation to the relevant group.
References in this section to the “demerger year” are references to the production year in which the demerger event occurs.
This section applies for the purposes of this Chapter.
“Production premises” means premises (whether or not in the United Kingdom) on which alcoholic products are produced.
Production premises are “group premises” at a time in a production year (the “reference time”) if— also produces alcoholic products on any other premises at the reference time or any earlier time in that year.
a person (“P”) who produces alcoholic products on the premises at the reference time or at any earlier time in that year, or
a person connected with P,
“Connected premises”, in relation to group premises, means premises on which alcoholic products are produced at the reference time or at any earlier time in the current year, by—
P, or
a person connected with P.
References to “the production group”, in relation to group premises, are references to the group consisting of—
the group premises, and
every set of connected premises.
Production premises are “non-group premises” at a time in a production year if, at that time, they are not group premises.
In this Chapter—
references to the “producer”, in relation to a set of premises, are references to the person who produces alcoholic products on those premises, and
references to a “small producer” are references to a person who produces small producer alcoholic products.
References in this Chapter to a person being or becoming connected with another person are to be construed in accordance with section 1122 of CTA 2010.
But the Commissioners may, if they think it appropriate, treat two connected persons as if they were not connected with one another for the purposes of this Chapter.
The following Table sets out expressions defined or explained for the purposes of this Chapter— Expression Provision adjusted post-merger amount section 64(1) to (3) alcohol production amount section 57(1)(a) connected premises section 69(4) current year section 54(1) duty discount section 59(1) estimated alcohol production amount section 57(1)(b) group premises section 69(3) merger transition year section 61(4) non-group premises section 69(6) post-merger production group section 61(3) post-merger production group premises section 61(2) previous year section 54(4)(b) producer (in Chapter 3) section 69(7)(a) production group section 69(5) production premises section 69(2) production year section 54(4)(a) small producer section 69(7)(b) small producer alcoholic products section 55 small production limit section 56(4) small production premises section 56 (for general purposes); section 62 (in relation to a post-merger production group) SP1 and SP2 section 61(1) Year 1, Year 2 and Year 3 section 61(3)
Alcohol duty is not charged on alcoholic products which—
are produced, in the United Kingdom, by a person who produces alcoholic products only for the person’s own domestic use, and
are not spirits.
This section applies where—
alcohol duty is chargeable on alcoholic products produced in the United Kingdom, and
the Commissioners are satisfied that the alcoholic products are to be used only for the purposes of research into, or experiments in, the production of alcoholic products.
The Commissioners may remit or repay the alcohol duty.
This section applies where—
alcohol duty is chargeable on alcoholic products, and
the Commissioners are satisfied that the alcoholic products have become spoilt or unfit for use.
The Commissioners may remit or repay the alcohol duty.
Subsection (2) applies where a person proves to the satisfaction of the Commissioners that—
alcohol duty is chargeable, and has been paid, on alcoholic products, and
the alcoholic products have been used as an ingredient in the production or manufacture of—
a qualifying food product, or
a beverage of an alcoholic strength of 1.2% or less.
The person is entitled to repayment of the alcohol duty, on making a claim in accordance with this section (subject to subsection (7)).
In this section “qualifying food product” means—
vinegar,
chocolates containing alcohol, where 100 kilograms of the chocolates would not contain more than 8.5 litres of alcohol, or
any other food (for human consumption) which contains alcohol, where 100 kilograms of the food would not contain more than 5 litres of alcohol.
Alcoholic products that are converted into vinegar are treated, for the purposes of this section, as being used as an ingredient in the production or manufacture of vinegar.
Neither of the following is a qualifying food product for the purposes of this section—
a beverage, including a beverage produced or intended for consumption in frozen form;
a product that is intended for consumption as a substitute for a beverage.
A claim for repayment under this section—
must be in the form and manner, and contain the information, required by the Commissioners (either generally or in a particular case), and
except so far as the Commissioners otherwise allow, relate to duty paid on alcoholic products used as an ingredient during a period of 3 months ending not more than 3 years before the claim is made.
No repayment of duty may be made unless the Commissioners are satisfied that the repayment claimed does not relate to any duty which has been repaid or drawn back prior to the making of the claim.
The Commissioners may remit any alcohol duty chargeable—
on alcoholic products imported into the United Kingdom at a time when they are contained as an ingredient in a qualifying food product within subsection (3)(b) or (c), or
on alcoholic products used as an ingredient in the manufacture or production in an excise warehouse of a qualifying food product within subsection (3)(b) or (c).
Alcohol duty is not charged on spirits contained in medical articles imported into the United Kingdom.
“Medical article” means an article recognised by the Commissioners as being an article used for medical purposes.
Alcohol duty is not charged on spirits contained in food and drink flavourings.
In this section—
This section applies where a person proposes to use spirits, on which alcohol duty is chargeable, either—
in the manufacture or preparation of medical articles, or
for scientific purposes.
This section also applies where—
a person proposes to use spirits, on which alcohol duty is chargeable, for the purposes of art or manufacture (other than the manufacture of medical articles), and
the Commissioners are satisfied that denatured alcohol would not be suitable for that use.
The Commissioners may authorise the person to receive the spirits, and permit the delivery of the spirits from relevant premises to that person, without payment of the alcohol duty.
In subsection (3), “relevant premises” means—
an excise warehouse, or
premises in respect of which a person is approved (including premises on which a person is authorised to hold alcoholic products without payment of duty) under section 82.
An authorisation under this section may be given subject to the conditions (if any)—
specified by the Commissioners in a notice published by them;
imposed by them in a particular case.
If a person fails to comply with a condition in respect of an authorisation, the failure attracts a penalty under section 9 of FA 1994.
Subsection (8) applies if—
the spirits are delivered to the person mentioned in subsection (3), and
the spirits are used otherwise than for the purpose in respect of which the authorisation was given.
The Commissioners—
may assess as being alcohol duty due from the person an amount equal to the alcohol duty that would have been charged on the spirits if, at the time of delivery, no authorisation under this section had been given, and
must notify that person or the person’s representative of the assessment.
In this section “medical article” has the same meaning as in section 76.
The Commissioners may remit any alcohol duty chargeable on spirits imported into the United Kingdom at a time when the spirits are contained in goods that are not for human consumption.
If it turns out that the goods containing spirits are for human consumption, the Commissioners—
may assess as being alcohol duty due from the relevant person an amount equal to the alcohol duty that would (apart from subsection (1)) have been charged on the goods, and
must notify the relevant person or that person’s representative of the assessment.
For the purposes of subsection (2), references to “the relevant person” are references to the importer.
If a person makes unauthorised use of an article to which this section applies—
that conduct attracts a penalty under section 9 of FA 1994, and
the article is liable to forfeiture.
This section applies to—
an article containing spirits which are exempt under section 76 from the charge to alcohol duty;
an article in respect of which spirits were used in the manufacture or preparation, where remission of alcohol duty on the spirits was obtained under section 78.
A person makes “unauthorised use” of an article for the purposes of this section if—
the person uses the article other than for medical or scientific purposes, and
the person has not complied with the requirements under subsection (4).
The requirements are that—
the person must obtain the written consent of the Commissioners to the use of the article other than for medical or scientific purposes, and
the person must pay to the Commissioners an amount equal to the duty shortfall.
In this section, the “duty shortfall” means—
the difference between the duty charged on the spirits contained in, or used in the manufacture or preparation of, the article, and
the duty which would have been chargeable had the article not been exempt under section 76 or the duty had not been remitted under section 78.
The Commissioners may make regulations for the purpose of enforcing this section.
Regulations under subsection (6) may, in particular, require a person carrying on any trade in which spirits or articles containing, manufactured or prepared with spirits are, in the opinion of the Commissioners, likely to be or have been used—
to give and verify particulars of the materials which the person is using or has used, or the articles the person has sold;
to produce any documents (of whatever nature) relating to such materials or articles.
If a person contravenes or fails to comply with any regulation made under subsection (6), the contravention or failure attracts a penalty under section 9 of FA 1994.
In this section, a reference to an article includes a reference to any part of that article.
The remission or repayment of alcohol duty under any provision of this Chapter is subject to the conditions (if any)—
specified by the Commissioners in a notice published by them;
specified by or under regulations made by them;
imposed by them in a particular case.
If a person fails to comply with a condition in respect of the remission or repayment, the failure attracts a penalty under section 9 of FA 1994.
A person may not produce alcoholic products on any premises unless—
the production on those premises is in accordance with an approval given under this section by the Commissioners to the person, or
the person is exempt from the approval requirement under section 84 or 85.
The Commissioners may approve a person under this section only if they are satisfied that the person is a fit and proper person to produce alcoholic products.
An approval under this section may authorise the approved person to hold alcoholic products (including alcoholic products produced by another person in, or imported into, the United Kingdom) on certain premises without payment of alcohol duty.
A person may not carry out other activities on those premises in relation to those alcoholic products, without payment of alcohol duty, except in accordance with an approval under this section.
The reference in subsection (4) to “activities” includes, in particular, packaging and processing, or carrying out other operations on or in relation to, the alcoholic products.
An approval under section 82 may be given to a person—
in respect of—
more than one category of alcoholic product;
more than one set of premises;
for such period as the Commissioners think fit.
An approval is subject to the conditions or restrictions (if any)—
specified by the Commissioners in a notice published by them;
specified by or under regulations made by them;
imposed by them in a particular case.
The Commissioners may, at any time, revoke or vary the terms of an approval.
An application for approval must be in the form and manner, and contain the information, specified by or under regulations made by the Commissioners.
For the purposes of section 82(1)(b), a person is exempt from the approval requirement if—
the person produces alcoholic products only for the person’s own domestic use, and
the alcoholic products are not spirits.
For the purposes of section 82(1)(b), a person is exempt from the approval requirement if—
the person produces alcoholic products only for the purposes of research into, or experiments in, the production of alcoholic products, and
the person complies with, and the alcoholic products are produced in accordance with, the requirements specified—
by the Commissioners in a notice published by them, or
by or under regulations made by the Commissioners.
A person may not mix two or more alcoholic products unless one of the following exemptions applies.
The first exemption applies if the products are mixed—
either—
in accordance with an approval under section 82, or
in an excise warehouse, and
the mixing takes place before the excise duty point.
The second exemption applies if all of the alcoholic products being mixed—
fall within the same paragraph of section 44(1), and
are of the same alcoholic strength.
The third exemption applies if—
the alcohol duty on each of the alcoholic products being mixed has been paid, and
that amount is equal to or exceeds the amount of alcohol duty that would (if the mixing had taken place before the excise duty point) have been chargeable on the resulting mix.
The fourth exemption applies if—
the alcohol duty on each of the alcoholic products being mixed has been paid,
the resulting mix is intended for consumption on the premises on which the mixing takes place, and
the method of mixing is of a description specified in a notice published by the Commissioners.
A person may not mix water or any other substance with alcoholic products on which alcohol duty is chargeable if—
the mixing takes places after the excise duty point in relation to that charge,
the resulting product is intended for sale, and
if the mixing had taken place immediately before the excise duty point, the amount of alcohol duty would have been greater than the amount actually payable.
This section has effect, despite section 8 of the Isle of Man Act 1979, as if a removal of relevant alcoholic products to the United Kingdom from the Isle of Man constituted their importation into the United Kingdom (and references to the charge to alcohol duty and to the excise duty point are to be read accordingly).
The Commissioners may by regulations (“alcoholic products regulations”) make provision—
regulating the production, packaging, keeping and storage of alcoholic products produced in, or imported into, the United Kingdom;
for determining when the production of any alcoholic product begins and when it is completed;
for securing and collecting alcohol duty;
for determining alcohol duty, the rate and the method of charging the duty;
for charging alcohol duty, in specified circumstances, by reference to an alcoholic strength which any alcoholic product might reasonably be expected to have, or the rate of duty in force, at a time other than that at which the alcoholic product becomes chargeable;
for determining the alcohol production amount in relation to a set of premises (for the purposes of Chapter 3 of this Part), in specified circumstances, by reference to an alcoholic strength which any alcoholic product might reasonably be expected to have at a time other than that at which the alcoholic product is produced;
for full or partial relief from alcohol duty in specified circumstances (and whether or not subject to conditions);
regulating or prohibiting the addition of substances to, the mixing of, or the carrying out of other operations on or in relation to, any alcoholic product;
regulating the approval of persons under this Chapter, including the variation or revocation of the approval or of any condition or restriction to which it is subject;
permitting, in specified circumstances, the removal of alcoholic products from certain premises without payment of duty (whether or not subject to conditions);
make provision in respect of alcoholic products permitted to be removed from premises without payment of duty or on which alcohol duty has been remitted;
regulating the transportation of alcoholic products;
requiring the production of certificates as to matters relating to alcoholic products imported into the United Kingdom, and the production and producer of those products, as evidence that conditions for charging the duty at a particular rate are satisfied.
Alcoholic products regulations may, in particular, include provision—
requiring the making of returns;
for notifications and other communications with the Commissioners to be made electronically;
requiring persons to keep, and make available for inspection, specified records relating to alcoholic products;
for the imposition under the regulations of requirements as to documents to accompany, or be provided with, alcohol products at any time during a specified period or in specified circumstances, and requiring production of those documents;
conferring powers on an officer of Revenue and Customs to inspect, copy or remove for a reasonable period records or documents relating to alcoholic products;
for assessing an amount as alcohol duty due from a person in specified circumstances;
for the imposition under the regulations of conditions and restrictions (which may include a requirement to give a guarantee or other security).
The reference in subsection (1)(k) to alcoholic products permitted to be removed from premises without payment of duty is treated as including a reference to alcoholic products that are—
treated for the purposes of alcohol duty, by provision made (or having effect as if made) under section 12 of the Customs and Excise Duties (General Reliefs) Act 1979 (supply of duty-free goods to His Majesty’s ships), as exported,
supplied to persons on whom relief from payment of alcohol duty is conferred by provision made under section 13A of that Act (reliefs from duties and taxes for persons enjoying certain immunities and privileges), or
supplied for use on a ship, aircraft or railway vehicle as stores, in accordance with provision made under section 60A of CEMA 1979 (power to make regulations about stores).
In this section, “specified” means specified by or under alcoholic products regulations.
This section applies if a person contravenes or fails to comply with—
section 82,
section 86(1),
section 87(1), or
any provision made by or under alcoholic products regulations.
The person’s conduct attracts a penalty under section 9 of FA 1994.
Any alcoholic products, articles (including packaging or equipment) or substances in the person's possession, used (or which may be used) for or in connection with an action to which the contravention or failure relates, are liable to forfeiture.
Alcohol duty is not charged on denatured alcohol.
“Denatured alcohol” means an alcoholic product which has been mixed with a substance, and in a manner, specified by or under regulations made by the Commissioners (and references, however expressed, to “denaturing” alcoholic products are to be construed accordingly).
Provision made under subsection (2) may include provision specifying a substance, or a manner of mixing, by reference to particular circumstances or other factors, or to the approval or opinion of specified persons.
Where— the duty is to be remitted.
alcohol duty is chargeable on alcoholic products, and
the Commissioners are satisfied that the alcoholic products are to be converted into denatured alcohol before the duty is required to be paid,
A person may not denature any alcoholic products, or deal wholesale in denatured alcohol, unless the person holds an excise licence as a denaturer under this section.
For the purposes of this section, a person deals wholesale in denatured alcohol if the person sells, at any one time to any one person—
a quantity of at least 20 litres of denatured alcohol, or
a smaller quantity, specified by or under regulations made by the Commissioners, of denatured alcohol.
The Commissioners may, at any time, revoke or suspend an excise licence under this section.
An application for an excise licence as a denaturer must be in the form and manner, and contain the information, specified by the Commissioners in a notice published by them.
The Commissioners may, with a view to the protection of the revenue, by regulations make provision—
regulating the denaturing of alcoholic products;
regulating the supply, storage, removal, sale, delivery, receipt, use, export or shipment as stores of denatured alcohol;
permitting alcoholic products to be denatured in a warehouse;
permitting dealing wholesale (within the meaning of section 91) in denatured alcohol of a specified description, in specified circumstances, without an excise licence;
regulating the import, receipt, removal, storage and use of alcoholic products for denaturing;
regulating the storage and removal of substances to be used in denaturing alcoholic products;
about the manner in which account is to be kept of stocks of denatured alcohol in the possession of persons licensed as denaturers under section 91 and of retailers of denatured alcohol.
Regulations under this section may, in particular, include provision—
for applications and other communications with the Commissioners to be made electronically;
requiring persons licensed as denaturers under section 91 and retailers of denatured alcohol to keep, and make available for inspection, specified records relating to denaturing;
conferring powers on an officer of Revenue and Customs to inspect, copy or remove for a reasonable period those records;
for the imposition under the regulations of conditions and restrictions (which may include a requirement to give a guarantee or other security).
In this section, “specified” means specified by or under regulations under this section.
This section applies if a person—
fails to comply with section 91(1) (denaturing alcoholic products, or dealing wholesale in denatured alcohol, otherwise than in accordance with an excise licence), or
contravenes or fails to comply with any provision made by or under regulations under section 92.
Conduct mentioned in subsection (1)(a) or (b) attracts a penalty under section 9 of FA 1994.
Any alcoholic product or denatured alcohol, article (including packaging or equipment) or substance in the person’s possession, used (or which may be used) for or in connection with an action to which the contravention or failure relates is liable to forfeiture.
This section applies if, in relation to a person who holds an excise licence under section 91 (the “denaturer”), at a time when an account is taken of the quantity of denatured alcohol in the denaturer’s possession—
there is a difference between the actual amount and the proper amount, and
either—
where the actual amount exceeds the proper amount, the amount of the excess is more than 1% of the permitted amount, or
where the proper amount exceeds the actual amount, the amount of the excess is more than 2% of the permitted amount.
For the purposes of subsection (1)—
the “actual amount” is the quantity of alcoholic products of any description in the denatured alcohol in the denaturer’s possession;
the “proper amount” is the quantity of alcoholic products of the same description which, according to any accounts that are required to be kept by or under any regulations under section 92, ought to be in the denatured alcohol in the denaturer’s possession.
Where there is a difference between the actual amount and the proper amount, in relation to alcoholic products of a particular description, the “permitted amount” is the aggregate of—
the quantity of alcoholic products of that description when an account was last taken, and
the quantity of alcoholic products of that description that have since been lawfully added to the denaturer’s stock.
In a case within subsection (1)(b)(i), the relevant amount of any alcoholic products of the description to which the difference relates in the denaturer’s possession is liable to forfeiture.
The “relevant amount” for the purposes of subsection (4) is the amount corresponding to the amount of the excess mentioned in subsection (1)(b)(i), or such smaller amount as the Commissioners consider appropriate.
In a case within subsection (1)(b)(ii), the denaturer must, on demand by the Commissioners, pay alcohol duty—
on the amount of alcoholic products (of the same description) equal to the amount of the difference, or
if the Commissioners specify a smaller amount of alcoholic products (of the same description) in the demand, on that amount.
A demand made for the purposes of this section is to be combined, as if there had been a default of a kind mentioned in section 12 of FA 1994 (assessments to excise duty) with an assessment and notification under that section of the amount of duty due in consequence of the demand.
This section applies if a person, in contravention of regulations under section 92, uses or supplies denatured alcohol containing alcoholic products of any description.
The person must, on demand by the Commissioners, pay alcohol duty—
on the amount of alcoholic products contained, at the time of supply or use, in the denatured alcohol, or
if the Commissioners specify a smaller amount of alcoholic products (of the same description) in the demand, on that amount.
For the purposes of this section, a supply of denatured alcohol to a person who— is treated as being a supply in contravention of those regulations.
by reason of regulations under section 92 is prohibited from receiving it unless authorised to do so by or under the regulations, but
is not so authorised,
A demand made for the purposes of this section is to be combined, as if there had been a default of a kind mentioned in section 12 of FA 1994 (assessments to excise duty) with an assessment and notification under that section of the amount of duty due in consequence of the demand.
An officer of Revenue and Customs may, at any reasonable time—
enter and inspect the premises of a person authorised by regulations under section 92 to receive denatured alcohol,
inspect and examine any denatured alcohol on the premises, and
take samples of any denatured alcohol or of any goods containing denatured alcohol (paying a reasonable price for each sample).
Subsection (1) does not affect any other power conferred by the customs and excise Acts.
It is an offence for a person—
to prepare, or attempt to prepare, denatured alcohol for use as a beverage or as a mixture with a beverage;
to sell denatured alcohol (whether or not prepared as described in paragraph (a)) as a beverage or mixed with a beverage;
to use any denatured alcohol or a derivative of it in the preparation of any article capable of being used as a beverage;
to sell or possess any article capable of being used as described in paragraph (c), in the preparation of which denatured alcohol or any derivative of it has been used;
except as permitted by the Commissioners and in accordance with any conditions imposed by them—
to purify, or attempt to purify, denatured alcohol, or
after denatured alcohol has once been used, to attempt to recover the spirit or alcohol contained in it by distillation, condensation or in any other manner.
Subsection (1) is subject to subsections (5) and (6).
A person who commits an offence under this section is liable on summary conviction to a penalty not exceeding level 3 on the standard scale.
Any denatured alcohol, or any article (including packaging or equipment), in respect of which an offence under this section is committed is liable to forfeiture.
No offence is committed under this section where a person uses denatured alcohol or any derivative of it—
in the preparation for use as a medical article (as defined in section 76),
in the making of anything sold or supplied in accordance with regulations made by the Commissioners under section 92, or
in art or manufacture.
No offence is committed under this section where a person sells or possesses anything that—
is permitted to be prepared or made, by reference to paragraph (a) or (b) of subsection (5), for a use described in that paragraph, and
is sold or possessed for that use.
In this section, references to denatured alcohol include references to—
methanol, and
any mixture containing denatured alcohol or methanol.
This section defines certain expressions used in this Chapter.
A sale is of “controlled alcoholic products” if—
it is a sale of alcoholic products on which alcohol duty is charged under this Part at a rate greater than nil, and
the excise duty point for the alcoholic products falls at or before the time of the sale.
Controlled alcoholic products are sold “wholesale” if— and a reference to buying controlled alcoholic products wholesale is to be read accordingly.
the sale is of any quantity of the alcoholic products,
the seller is carrying on a trade or business and the sale is made in the course of that trade or business,
the sale is to a buyer carrying on a trade or business, for sale or supply in the course of that trade or business, and
the sale is not an incidental sale, a group sale or an excluded sale,
A sale is an “incidental sale” if—
the seller makes authorised retail sales of alcoholic products of any description, and
the sale is incidental to those sales.
A sale is an “authorised retail sale” if it is made by retail under and in accordance with a licence or other authorisation under an enactment regulating the sale and supply of alcohol.
A sale is a “group sale” if the seller and the buyer are both bodies corporate which are members of the same group (see section 106).
A sale is an “excluded sale” if it is of a description specified by or under regulations made by the Commissioners.
“Controlled activity” means—
selling controlled alcoholic products wholesale,
offering or exposing controlled alcoholic products for sale in circumstances in which the sale (if made) would be a wholesale sale, or
arranging in the course of a trade or business for controlled alcoholic products to be sold wholesale, or offered or exposed for sale in circumstances in which the sale (if made) would be a wholesale sale.
“UK person” means a person who is UK-established for the purposes of value added tax (see paragraph 1(10) of Schedule 1 to VATA 1994).
“Enactment” includes an enactment contained in—
an Act of the Scottish Parliament;
an Act or Measure of Senedd Cymru;
Northern Ireland legislation.
References in this Chapter to the “alcohol wholesaling provisions” are references to this section and sections 99 to 106, and Schedule 10.
The Commissioners may by regulations make provision as to the cases in which sales are, or are not, to be treated for the purposes of this Chapter as—
wholesale sales,
sales of controlled alcoholic products,
incidental sales,
authorised retail sales, or
group sales.
The Commissioners may by regulations make provision as to the cases in which a person is, or is not, to be treated for the purposes of this Chapter as carrying on a controlled activity by virtue of section 98(8)(b) or (c).
A UK person may not carry on a controlled activity otherwise than in accordance with an approval given by the Commissioners under this section.
The Commissioners may approve a person under this section to carry on a controlled activity only if they are satisfied that the person is a fit and proper person to carry on the activity.
The Commissioners may approve a person under this section to carry on a controlled activity for such period as they think fit.
An approval may be given subject to the conditions or restrictions (if any)—
specified by the Commissioners in a notice published by them;
specified by or under regulations made by them;
imposed by them in a particular case.
The conditions or restrictions may include conditions or restrictions requiring the controlled activity to be carried on only at or from premises specified or approved by the Commissioners.
The Commissioners may at any time revoke or vary the terms of an approval under this section.
In this Chapter “approved wholesaler” means a person approved under this section to carry on a controlled activity.
The Commissioners must maintain a register of approved wholesalers.
The register is to contain such information relating to approved wholesalers as the Commissioners consider appropriate.
The Commissioners may make publicly available such information contained in the register as they consider necessary to enable those who deal with a person who carries on a controlled activity to determine whether the person in question is an approved wholesaler for the purposes of that activity.
The information may be made available by such means as the Commissioners consider appropriate.
The Commissioners may by regulations make provision—
regulating the approval and registration of persons under the alcohol wholesaling provisions,
regulating the variation or revocation of any such approval or registration or of any condition or restriction to which such an approval or registration is subject,
about the register maintained under section 101,
regulating the carrying on of controlled activities, and
imposing obligations on approved wholesalers.
The regulations may, in particular, make provision—
requiring applications, and other communications with the Commissioners, to be made electronically;
as to the procedure for the approval and registration of bodies corporate which are members of the same group and for members of such a group to be jointly and severally liable for any penalties imposed under—
the regulations, or
Schedule 10;
requiring approved wholesalers to keep and make available for inspection such records relating to controlled activities as may be specified by or under the regulations;
conferring powers on an officer of Revenue and Customs to inspect, copy or remove for a reasonable period those records;
imposing a penalty of an amount specified by the regulations (which must not exceed £1,000) for a contravention of—
the regulations, or
any condition or restriction imposed under the alcohol wholesaling provisions;
for the assessment and recovery of such a penalty;
for alcoholic products (whether or not charged with any duty and whether or not that duty has been paid) to be subject to forfeiture for a contravention of—
the alcohol wholesaling provisions or the regulations made under this section, or
any condition or restriction imposed under the alcohol wholesaling provisions.
A person may not—
buy controlled alcoholic products wholesale from a UK person, unless the person is an approved wholesaler in relation to the sale, or
buy relevant alcoholic products from an Isle of Man person, unless the person is an Isle of Man approved wholesaler.
In this section and in section 104(4)—
“Isle of Man person” means a person who is established in the Isle of Man for the purposes of value added tax under any provision of the law in force in the Isle of Man corresponding to paragraph 1(10) of Schedule 1 to VATA 1994;
“Isle of Man approved wholesaler” means an Isle of Man person who is approved under any provision of the law in force in the Isle of Man corresponding to section 100;
“relevant alcoholic products” means alcoholic products which, if they had been produced in the United Kingdom, would have been charged with alcohol duty under this Part at a rate greater than nil.
A person who contravenes section 100(1) by selling controlled alcoholic products wholesale commits an offence if the person knows or has reasonable grounds to suspect that—
the buyer is carrying on a trade or business, and
the alcoholic products are for sale or supply in the course of that trade or business.
A person who contravenes section 100(1) by offering or exposing controlled alcoholic products for sale in circumstances in which the sale (if made) would be a wholesale sale commits an offence if the person intends to make a wholesale sale of the alcoholic products.
A person who contravenes section 100(1) by arranging in the course of a trade or business for controlled alcoholic products to be sold wholesale, or offered or exposed for sale in circumstances in which the sale (if made) would be a wholesale sale, commits an offence if the person intends to arrange for the alcoholic products to be sold wholesale.
A person who contravenes section 103 commits an offence if the person knows or has reasonable grounds to suspect that—
the UK person from whom the controlled alcoholic products are bought is not an approved wholesaler in relation to the sale, or
the Isle of Man person from whom the relevant alcoholic products are bought is not an Isle of Man approved wholesaler in relation to the sale.
A person who commits an offence under this section is liable on summary conviction—
in England and Wales to—
imprisonment for a term not exceeding the general limit in a magistrates’ court,
a fine, or
both,
in Scotland to—
imprisonment for a term not exceeding 12 months,
a fine not exceeding the statutory maximum, or
both, and
in Northern Ireland to—
imprisonment for a term not exceeding 6 months,
a fine not exceeding the statutory maximum, or
both.
A person who commits an offence under this section is liable on conviction on indictment to—
imprisonment for a period not exceeding 7 years,
a fine, or
both.
Schedule 10 contains provision about penalties for contraventions of the alcohol wholesaling provisions.
Two or more bodies corporate are members of a group for the purposes of the alcohol wholesaling provisions if each is established or has a fixed establishment in the United Kingdom and—
one of them controls each of the others,
one person (whether a body corporate or an individual) controls all of them, or
two or more individuals carrying on a business in partnership control all of them.
For the purposes of this section, a body corporate is to be taken to control another body corporate if—
it is empowered by or under an enactment to control that body’s activities, or
it is that body’s holding company within the meaning of section 1159 of, and Schedule 6 to, the Companies Act 2006.
For the purposes of this section—
an individual or individuals are to be taken to control a body corporate if the individual or individuals (were the individual or individuals a company) would be that body’s holding company within the meaning of section 1159 of, and Schedule 6 to, the Companies Act 2006 (meaning of “subsidiary” etc), and
a body corporate is established or has a fixed establishment in the United Kingdom if it is so established or has such an establishment for the purposes of value added tax.
The following Table sets out expressions defined or explained for the purposes of this Chapter— Expression Provision alcohol wholesaling provisions section 98(11) approved wholesaler section 100(7) authorised retail sale section 98(5) controlled activity section 98(8) enactment section 98(10) group (in relation to bodies corporate) section 106(1) group sale section 98(6) incidental sale section 98(4) Isle of Man person and Isle of Man approved wholesaler section 103(2)(a) and (b) relevant alcoholic products (for the purposes of sections 103 and 104(4)) section 103(2)(c) sale of controlled alcoholic products section 98(2) UK person section 98(9) wholesale section 98(3)
Schedule 11 makes provision about reviews and appeals.
An officer of Revenue and Customs may destroy, break up or spill anything seized as liable to forfeiture under any provision of this Part.
Subsection (1) does not affect any other provision of, or power conferred by, the customs and excise Acts.
Section 95 of CEMA 1979 (deficiency in goods occurring in course of removal from warehouse without payment of duty) is amended as follows.
After subsection (1) insert—
In subsection (2), in the words before paragraph (a), after “subsection (1)” insert “, (1A) or (1B)”.
This section applies where drawback of alcohol duty is allowable, under regulations made under section 60A of CEMA 1979 (power to make regulations about stores) or section 2 of F(No. 2)A 1992 (power to provide for drawback of excise duty), to a person who produces alcoholic products in accordance with an approval under section 82 (“the producer”).
Subject to the conditions (if any) that the Commissioners impose, drawback of alcohol duty may be set against any amount to which the producer is chargeable in respect of alcohol duty (and any reference in CEMA 1979 to drawback payable is to be construed in accordance with this section).
Schedule 12 makes provision about duty stamps.
The Alcoholic Liquor Duties Act 1979 is repealed.
The following sections of FA 1995 are repealed—
section 4 (alcoholic ingredients relief);
section 5 (denatured alcohol).
Schedule 13 makes minor and consequential amendments relating to this Part.
Wine of an alcoholic strength of at least 11.5% but not exceeding 14.5% is treated, for the purposes of the charge to alcohol duty, as if it were of an alcoholic strength of 12.5%.
This section expires at the end of the period of 18 months beginning with the day on which section 48 (rates) comes into force.
Alcohol duty is not charged on cider which is produced—
at a time before section 82 (approvals) comes into force, and
by a person who, at that time, is exempt from the requirement to register under section 62 of ALDA 1979 by reason of an order made (or having effect as if made) under subsection (3) of that section.
The following Table sets out expressions defined or explained in this Part for general purposes— Expression Provision alcohol section 45(5) alcoholic products section 44(1) and (2) alcoholic strength section 45(1) beer Schedule 6, paragraph 3 cider Schedule 6, paragraph 5 denatured alcohol section 90 excise duty point section 49 other fermented product Schedule 6, paragraph 12 qualifying draught product section 51(1) spirits Schedule 6, paragraph 1 wine Schedule 6, paragraph 11
This Part is to be construed as one with the Customs and Excise Acts 1979.
Any expression used in this Act or in any instrument made under this Act to which a meaning is given by any other Act included in the Customs and Excise Acts 1979 has, except where the context otherwise requires, the same meaning in this Act or any such instrument as in that Act.
The Commissioners may by regulations make provision supplementing provision made in relation to alcohol duty by or under this Part or any other enactment.
A power to make regulations under any provision of this Part may be exercised so as to make different provision for different purposes or areas.
A power to make regulations under any provision of this Part includes power to make—
provision which applies generally or only for specified cases or purposes;
provision conferring a discretion on a specified person to do anything under, or for the purposes of, the regulations;
provision by reference to things specified in a notice published in accordance with the regulations;
consequential, supplementary, incidental, transitional or saving provision.
Regulations under this Part are to be made by statutory instrument.
This section does not apply to regulations under section 120.
A statutory instrument containing any regulations made under section 46(a) or section 51(5) must be laid before the House of Commons, and, unless approved by that House before the end of the period of 28 days beginning with the date on which the instrument is made, ceases to have effect at the end of that period.
The fact that a statutory instrument ceases to have effect as a result of subsection (1) does not affect—
anything previously done under the instrument, or
the making of a new statutory instrument.
In calculating the period for the purposes of subsection (1), no account is to be taken of any time—
during which Parliament is dissolved or prorogued, or
during which the House of Commons is adjourned for more than 4 days.
A statutory instrument containing (whether alone or with other provision) any regulations made under paragraph 2 of Schedule 12 may not be made unless a draft of the instrument has been laid before, and approved by a resolution of, the House of Commons.
A statutory instrument containing regulations made under this Part, other than regulations in respect of which subsection (1) or subsection (4) applies, is subject to annulment in pursuance of a resolution of the House of Commons.
A statutory instrument containing regulations to which subsection (1) applies may also include regulations relating to alcohol duty under any other provision of the customs and excise Acts (including any provision of this Part) if the Parliamentary procedure applicable to a statutory instrument containing regulations under the other provision does not require House of Commons approval.
Where regulations are included as mentioned in subsection (6), the procedure applicable to the statutory instrument is the procedure mentioned in subsection (1) (and not the procedure mentioned in subsection (6)).
If— the only Parliamentary procedure applicable to a statutory instrument mentioned in paragraph (a) is that given by this section.
a statutory instrument contains regulations under any provision of this Part (other than regulations in respect of which subsection (1) or subsection (4) applies) and regulations relating to alcohol duty under any other provision of the customs and excise Acts, and
the Parliamentary procedure applicable to a statutory instrument containing provision under the other provision does not require House of Commons approval,
For the purposes of subsection (6) and subsection (8) the Parliamentary procedure applicable to a statutory instrument requires House of Commons approval if, as a condition of its continuing to have effect or its making, the House of Commons has to approve the statutory instrument or a draft of it.
This section does not apply to regulations under section 120.
The following provisions of this Part come into force on the day on which this Act is passed—
this Chapter, and
any other provision of this Part so far as it confers a power to make regulations.
The other provisions of this Part (so far as not brought into force by subsection (1)) come into force on such day or days as the Commissioners may by regulations appoint.
Different days may be appointed for different purposes or different areas.
The Commissioners may by regulations make consequential, supplementary, incidental, transitional or saving provision in connection with the coming into force of any provision of this Part.
The power to make regulations under subsection (4)—
may be exercised so as to make different provision for different purposes or areas, and
includes power to make provision of a kind described in section 118(3)(a) to (c).
Regulations under this section are to be made by statutory instrument.
The purpose of this Part is to implement the provisions of the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules).
For that purpose, this Part makes provision for a tax payable in respect of members of multinational groups who are located in territories (outside the United Kingdom) where their rate of tax (as determined in accordance with this Part) is less than 15%.
The tax is to be known as “multinational top-up tax”.
Sections 122 to 124 set out the charge to multinational top-up tax and describe how it is to be calculated.
Chapter 2 of this Part—
sets out the meaning of “multinational group”;
describes who the members of such a group are;
identifies the ultimate parent of such a group;
limits the application of this Part to multinational groups with an annual revenue of at least 750 million euros and that have at least one member in the United Kingdom (such a group is referred to in this Part as “qualifying”);
sets out how to determine which members of a multinational group (“responsible members”) are responsible for paying the tax and which members they are responsible for.
A person is chargeable to multinational top-up tax for an accounting period of a multinational group if the group is a qualifying multinational group in that period and—
the person—
is a responsible member of the multinational group at any time in that period,
is a body corporate or a partnership that is not a body corporate, and
is located in the United Kingdom, or
the person is chargeable to tax in respect of an entity that is a responsible member of the multinational group at any time in that period.
A person is chargeable to tax in respect of a responsible member of a multinational group if—
the profits of the responsible member would, on the relevant assumptions, be the profits of the person for the purposes of income tax or corporation tax,
the responsible member is located in the United Kingdom, and
the responsible member is not—
a body corporate, or
a partnership that is not a body corporate.
The relevant assumptions are—
that the responsible member has profits that are chargeable to income tax or corporation tax, and
that the person is resident in the United Kingdom for the purposes of that tax.
Where a partnership that is not a body corporate is chargeable to multinational top-up tax as a result of subsection (1)(a)—
the responsible partners are liable to pay the tax, and
the liability of the responsible partners to do so is joint and several.
The references in subsection (4) to “the responsible partners” are to each member of the partnership at any time during the accounting period who—
in the case of a partner that is an entity, is located in the United Kingdom, or
in the case of a partner that is an individual, is tax resident in the United Kingdom.
A partnership is to be regarded for the purposes of this section as continuing to be the same partnership regardless of a change in membership, provided that a person who was a member before the change remains a member after the change.
Where more than one person is chargeable to tax in relation to the same responsible member of a qualifying multinational group as a result of the application of subsection (2), each of those persons is jointly and severally liable to multinational top-up tax.
Where a person is chargeable to multinational top-up tax for an accounting period as a responsible member of a qualifying multinational group or in respect of a responsible member of a qualifying multinational group, the amount (if any) the person must pay is determined as follows— Step 1 Determine which, if any, of the multinational group’s members that the responsible member is responsible for have top-up amounts or additional top-up amounts for that period and the extent of those amounts. Step 2 Determine how much of each of those amounts is to be attributed to the responsible member. Step 3 Add together the amounts attributed to the responsible member. Step 4 If the result of Step 3 is not expressed in sterling, convert the result of that Step to sterling.
Generally, a member of a multinational group in a territory will have a top-up amount for an accounting period if—
the effective tax rate of the members of the group in that territory for that period is less than 15%, and
that member has profits for that period.
Chapter 3 of this Part sets out how to determine the effective tax rate of the members of a multinational group in a territory by reference to the profits of, and the taxes payable by, those members in that territory.
Chapter 4 of this Part sets out how to calculate the profits of members of a multinational group.
Chapter 5 of this Part sets out—
which taxes (referred to in this Part as “covered taxes”) are to be considered in determining the effective tax rate of those members, and
how to determine the amount of covered taxes allocated to those members.
Chapter 6 of this Part sets out how to use the effective tax rate and profits of the members of a multinational group to determine the top-up amounts of those members.
Chapter 7 of this Part sets out how to attribute those top-up amounts to a responsible member of the group.
Chapter 8 of this Part contains provisions about—
additional top-up amounts, and
further adjustments that may need to be made (including provision about adjustments for restructuring of multinational groups).
Chapter 9 of this Part sets out special provision for investment entities, joint venture groups and minority owned members (including provision that applies to those entities instead of provision in the previous Chapters).
Chapter 10 of this Part contains definitions and other provisions relevant to the calculations and other determinations to be made for the purposes of multinational top-up tax and Chapter 11 contains general provision.
Schedule 14 makes provision for—
information returns which must be made in respect of multinational groups,
assessments to multinational top-up tax,
penalties, and
other administrative matters.
References in this Part to a multinational group are to a consolidated group where at least one of the members of that group is not located in the same territory as the others.
A “consolidated group” means the following entities (which are its members)—
an entity (the “ultimate parent”)—
in which no other entity has a controlling interest, and
which has a controlling interest in other entities, and
the entities whose assets, liabilities, income, expenses and cash flows—
are included in the consolidated financial statements of the ultimate parent, or
are not included in those statements only because of an exclusion on size or materiality grounds or on the grounds that the entity in question is held for sale.
For the purposes of this Part, excluded entities are to be treated as not being members of a multinational group.
But subsection (1) does not apply for the purposes of the following provisions—
section 126 (and accordingly an excluded entity that is the ultimate parent of multinational group remains the ultimate parent of that group),
this section, and
section 129 (determining whether a multinational group is qualifying).
The following are excluded entities—
a governmental entity;
an international organisation;
a pension fund;
a non-profit organisation;
a qualifying non-profit subsidiary;
a qualifying service entity;
a qualifying exempt income entity.
The following are also excluded entities if they are the ultimate parent of a multinational group, or would be but for the fact they do not produce consolidated financial statements that include assets, liabilities, income expenses and cash flows of entities in which they have ownership interests—
an investment fund,
a UK REIT, or
an overseas REIT equivalent.
An entity is a qualifying non-profit subsidiary in an accounting period if—
it is 100% owned by one or more entities that are non-profit organisations,
the revenue (see section 129(5)) of the multinational group of which the entity is a member would not exceed the threshold set out in section 129(4) for that period if the revenue of every member that is a non-profit organisation, a qualifying service entity or a qualifying exempt income entity were ignored,
the revenue of the group for that period that is ignored for the purposes of paragraph (b) is less than 25% of the total revenue of the group, and
no election under subsection (8) is in force in relation to the entity.
An entity is a qualifying service entity if—
it is 95% owned by one or more qualifying excluded entities,
either—
the entity only carries out activities that are ancillary to the activities of those owners, or
all, or almost all, of its activities, ignoring activities falling within sub-paragraph (i), consist of the holding of assets or the investment of funds for the benefit of those owners, and
no election under subsection (8) is in force in relation to the entity.
An entity is a qualifying exempt income entity if—
it is 85% owned by one or more qualifying excluded entities,
almost all of the entity’s income is excluded dividends or excluded equity gains (or a mixture of both), and
no election under subsection (8) is in force in relation to the entity.
The filing member of a multinational group (see paragraph 2 of Schedule 14) may make an election that a member of that group that would otherwise be an excluded entity as a result of subsection (5), (6) or (7) is not to be an excluded entity.
Schedule 15 makes provision about elections under this Part.
Paragraph 1 of that Schedule (long term elections) applies to an election under subsection (8).
For the purposes of subsection (5), the reference to an entity being 100% owned by one or more entities that are non-profit organisations is to those entities together having that percentage of ownership interest in that entity.
For the purposes of subsections (6) and (7)—
despite section 232(3) (permanent establishments treated as distinct from main entity), the conditions in subsection (6)(b) and (7)(b) are only met in relation to a permanent establishment or a main entity if the conditions are met by the main entity and all of its permanent establishments taken together as if they were a single entity;
an excluded entity is “qualifying” if it is not a pensions service entity, and
references to an entity being 95% or 85% owned by qualifying excluded entities are to those entities together having at least that percentage of the ownership interests in that entity (see section 245 for how to calculate ownership interests in excluded entities).
The ultimate parent of a multinational group is a responsible member of that group if it is subject to Pillar Two IIR tax.
An ultimate parent that is a responsible member of a multinational group is responsible for all of its members that are not located in the territory it is located in.
An intermediate parent member of a multinational group (see section 237(2)) that is located in a Pillar Two territory is a responsible member of that group if it is subject to Pillar Two IIR tax and—
no intermediate parent member of that group that is subject to Pillar Two IIR tax has a controlling interest in it,
the ultimate parent is not subject to Pillar Two IIR tax, and
it has an ownership interest in a member of the group that has a top-up amount.
Such an intermediate parent member is responsible for all of the members of the group it has an ownership interest in that are not located in the territory it is located in.
A partially-owned parent member of a multinational group (see section 237(1)) that is located in a Pillar Two territory is a responsible member if it is subject to Pillar Two IIR tax and—
it is not wholly owned by another partially-owned parent member of that group that is subject to Pillar Two IIR tax, and
it has an ownership interest in a member of the group that has a top-up amount.
Such a partially owned parent member is responsible for all of the members of the group it has an ownership interest in that are not located in the same territory it is located in.
For the purposes of this Part an entity is subject to Pillar Two IIR tax if—
the entity is located in the United Kingdom and is not an excluded entity, or
the entity—
is located in another Pillar Two territory in which a tax equivalent to multinational top-up tax is in force, and
is not excluded from the application of that tax as a result of provision equivalent to section 127.
For the purposes of this Part, a multinational group is “qualifying” in an accounting period if conditions A and B are met.
Condition A is that the group’s members have revenue that exceeds the threshold set out in subsection (4) in at least 2 accounting periods of the previous 4 accounting periods.
Condition B is that at least one of the group’s members is located in the United Kingdom.
The threshold for an accounting period is the amount given by multiplying 750 million euros by the amount given by dividing the number of days in the accounting period by 365.
For the purposes of this section, and section 127(5), the revenue of the members of a multinational group for a period is to be determined by reference to the consolidated financial statements of the ultimate parent for that period.
This section applies for the purpose of determining whether condition A in section 129(2) is met by a multinational group in an accounting period (“the qualifying period”) where its composition has changed—
in that period, or
during the previous 4 accounting periods (“the testing period”).
Reference in subsection (1) to a change in the composition of a multinational group includes its formation as a result of the acquisition by one entity of ownership interests in another.
Where a member of the multinational group was not a member of any consolidated group in one or more of the accounting periods in the testing period—
its revenues for those accounting periods are to be determined by reference to its financial statements or any consolidated financial statements in which its revenue is included (and, if necessary, apportioned on a just and reasonable basis to those accounting periods), and
those revenues are to be treated as forming part of the revenues of the multinational group in those periods (whether or not the group existed in those periods).
Where a multinational group is the result of a merger of two or more consolidated groups in the qualifying period or the testing period, for each accounting period of those periods in which they were separate groups, add together the revenues of each consolidated group for that period (determined by reference to the consolidated financial statements of the ultimate parent of each group and if necessary, apportioned on a just and reasonable basis to the accounting period of the merged group) to determine whether the threshold in section 129(4) is met for that period.
For the purposes of this section “merger” means any arrangement that results in two or more consolidated groups becoming a single consolidated group.
Where a multinational group is the result of a qualifying de-merger (“a de-merged group”), section 129 has effect in relation to that group for its first accounting period that ends after the de-merger, and in the 3 accounting periods that follow it as if for subsection (2) there were substituted—
In this section “qualifying de-merger” means the separation of members of a multinational group that meets condition A in section 129(2) into two or more consolidated groups, such that those members cease to all be consolidated by the same ultimate parent.
The effective tax rate of the standard members of a multinational group in a territory for an accounting period is determined as follows— Step 1 Determine, in accordance with Chapter 4, the adjusted profits for that period of each standard member of that group in that territory. Step 2 Subtract the sum of the losses of those members of the group that made a loss in that period from the sum of the profits of those members of the group that made a profit in that period. Step 3 If the result of Step 2 is nil or less, the effective tax rate is to be treated as 15%. Otherwise, proceed to Step 4. Step 4 Determine the combined covered tax balance for the standard members of the group in that territory (which may be negative). Step 5 If that balance is nil the effective tax rate is 0%. Otherwise, proceed to Step 6. Step 6 Divide the combined covered tax balance by the result of Step 2. Step 7 Except where Step 3 or 5 applies, the effective tax rate of the standard members of that group is X% where X (which will be negative if the combined covered tax balance is negative) is the result of Step 6 multiplied by 100.
The combined covered tax balance for standard members of a multinational group in a territory is— Section 164 contains provision about the determination of covered tax balances of members of multinational groups.
where those members only have positive covered tax balances (see Chapter 5), the sum of those balances,
where those members only have negative covered tax balances (see that Chapter), the sum of those balances expressed as a negative number, or
where those members have a mixture of positive covered tax balances and negative covered tax balances, the amount (which may be positive or negative) given by subtracting the sum of those negative covered tax balances from the sum of those positive covered tax balances.
For the purposes of this Part—
a member of a multinational group is a “standard member” if it is not—
an investment entity, or
a minority owned member, and
a stateless member of a multinational group is to be treated as being the sole member of the group located in a nominal territory.
For the purposes of this Part, references to the adjusted profits of a member of a multinational group are to the underlying profits of that member adjusted in accordance with this Chapter and (to the extent applicable) Chapter 8.
Sections 134 to 137 set out how to determine the underlying profits.
Sections 138 to 158 set out various adjustments that may need to be made to those profits.
Sections 159 and 160 set out adjustments to be made in relation to members that are permanent establishments.
Sections 161 to 164 make provision for elections for certain matters to be calculated in an alternative manner.
Sections 167 to 171 set out adjustments in relation to transparent and hybrid entities and entities subject to a “qualifying dividend regime”.
Other provisions of this Part may require further adjustments of underlying profits, including provision in—
Chapter 9 (investment entities), and
Schedule 16 (transitional provision).
The normal rule is that the underlying profits of a member of a multinational group, other than a member that is a permanent establishment, are the member’s profits as they would be determined for that member in preparing consolidated financial statements for the ultimate parent.
But those profits may instead be determined on the basis of an alternative accounting standard, and information in the separate financial accounts of the member, if all of the conditions in subsection (3) are met.
Those conditions are that—
it is not reasonably practicable to determine those profits on the basis of the accounting standard used in the preparation of the consolidated financial statements of the ultimate parent,
the alternative accounting standard is an acceptable accounting standard or an authorised accounting standard,
the alternative accounting standard is that used for the financial accounts of the member, and
the information in those accounts is reliable.
Where an alternative accounting standard is used and an amount relevant to the underlying profits of a member of a multinational group is recorded in a currency other than the currency used for the consolidated financial statements of the ultimate parent, that amount is to be converted to that currency for the purposes of this Part.
Subsection (6) applies where the application of a particular policy of the alternative accounting standard in the determination of the profits of the member results in a significant accounting standard difference that would not arise if the accounting standard of the ultimate parent had been applied.
The underlying profits are to be adjusted to eliminate that difference (as if the accounting standard of the ultimate parent had been applied).
Information in the financial accounts of the member is “reliable” if an auditor applying the generally accepted auditing standards of a relevant territory would reasonably conclude the member has in place such processes relating to their preparation as are likely to make the information in the financial accounts a fair and accurate description of the income, expenses, assets and liabilities of that member.
For the purposes of subsection (7), the following are relevant territories—
the territory in which the member is located;
the territory in which the ultimate parent is located;
if the member is a flow-through entity (see section 168(2)) that is a stateless entity, the territory in which it was created.
For the purposes of this section, reference to a “significant accounting standard difference” is to a difference of more than 1 million euros between the treatment of an amount in the financial accounts of a member of a multinational group and the consolidated financial statements of the ultimate parent that is not eliminated over time.
The underlying profits of a member of a multinational group that is a permanent establishment are the member’s profits—
if the member has separate financial accounts, as reflected in those accounts, and
if not, as reflected in the underlying profits accounts of the main entity, attributed between the permanent establishment and the main entity in accordance with section 159.
If the member is a permanent establishment falling within paragraph (d) of section 232(2) (income of permanent establishment exempt from tax in territory of main entity) the member’s underlying profits are determined only by reference to its relevant income and relevant expenses.
For the purposes of subsection (2)—
the relevant income of the member is the income of the member that is exempted from tax in the territory where the main entity is located that is attributable to operations carried out outside the territory the main entity is located in, and
the relevant expenses of the member are such of its expenses as are attributable to those operations and are not deducted for tax purposes in the territory of the main entity.
Profits (as determined in accordance with this Part) of a permanent establishment are not to be taken into account in determining the adjusted profits of the main entity, and vice versa.
But subsection (4)—
does not apply to profits of a permanent establishment that are excluded from its profits as a result of an adjustment under section 159, and
is subject to section 160 (attribution of losses between permanent establishment and main entity).
In this Part, reference to the “underlying profits accounts” of a member of a multinational group is to the statements or accounts (which may in some circumstances be hypothetical) that are the basis of the determination of the member’s underlying profits for the purposes of this Part.
Except as required by any other provision of this Part, amounts that are recognised outside the profit and loss account in the underlying profits accounts of a member of a multinational group are not to be reflected in the underlying profits of that member.
The underlying profits of a member of a multinational group for an accounting period are to be adjusted by adding back any debit, and excluding any credit, for tax expense amounts reflected in its those profits.
In this Part “tax expense amount” means an amount of tax expense (including a deferred tax expense) in respect of—
a covered tax (whether or not the income to which the tax relates are excluded from adjusted profits for the purposes of this Part);
multinational top-up tax, or any tax equivalent to multinational top-up tax;
a qualifying domestic top-up tax (see section 256);
a qualifying undertaxed profits tax (see section 257);
taxes accrued by an insurance company in respect of returns to policyholders to the extent that section 152(2) applies in relation to those taxes;
a disqualified refundable imputation tax (see section 253).
The underlying profits of a member of a multinational group are to be adjusted so that they include income, expenses, gains and losses arising from transactions between that member and other members of that group.
Subsection (1) is subject to—
section 137 (amounts outside profit and loss excluded), and
section 164 (where an election is made under that section to exclude profits from intra-group transactions).
The underlying profits of a member of a multinational group for an accounting period are to be adjusted so that they do not reflect relevant share acquisition adjustments.
“Relevant share acquisition adjustment” means a purchase accounting adjustment to the consolidated financial statements of an ultimate parent of a multinational group arising as a result of an entity becoming a member of the group as a result of the acquisition of shares in the entity by an existing member of the group.
This section does not apply to a relevant share acquisition adjustment resulting from an acquisition of shares before 1 December 2021 if it is not reasonably practicable to identify the adjustment made.
The underlying profits of a member of a multinational group are to be adjusted so as to exclude any excluded dividends received or accrued by that member.
“Excluded dividends” means—
a dividend or other distribution arising as a result of a qualifying interest in a flow-through entity (see section 168), or
any other dividend or other distribution arising as a result of a qualifying interest in an entity, other than a dividend or other distribution falling within subsection (3).
The following fall within this subsection—
a dividend or other distribution arising as a result of a qualifying interest that is a short-term portfolio holding;
a dividend or other distribution arising as a result of a qualifying interest in an investment entity that is subject to an election under section 214 (taxable distribution method election);
a dividend or other distribution made by a member of a multinational group if—
its recipient is a member of the same group, and
payments in respect of the distribution (whether or not the distribution was accounted for as a distribution at the time of payment) are treated as an expense of the member that made it for the purposes of determining the member’s underlying profits, or
any other dividend or other distribution to the extent it reflects debt rather than a qualifying interest.
For the purposes of subsection (2) a qualifying interest in an entity held by a member of a multinational group is a portfolio holding if, on the vesting date of the distribution, the members of that group do not, between them, have qualifying interests that entitle them to 10% or more of the entity’s—
profits,
capital,
reserves, and
voting rights.
A portfolio holding held by a member of a multinational group is a short-term portfolio holding if it was held for less than 1 year before the vesting date of the distribution.
The vesting date of a distribution is the earlier of—
the day on which it is made, and
the day on which the person to whom it arises is entitled to have it made.
The filing member of a multinational group may elect that all portfolio holdings held by a member of the group specified in the election are to be treated for the purposes of this section as short-term portfolio holdings.
Paragraph 1 of Schedule 15 (long term elections) applies to an election under subsection (7).
In this section, and in section 142, “qualifying interest” in an entity means—
a direct ownership interest in it, or
an entitlement to exercise voting rights in relation to it.
The underlying profits of a member of a multinational group are to be adjusted so as to exclude any excluded equity gain or loss.
“Excluded equity gain or loss” means any gain, profit or loss arising from—
gains and losses from changes in fair value of a qualifying interest or the impairment of such an interest, other than an interest to which subsection (3) applies,
profit or loss in respect of a qualifying interest included in underlying profits under the equity method of accounting, other than an interest to which subsection (3) applies, or
gains and losses from a disposition of a qualifying interest, other than an interest to which subsection (3) applies.
This subsection applies to a qualifying interest in an entity if the members of the multinational group do not, at the relevant time, have qualifying interests between them that entitle them to 10% or more of that entity’s—
profits,
capital,
reserves, and
voting rights.
The “relevant time” means—
for the purposes of testing whether subsection (3) applies to an interest for the purposes of subsection (2)(a) or (b), the end of the accounting period in which the gain, profit or loss arose, and
for the purposes of testing whether subsection (3) applies to an interest for the purpose of subsection (2)(c), immediately before the disposition.
See also section 165 which provides for an election to treat certain gains or losses as not being excluded equity gains or losses.
The underlying profits of a member of a multinational group are to be adjusted so as to include any relevant revaluation method gain or loss.
“Relevant revaluation method gain or loss” means a gain or loss, before making any adjustment to reflect tax expense amounts, arising as a result of the use of an accounting method or practice that—
periodically adjusts the carrying value of the member’s property, plant and equipment to its fair value,
records the changes in value in other comprehensive income, and
does not subsequently report the gains or losses through the profit and loss account.
In this Part—
“international shipping” means the transportation of passengers or cargo by ship between different territories;
This section only applies in relation to a member of a multinational group where its accounting currency and its tax currency are different.
Where— the member’s underlying profits are to be adjusted so that the gain or loss is reflected in those profits on the same basis it is reflected in its taxable income.
the member has a gain or a loss as a result of fluctuations in the exchange rate between its accounting currency and its tax currency, and
the gain or loss is reflected differently in its taxable income and in the determination of its underlying profits (including where it is not reflected at all in one of those),
Where— the member’s underlying profits are to be adjusted to exclude that gain or loss.
the member has a gain or a loss as a result of fluctuations in the exchange rate between its accounting currency and a third currency,
the gain or loss is reflected in its underlying profits, and
the gain or loss is not reflected, or is reflected to a different extent, in its taxable income,
Where— the member’s underlying profits are to be adjusted so that the gain or loss is fully reflected in those profits (whether or not it is reflected in its taxable income).
the member has a gain or a loss as a result of fluctuations in the exchange rate between its tax currency and a third currency, and
the income or loss is not reflected, or is reflected to a different extent, in its underlying profits,
In this Part—
“tax currency” means the currency in which the profits of that member are determined for the purposes of determining its liability to covered taxes in the territory in which it is located;
“taxable income” means income subject to, and determined for the purposes of, covered taxes.
Where the underlying profits of a member of a multinational group reflects— those profits are to be adjusted to exclude those expenses.
expenses accrued for illegal payments (for example, bribes or kickbacks), or
expenses accrued for fines or penalties of 50,000 euros or more,
For the purposes of subsection (1)(a), a payment is illegal if the making of that payment is, or forms part of conduct which is, an offence under the law of—
the United Kingdom,
the territory of the member, or
the territory of the ultimate parent.
For the purposes of subsection (1)(b), where more than one fine or penalty is accrued in respect of the same conduct, or for continuing conduct, those fines or penalties are to be aggregated.
Where there has been a change to the net assets and liabilities of a member of a multinational group at the start of an accounting period, the underlying profits of that member for that period are to be adjusted to include the amount of that change if the change is attributable to—
a change in accounting policy that affects income or expenses included in determining the member’s adjusted profits, or
a correction of an error reflected in the determination, for the purposes of this Part, of the adjusted profits of the member for a previous accounting period, except to the extent the correction of the error results in a material decrease to the member’s liability to covered taxes such that section 217 (post-filing adjustments of covered taxes) applies.
Where the underlying profits of a member of a multinational group for an accounting period reflect pension expense, the underlying profits are to be adjusted in accordance with the following steps— Step 1 Determine whether income (expressed as a positive number) or expense (expressed as a negative number) has accrued to the member in respect of the pension fund in the period. Step 2 Add the sum of contributions made to the pension fund by the member in the period to the result of Step 1. Step 3 If the result of Step 2 is more than nil, reduce the underlying profits by that amount. If the result of Step 2 is less than nil, increase the underlying profits by that amount (as expressed as a positive number).
The underlying profits of a member of a multinational group are to be adjusted (if necessary) to secure that—
qualifying refundable tax credits are treated as income, and
other tax credits (refundable or otherwise) are not treated as income.
A refundable tax credit is “qualifying” to the extent that, under the law of the territory in which it is given, it entitles a person to receive (by way of payment or discharge of liability) the amount of the refundable tax credit within 4 years of meeting the conditions for receiving it.
But a refundable tax credit is never qualifying if it is creditable or refundable pursuant to a qualified refundable imputation tax or a disqualified refundable imputation tax (see section 253).
In this Part “refundable tax credit” means a tax credit which— is payable in cash or cash equivalents (which for these purposes includes by way of discharge against a liability to a tax which is not a covered tax).
after any liability to covered taxes has been reduced or discharged by it, or
in the absence of any tax liability to covered taxes,
Subsection (6) applies to a member of a multinational group if any of Conditions A to D are met.
Condition A is that—
a debit is recorded in the underlying profits accounts of the member that arises from a transaction (“the relevant transaction”) comprising a transfer of an asset between the member and another member of that group,
both members are located in the same territory, and
the relevant transaction is not recorded on an arm’s length basis.
Condition B is that—
the member is party to a transaction (“the relevant transaction”) with another member of that group,
both members are located in the same territory,
one of the members is a minority owned member and the other is not, and
the relevant transaction is not recorded in the member’s underlying profits accounts on an arm’s length basis.
Condition C is that—
the member is party to a transaction (“the relevant transaction”) with another member of that group,
both members are located in the same territory,
one of the members is an investment entity and the other is not, and
the relevant transaction is not recorded in the member’s underlying profits accounts on an arm’s length basis.
Condition D is that—
the member is party to a transaction (“the relevant transaction”) with another member of that group,
both members are located in the same territory, and
the recorded value of the relevant transaction is not the same in each member’s underlying profits accounts.
Where this subsection applies to a member of a multinational group, the underlying profits of the member are to be adjusted to secure that the relevant transaction is reflected on an arm’s length basis.
In this Part “arm’s length basis”, in relation to a transaction between members of the same multinational group, means reflecting the conditions of the transaction as would have been obtained had the transaction been conducted between independent enterprises in a comparable transaction under comparable circumstances.
This section applies if—
a transaction between two members of a multinational group located in different territories is not recorded in the same amount, or is not recorded on an arm’s length basis (or is not recorded at all), in the underlying profits accounts of both of those members, and
there is a permanent difference in respect of the transaction in relation to one or both of those members as a result of adjustments to the taxable income of the member made in connection with transfer pricing.
Subsection (3) applies if—
for each member there is a permanent difference in respect of the transaction which arises as a result of adjustments made in connection with transfer pricing, and
the permanent difference for each member corresponds to the permanent difference for the other.
Where this subsection applies, the underlying profits of each of the members are to be adjusted so that the amount of the transaction reflects the amount reflected in the member’s taxable income.
Subsection (5) applies if—
one of the members (“A”) is a high tax member,
there is a permanent difference for A in respect of the transaction which arises as a result of adjustments made in connection with transfer pricing, and
there is no permanent difference for the other member (“B”) in respect of the transaction arising as a result of adjustments made in connection with transfer pricing.
Where this subsection applies—
the underlying profits of A are to be adjusted so that the amount of the transaction reflects the amount reflected in the member’s taxable income, and
an adjustment is to be made to the underlying profits of B which corresponds with the amount of the adjustment made to the profits of A.
For the purposes of this section, a member of a multinational group is a high tax member for an accounting period (“the relevant period”) if—
the nominal tax rate in the territory in which the member is located is, or exceeds, 15% in the relevant period, and
the effective tax rate of the standard members of that group in that territory is, or exceeds, 15% in either, or both, of the accounting period that immediately preceded the relevant period and the accounting period immediately before that one.
In this section reference to a “permanent difference” is to a difference between the treatment of an amount for the purposes of covered taxes and for accounting purposes that is not eliminated over time (and accordingly does not give rise to deferred tax).
This section applies to a member of a multinational group where—
it is released from an obligation to pay a debt (however that obligation arises), and
at the time of that release, one or more of the circumstances mentioned in paragraphs (a) to (c) of subsection (2) applied to it.
Those circumstances are—
that the member meets an insolvency condition mentioned in paragraphs (a) to (e) of section 322(6) of CTA 2009 (release of debts);
that—
it is reasonable to suppose that within 12 months, ignoring any debts owed to persons and entities that are connected to the member, the member will be unable to meet its debts to persons and entities it is not connected to as they fall due, and
the member has obtained an independent expert opinion confirming that is the case;
that the member’s liabilities exceed its assets.
Where the circumstance in subsection (2)(a) applies to the member, its underlying profits are to be adjusted to exclude any profits arising as a result of the release of the debt obligation.
Where— the member’s underlying profits are to be adjusted to exclude any profits arising as a result of the release of the debt obligation.
the circumstance in subsection (2)(b) applies to the member,
the circumstance in (2)(a) does not, and
the debt—
is not a debt owed to a person or entity that is connected to the member, or
the debt is owed to a person or entity that is connected to the member, but the release of the debt obligation can reasonably be regarded as part of arrangements to secure the solvency of the member that involve the release of debt owed to a person that is not connected to the member,
Subsection (6) applies where—
the circumstance in subsection (2)(c) applies to the member,
neither the circumstance in subsection (2)(a) nor (2)(b) applies to the member, and
the debt is not a debt owed to a person or entity that is connected to the member.
Where this subsection applies, the underlying profits of the member are to be adjusted to exclude the lesser of—
the amount of any profits arising as a result of the release of the debt obligation,
if, as a result of the release of the debt obligation, the member’s assets exceed its liabilities, the amount by which its liabilities exceeded its assets immediately before the release, and
if, in determining the member’s liability to tax, some or all of the profits arising as a result of the release of the debt obligation are offset by deferred tax assets, the amount of those profits that are offset.
Where the member is released from more than one obligation to pay a debt at the same time, the release of those obligations is to be treated, for the purposes of applying the conditions in this section, as if they represented the release of a single obligation to pay a debt.
This section applies to a member of a multinational group that carries on a life assurance business.
Where amounts charged to the member’s policyholders for taxes payable by the member are reflected in its underlying profits, those profits are to be adjusted to exclude such of those amounts as would (had they not been charged to the policyholders) have formed part of the member’s tax expense amount.
Where returns to the member’s policyholders are not reflected in the member’s underlying profits but corresponding increases or decreases in the liability of the member to the policyholders are so reflected, those profits are to be adjusted so as to reflect those returns to the extent they correspond with those increases or decreases in liability.
In this section “life assurance business” has the meaning it has in section 56 of FA 2012.
The underlying profits of a member of a multinational group that is an insurance company are to be adjusted so as to exclude any expense resulting from the movement of its insurance reserves where the movement is economically matched by excluded dividends (ignoring the extent to which those dividends also reflect any investment management fees).
The underlying profits of a member of a multinational group that is an insurance company are to be adjusted so as to exclude any expense resulting from the movement of its insurance reserves where the movement is economically matched by an excluded equity gain or loss.
Where— the member’s underlying profits for that period are to be adjusted to exclude those expenses.
the underlying profits of the member of a multinational group for an accounting period reflect expenses attributable to a qualifying intra-group financing arrangement that could be reasonably expected, over the expected duration of the arrangement, to—
increase the amount of expenses taken into account in calculating the member’s underlying profits, and
not result in a corresponding increase in the taxable income of a member of the group that is a high tax member for that period,
the member is a low tax member for that period, and
the expenses are not required to be included as a result of section 155,
In this section—
“intra-group financing arrangement” means an arrangement between two or more members of a multinational group under which a member (member A) directly or indirectly provides credit or otherwise makes an investment in another member (member B);
an intra-group financing arrangement is “qualifying” if member A is a high tax member and member B is a low tax member;
a member of a multinational group is a “high tax member” in an accounting period if the effective tax rate for the standard members of the group located in the member’s territory would, ignoring intra-group financing arrangements, be 15% or more.
Where amounts recognised by a member of a multinational group as a decrease to its equity in an accounting period that is attributable to distributions paid or payable in respect of qualifying tier one capital issued by the member are not reflected in its underlying profits for that period as expenses, those profits are to be adjusted to reflect those amounts as expenses.
Where amounts recognised by a member of a multinational group as an increase to its equity in an accounting period that is attributable to distributions received or receivable in respect of qualifying tier one capital held by the member are not reflected in its underlying profits for that period as income, those profits are to be adjusted to reflect those amounts as income.
In this section “qualifying tier one capital” means an instrument issued by an entity pursuant to regulatory requirements applicable to the banking or insurance sector that is convertible to equity or written down if a pre-specified trigger event occurs and that has other features which are designed to aid loss absorbency in the event of a financial crisis.
Where the underlying profits of a member of a multinational group for an accounting period reflect the inclusion of international shipping profits, the member’s underlying profits for that period are to be adjusted to exclude those profits.
The member’s international shipping profits for the period are the sum of the member’s—
core international shipping profits (see section 157), and
ancillary international shipping profits (see section 158).
Subsection (1) does not apply if, in the period, the strategic and commercial management of any ship used in international shipping giving rise to those profits is not effectively carried on within the territory in which the member is located.
In this section, and in sections 157 and 158—
“transportation” does not include towing or dredging.
A member’s core international shipping profits for a period are the member’s core international shipping revenue for the period less the member’s core international shipping costs for the period.
A member’s core international shipping revenue is all revenue earned by the member in consideration for the member’s performance of core international shipping activities.
A member’s core international shipping costs are the sum of—
all costs incurred by the member that are directly attributable to the member’s performance of core international shipping activities, and
all costs incurred by the member that are indirectly attributable to the member’s performance of core international shipping activities multiplied by the core international shipping factor.
The core international shipping factor is the member’s core international shipping revenue divided by all revenue earned by the member from any source.
An activity is a core international shipping activity if it is of a type referred to in subsection (6).
The types of activity are—
carrying out international shipping, whether alone or in conjunction with another person;
leasing as lessor a ship to be used for international shipping, where—
the ship is leased fully equipped, crewed and supplied, or
the lessee is a member of the same multinational group and the purpose of the lease is to allow that member to carry out a core international shipping activity;
arranging for another person to carry out international shipping under slot-chartering arrangements;
the sale of a ship used in international shipping, where the ship has been held for use by the member for at least one year.
A member’s ancillary international shipping profits for a period are the member’s ancillary international shipping revenue for the period, less—
the member’s ancillary international shipping costs for the period, and
the member’s ancillary international shipping profit cap adjustment for the period.
A member’s ancillary international shipping revenue is all revenue earned by the member in consideration for the member’s performance of ancillary international shipping activities.
A member’s ancillary international shipping costs are the sum of—
all costs incurred by the member that are directly attributable to the member’s performance of ancillary international shipping activities, and
all costs incurred by the member that are indirectly attributable to the member’s performance of ancillary international shipping activities multiplied by the ancillary international shipping factor.
The ancillary international shipping factor is the ancillary international shipping revenue divided by all revenue earned by the member from any source.
An activity is an ancillary international shipping activity if—
it is of a type referred to in subsection (6), and
it is performed primarily in connection with international shipping.
The types of activity are—
leasing as lessor a ship to be used for international shipping, where—
the ship is not leased fully equipped, crewed and supplied,
the lessee is a third party, and
the lease has not been in effect for a period exceeding three years, or entered into on terms that would result in the lease being in effect for such a period;
selling tickets for a domestic leg of an international voyage carried out by a third party;
leasing as lessor a container of a kind used for international shipping;
storing such a container for a short period, including by leasing as lessor space for the storage of such a container by another person;
providing support services (see subsection (7)(e)) to persons engaged in international shipping;
holding assets necessary for the member to carry out a core international shipping activity;
the disposal of emissions allowances it is necessary for the member to hold in order to carry out international shipping.
For the purposes of subsection (6)—
“third party”, in relation to a member of a multinational group, means a person that is not—
the member, or
a member of the same multinational group;
“domestic leg of an international voyage” means the transportation of passengers or cargo by ship between two locations in a single territory in circumstances where the ship’s overall voyage has proceeded from or will continue to a different territory;
a lease of a ship is in effect for the period in which the practical effect of that lease and any associated arrangements (including any other lease) is that a person is in the position of a lessee of the ship, whether or not the lease or any other document expressly provides that the person is a lessee of the ship for the whole of that period;
“lessee”, in relation to a ship, means the person referred to in paragraph (c);
“support services” means engineering, maintenance, cargo handling, catering and customer relations services.
The member’s ancillary international shipping profit cap adjustment is to be calculated by taking the following steps— Step 1 Determine the “cap threshold” in accordance with Steps 2 to 5. Step 2 Calculate the core international shipping profits for each member of the group in the territory. Step 3 Add together the amounts calculated at Step 2. Step 4 If the result of Step 3 is nil or less, the cap threshold is nil. Otherwise, proceed to Step 5. Step 5 Divide the result of Step 3 by two. This is the cap threshold. Step 6 Calculate the ancillary international shipping profits for each member of the group in the territory (ignoring the requirement to subtract the ancillary international shipping profit cap adjustment). Step 7 Add together the amounts calculated at Step 6. Step 8 Subtract the cap threshold from the result of Step 7. If the result is nil or less, the member’s ancillary international shipping profit cap adjustment is nil. Otherwise, proceed to Step 9. Step 9 If the ancillary international shipping profits for the member calculated at Step 6 are nil or less, the member’s ancillary international shipping profit cap adjustment is nil. Otherwise, proceed to Step 10. Step 10 Add together any positive ancillary international shipping profits calculated at Step 6. Step 11 Divide the ancillary international shipping profits for the member calculated at Step 6 by the result of Step 10. Step 12 Multiply the result of Step 8 by the result of Step 11. This is the member’s ancillary international shipping profit cap adjustment.
Where a member of a multinational group is a permanent establishment falling within paragraph (a) of section 232(2) (entity treated as permanent establishment in accordance with tax treaty), its underlying profits are to be adjusted so that they only reflect amounts of income and expenses that are attributable to it in accordance with the tax treaty in accordance with which it is treated as a permanent establishment (regardless of whether an amount of income is subject to tax or not, or an amount of expenses are deductible or not).
Where a member of a multinational group is a permanent establishment falling within paragraph (b) of section 232(2) (permanent establishment taxed on similar basis to residents in absence of tax treaty), its underlying profits are to be adjusted so that they only reflect amounts of income and expenses that are attributable to it in accordance with the law of the territory in which the member is located (regardless of whether an amount of income is subject to tax or not, or an amount of expenses are deductible or not).
Where a member of a multinational group is a permanent establishment falling within paragraph (c) of section 232(2) (permanent establishment located in territory without corporate income tax), its underlying profits are to be adjusted so that they only reflect amounts of income and expenses that would have been attributed to it in accordance with Article 7 of the OECD tax model.
Subsection (2) applies where, on determining (ignoring this section) the adjusted profits of a member of a multinational group that is a permanent establishment for an accounting period (“the relevant period”), that member has a loss.
So much of that loss as— is to be treated as an expense of the main entity for the purposes of determining the adjusted profits of the main entity for the relevant period.
is treated as an allowable expense of the main entity for the purposes of the computation of tax in the territory in which the main entity is located, and
is not set off against an item of income that is subject to tax under the laws of both the territory of the permanent establishment and the territory of the main entity,
Subsections (4) and (5) apply where an amount (“the relevant amount”) is treated as an expense of the main entity for the purposes of determining its adjusted profits for the relevant period as a result of subsection (2).
The relevant amount is to be excluded from the adjusted profits of the permanent establishment for the relevant period.
Where, on determining (ignoring this section) the adjusted profits of the permanent establishment for an accounting period after the relevant period, the permanent establishment has made a profit for that period, those profits are to be treated as income of the main entity for the purpose of determining that entity’s adjusted profits for that period.
But subsection (5) only applies until the total amount treated as income of the main entity as a result of that subsection is equal to the relevant amount.
Where profits of the permanent establishment for an accounting period are treated as income of the main entity as a result of subsection (5), those profits are to be excluded from the adjusted profits of the permanent establishment for that period.
The filing member of a multinational group may elect that all of the group’s members in a territory, or all of the group’s members in that territory that are investment entities, are to use the realisation principle in determining gains and losses in relation to—
all assets and liabilities that are subject to fair value or impairment accounting, or
tangible assets that are subject to fair value accounting or impairment accounting.
Where such an election is in force in relation to members of multinational group in a territory—
the underlying profits of each of the group’s members for each of the accounting periods in respect of which the election is in force are to be adjusted so as to exclude gains and losses in respect of assets or liabilities to which the election applies that are attributable to fair value or impairment accounting;
the carrying value of an asset or liability to which the election applies to be used for the purposes of determining gains or losses in respect of that asset or liability, is to be its carrying value at the later of—
the commencement of the first accounting period of the multinational group to which the election applied, or
the time the asset was acquired or the liability was incurred.
Paragraph 1 of Schedule 15 (long term elections) applies to an election under this section.
Where an election under this section has been revoked, the underlying profits of each member of a multinational group in respect of which the election was in force are to be adjusted in the first accounting period in respect of which the election no longer applies (“the revocation period”) by adjusting for the change in treatment of the assets and liabilities that were subject to the election and that remain held by the member at the commencement of the revocation period.
To adjust the underlying profits of a member of a multinational group for the change in treatment of an asset or liability subject to an election under this section, subtract the carrying value of that asset or liability as determined in accordance with subsection (2)(b) from the fair value of the asset or liability at the commencement of the revocation period and—
if the amount given is positive, add it to those profits, or
if the amount is negative, subtract it from those profits.
The filing member of a multinational group may make an election under this section for the members of the group located in a territory to adjust their underlying profits in accordance with subsection (2).
Where such an election has effect—
the underlying profits of each such member is adjusted by substituting, for the amount of any expense for stock-based compensation, the amount that was allowed as a deduction for the same expense when calculating the member’s taxable income, and
where such a member has an expense for stock-based compensation that arises in connection with an option that expires without exercise, the underlying profits of that member for the accounting period in which the option expires are to be increased by such amount of that expense as was an expense in determining the member’s adjusted profits for a previous accounting period.
Where— the member’s adjusted profits are to be adjusted to include the amount of that excess as if it were income.
the underlying profits of a member of a multinational group are adjusted in accordance with subsection (2) in respect of an amount of stock-based compensation,
some expenses in respect of that compensation were recorded in the underlying profits of the member in one or more accounting periods before the election had effect, and
the sum of the expenses recorded in those periods exceeds the sum of what those expenses would have been had the election been in effect for those periods,
Paragraph 1 of Schedule 15 (long term elections) applies to an election under this section.
Where— the member’s adjusted profits are to be adjusted to include the amount of that excess as if it were income.
the underlying profits of a member of a multinational group are adjusted in accordance with subsection (2),
the election is revoked before all of the stock-based compensation has been paid, and
the sum of amounts deducted in accordance with subsection (2) exceeds the sum of the financial account expense accrued that has been paid,
The filing member of a multinational group may elect that the net gain in respect of the disposal of local tangible assets by standard members of the group in a territory in an accounting period (“the election period”) is to be spread across that period and the preceding 4 accounting periods (collectively “the look-back period”) in accordance with subsection (2).
To spread the net gain across those periods take the following steps— Step 1 For each standard member of the group in the territory, determine whether it has net losses in the first accounting period of the look-back period (“the carry-back period”) in respect of the disposal of local tangible assets (ignoring any losses in relation to which these steps have previously been carried out). Step 2 Allocate the proportion of the net gain in the election period to each standard member with such losses in the carry-back period that is equal to the proportion those losses represent of the total losses in respect of the disposal of local tangible assets of all such members of the group in the carry-back period. Step 3 Adjust the underlying profits of each such member by reducing the member’s losses (but not below nil) by the amount allocated to it under Step 2. Step 4 If there remains an amount of the net gain which was not used to reduce members’ losses in accordance with Step 3, carry out Steps 1 to 3 again, but as if— the reference in Step 2 to the net gain were to that amount, and the reference to the first accounting period of the look-back period were to the second accounting period of the look-back period. Step 5 If there still remains an amount of the net gain which was not used to reduce the members’ losses, carry out Steps 1 to 3 again but as if— the reference in Step 2 to the net gain were to that amount, and the reference to the first accounting period of the look-back period were to the third accounting period of the look-back period. Step 6 If there still remains an amount of the net gain which was not used to reduce the members’ losses, carry out Steps 1 to 3 again but as if— the reference in Step 2 to the net gain were to that amount, and the reference to the first accounting period of the look-back period were to the fourth accounting period of the look-back period. Step 7 If there still remains an amount of the net gain which was not used to reduce the members’ losses, carry out Steps 1 to 3 again but as if— the reference in Step 2 to the net gain were to that amount, and the reference to the first accounting period of the look-back period were to the election period. Step 8 If there still remains an amount of the net gain which was not used to reduced the members’ losses, divide the amount remaining by 5. Step 9 For each accounting period of the look-back period, determine whether any member of the group in the territory has net gains from the disposal of local tangible assets. Step 10 For each accounting period in the look-back period where at least one standard member in the territory has such gains, adjust the underlying profits of each member who has such gains in that period by adding the amount given by multiplying the result of Step 8 by the amount given by dividing the amount of those gains by the amount of net gains from the disposal of local tangible assets of all members in that territory for that period. Step 11 For each accounting period in the look-back period where no member has any such gains, adjust the underlying profits of each member in the territory by adding the amount given by multiplying the result of Step 8 by the amount given by dividing 1 by the number of members of the group in that territory.
For the purposes of this section any gain or loss arising from the transfer of assets between standard members of a multinational group is to be ignored.
Where, as a result of an election under this section, the underlying profits of a member of a multinational group in an accounting period is adjusted, the following are to be recalculated for that period—
the effective tax rate for the member and the other members of that group located in the same territory, and
the top-up amounts that those members would have.
Section 206—
makes provision about the consequences of a recalculation (which may include the generation of an additional top-up amount), and
applies to recalculations under subsection (4).
Where an election under this section has effect in relation to a member of a multinational group, any amount of tax with respect to any gains or loss in respect of the disposal of local tangible assets in the election year is to be excluded from the calculation of the member’s covered tax balance.
Paragraph 2 of Schedule 15 (annual elections) applies to an election under this section.
In this section “local tangible asset” means immovable property in the same territory as the member disposing of it is located.
The filing member of a multinational group may elect that standard members of the group that are located in the same territory and are included in a tax consolidation group are to apply the consolidated accounting treatment of the ultimate parent to eliminate income, expenses, gains and losses arising from transactions between those members.
Where an election under this section has effect—
the underlying profits of those members are to be adjusted accordingly in the accounting periods for which the election has effect, and
the underlying profits of those members are to be adjusted for the first accounting period for which the election has effect so as to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising from the making of the election.
Paragraph 1 of Schedule 15 (long term elections) applies to an election under this section.
Where an election under this section is revoked, the underlying profits of the members to whom the election applied are to be adjusted in the first accounting period in which the revocation has effect so as to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising from the revocation of the election.
For the purposes of this section, members of a multinational group in a territory are included in a “tax consolidation group” if under the law of that territory the income, expenses, gains or losses of those members may for tax purposes be aggregated, surrendered to each other or otherwise shared or transferred between them as a result of a connection between those members.
The filing member of a multinational group may elect that qualifying excluded equity gains or losses of the standard members of the group in a territory are to be treated as not being excluded equity gains or losses for the purposes of section 142.
Excluded equity gains or losses are “qualifying” if—
those gains or losses are subject to covered taxes (as taxable gains or allowable losses) in that territory, or
in the case of gains or losses falling within section 142(2)(a) that are not subject to covered taxes in that territory, gains or losses on the disposal of the qualifying interest in question are subject to covered taxes in that territory.
Paragraph 1 of Schedule 15 (long term elections) applies to an election under subsection (1).
But a revocation of the election under that paragraph does not have effect in relation to equity gains or losses in respect of an ownership interest if— Accordingly, subsection (1) will apply to equity gains and losses in respect of that ownership interest even after the election is revoked.
any member’s adjusted profits have included a loss in respect of that ownership interest as a result of subsection (1), and
that loss would otherwise have been excluded from those profits as a result of section 142(1).
The filing member of a multinational group may elect that the underlying profits of a member of the group specified in the election are to be adjusted to exclude qualifying gains or losses arising from fluctuations in exchange rates.
A gain or loss arising from fluctuations in exchange rates is “qualifying” to the extent—
the gain or loss is attributable to an instrument intended to act as a hedge against currency risk in ownership interests held by the member or another member of the group, other than an ownership interest in an entity falling within subsection (3),
the gain or loss is recognised in other comprehensive income in the consolidated financial statements of the ultimate parent,
the instrument is considered an effective net investment hedge under the authorised accounting standard upon which those statements are prepared,
where the instrument is held by the member, the economic and accounting effect of the hedge has not been transferred to any other entity, and
where the instrument is not held by the member, the economic and accounting effect of the hedge has been transferred to the member.
An ownership interest in an entity held by a member of a multinational group falls within this subsection if the members of that group do not, between them, have qualifying interests that entitle them to 10% or more of the entity’s —
profits,
capital,
reserves, and
voting rights.
Paragraph 1 of Schedule 15 (long term elections) applies to an election under this section.