Tunisia - Central Tunisia Irrigation Project : Loan 2234 - Project Agreement - 2 - Conformed

Schedule 18 to FA 1998 (company tax returns) is amended as follows. In paragraph 52(2A)(b) (application of provisions about discovery assessments to amounts paid by way of R&D expenditure credit), for “Chapter 6A of Part 3” substitute “Chapter 1A of Part 13”. In paragraph 83A (application of Part 9A of the Schedule to claims for R&D relief), for the words from “to” to the end substitute “to claims for relief under Part 13 of the Corporation Tax Act 2009 (relief for research and development).” In paragraph 83E (deadlines for claiming R&D relief)—

CTA 2010 is amended as follows. In section 269DA(2) (meaning of banking company’s “surcharge profits”), in the definition of “RDEC”, for “Chapter 6A of Part 3 of CTA 2009 (trade profits: R&D expenditure credits)” substitute “Chapter 1A of Part 13 of CTA 2009 (R&D expenditure credit)”. In Part 8A (profits from exploiting patents etc)— In Chapter 9 of Part 8B (treatment of R&D credits and relief for purposes of Northern Ireland rate)—

Sub-paragraphs (2) and (3) apply if, but for those sub-paragraphs— in respect of expenditure attributable to the same research and development. If company B would have been entitled to old R&D relief in respect of its expenditure had the Part 1 amendments not been made, only company B is entitled to the relief. In any other case, only company A is entitled to the relief. Sub-paragraph (5) applies if— The company is to be treated as satisfying sections 1042F(4) and 1053A(4) of CTA 2009 for the purposes of ascertaining the entitlement of another company to new R&D relief in respect of expenditure attributable to the same research and development as the expenditure mentioned in sub-paragraph (4). Sub-paragraph (7) applies if— For the purpose of ascertaining the entitlement of company D to new R&D relief, the research and development is to be treated as contracted out by company D within the meaning of section 1133 of CTA 2009 (as it has effect after the Part 1 amendments). In this paragraph—

Sub-paragraph (2) applies if, in an accounting period beginning before the appointed day but ending on or after 1 April 2023, a company— The amount of R&D tax credit to which the company is entitled for the period is to be determined as if the amendment made by section 4(3)(d) of FA 2023 (reduction in rate of credit from 14.5% to 10%) had not been made. Subsections (2) to (7) of section 1045ZA of CTA 2009, as inserted by paragraph 6(6), determine whether a company meets the R&D intensity condition in an accounting period for the purposes of sub-paragraph (1)(b). But that section is to be read for the purposes of sub-paragraph (3) as if— In this paragraph, “Chapter 2 surrenderable loss” and “R&D tax credit” have the same meanings as in Chapter 2 of Part 13 of CTA 2009 (see sections 1054 and 1055 of that Act).

In Schedule 24 to FA 2007 (penalties for errors), in paragraph 28(fa) (meaning of “corporation tax credit”), before paragraph (iv) insert—.

Paragraph 52 of Schedule 18 to FA 1998 (recovery of excessive payments) is amended as follows. In sub-paragraph (1), in the words before paragraph (a), for “paragraph” substitute “sub-paragraph”. In sub-paragraph (2)— In sub-paragraph (2A), after paragraph (c) insert , or. In this paragraph, “creative sector credit” means— In sub-paragraph (5)— Those amendments have effect in relation to accounting periods beginning on or after 1 April 2024.

Section 528 is amended as follows. In subsection (4)— After subsection (4B) insert— In subsection (5), for “subsection (4)(a)” substitute “determining whether the non-close condition is met”. After subsection (5A) (as inserted by paragraph 4) insert— Section 528 has effect, and is to be deemed always to have had effect, with the amendments made by this paragraph.

Section 606 (meaning of group) is amended as follows. In subsection (2), omit paragraphs (b) and (c) (but not the “or” at the end of paragraph (c)). In subsection (5), omit the definitions of “insurance company” and “insurance subsidiary”.

Section 535A (disposals of rights or interests in UK property rich companies) is amended as follows. After subsection (7) insert— In subsection (8) after “subsection (7)” insert “or (7A)”.

The amendments made by this Schedule, except those made by sub-paragraphs (16) to (18) of paragraph 9, have effect in relation to accounting periods beginning on or after the appointed day. In this Part, the “appointed day” is a day appointed by the Treasury in regulations.

The reference in section 1142B of CTA 2009 (as amended by paragraph 9(15)) to claims under section 1042C of that Act is to be read as including claims under section 104A of that Act before its repeal by paragraph 2.

Schedule 18 to FA 1998 (company tax returns etc) is amended as follows. In paragraph 10 (certain claims and elections to be included in tax return)— In the heading of Part 9D, for the words from “for” to “or” substitute “under Parts 14A to”. In paragraph 83S (application of Part 9D), for “the following reliefs—” substitute “—.

CTA 2010 is amended as follows. In section 45A(3) (conditions for carrying forward trade loss against total profits), in paragraph (b)(ii), after “section” insert “1179BF,”. In Part 8A (profits from exploiting patents etc)— In Part 8B (profits taxable at Northern Ireland rate), after Chapter 10 insert—

Part 15C of CTA 2009 (theatrical productions) is amended as follows.

(As to other capital expenditure, see section 53 and subsection (2).)

Section 1217JA (expenditure on theatrical productions that qualifies for relief) is amended as follows. In subsection (1)(b), after “(2)” insert “or (3)”. After subsection (2) insert— Those amendments have effect in relation to expenditure incurred on or after 1 April 2024.

After section 1217KC insert— That amendment has effect in relation to claims made on or after 1 April 2024.

In paragraph 83W(1) of Schedule 18 to FA 1998 (time limits for claims under Parts 15 to 15E of CTA 2009), for the words from “first” to the end substitute end of the period of— That amendment has effect in relation to accounting periods beginning on or after 1 April 2024.

In Section 528 (conditions for company), in subsection (4A), after paragraph (b) insert—.

Sub-paragraph (2) applies where— Part 12 of CTA 2010 has effect in relation to such a person for the purposes of determining whether the company meets those conditions as if the amendments made by paragraph 4 had not been made for so long as the person’s interest in the company as a proportion of all interests in the company— Sub-paragraph (4) applies where— That Schedule has effect in relation to the former qualifying investor for a qualifying purpose as if the amendments made by paragraph 4 had not been made for so long as— Sub-paragraph (6) applies when determining whether a collective investment scheme constituted before the day on which this Act is passed meets the genuine diversity of ownership condition for the purposes of any of paragraphs (a) to (c) of section 528(4A). Regulation 75(2) of the Offshore Funds (Tax) Regulations 2009 (including as it applies for the purposes of regulation 75(5) of those Regulations) has effect, for those purposes, as if it referred to a statement prepared by the manager of the scheme (instead of the documents referred to in that paragraph) which—

In section 529 (conditions as to property rental business)—

Section 452 of TIOPA 2010 (corporate interest restriction: REITs) is amended as follows. In subsection (1)(b), after “(5)” insert “, or section 535A(2),”. In subsection (4)(b), after “(5)” insert “, or section 535A(2),”.

The amendments made by this Schedule have effect—

Sub-paragraph (2) applies in relation to bearer instruments issued before 1 January 2024— The amendment made by paragraph 19(3) is to be disregarded. In sub-paragraph (1) “bearer instrument” and “UK company” have the same meaning as in Schedule 15 to FA 1999 (see paragraphs 3 and 11 of that Schedule). Sub-paragraph (5) applies in relation to UK bearer instruments within the meaning of section 99(1A) of FA 1986 issued before 1 January 2024. The amendments made by paragraph 6(2) and (3) are to be disregarded.

Section 131 (whether de-merged groups meet the revenue threshold) is amended as follows. In subsection (1), omit “if” in the second place it occurs (immediately following “A de-merged group meets condition A”). For subsection (2) substitute—

After section 147 insert— In section 148 (treatment of qualifying refundable tax credits)— After that section insert— In section 175 (amounts excluded from covered tax balance), in subsection (2), in paragraph (c), after “credit”, in the second place it occurs, insert “, or in respect of a marketable transferable tax credit,”. In section 176 (amounts to be reflected in covered tax balance), in subsection (2)— After section 176 insert—

In section 153 (exclusion of certain insurance reserve movement expense), in subsection (1) after “excluded dividends” insert “falling within section 141(2)(b)”.

Section 168 (underlying profits of transparent and reverse hybrid entities) is amended in accordance with sub-paragraphs (2) to (8). In subsection (2), in paragraph (b), after territory insert “as a result of being tax resident in that territory”. In subsection (3), after “entity” insert “or individual”. In subsection (6), in paragraph (a), after “is” insert “an entity that is” For subsection (9) substitute— In subsection (10), after “entity” insert “or an individual”. In subsection (11), in the words before paragraph (a), for “is located” substitute “was created, R is not tax resident in any territory”. After that subsection insert— In section 170 (adjustments for ultimate parent that is a flow-through entity)— In section 238 (tax transparency of entities)—

In section 177 (permanent establishments), in subsection (1), after “establishment”, in the second place it occurs, insert “(and is to be regarded as qualifying current tax expense of the permanent establishment for the purposes of applying section 175(2)(a))”. Section 178 (reallocation of tax expense) is amended as follows. In subsection (1), in the words after paragraph (b) after “qualifying” insert “current”. After subsection (1) insert— In subsection (2), in the words before Step 1, after “O” insert “(under subsections (1) and (1A))”. After subsection (4) insert— In section 179 (controlled foreign company tax regimes)—

Section 183 (substitute loss carry forward assets) is amended as follows. In subsection (3), in paragraph (b), for “in respect of which the foreign tax was calculated” substitute “in the territory in which the member is located”. In subsection (4), after “qualifying” insert “foreign”. In subsection (5), after “section” insert “and in section 183A“ After section 183 insert—

In section 197(4)—

After section 198 insert—

After section 251 insert— For the purposes of this Part of this Schedule, a country-by-country report in relation to a territory is “qualifying” if the information relating to the territory is prepared on the basis of qualified financial statements of the multinational group (see paragraph 4). Where there is no requirement under the law of any territory for a country-by-country report to be prepared and filed in respect of a multinational group, the filling member may include, in the information return in which the election is made, the information that would have been in such a report— Where such information has been included in that information return, that information is to be treated as if it were a country-by-country report in relation to the territory for the purposes of this Chapter (and where that information complies with sub-paragraph (7), the condition in sub-paragraph (2)(b) is to be treated as met). In section 276(b)(i) (application of transitional provision for domestic top-up tax purposes), for “and (8)” substitute “to (9)”.

In section 239(6)— In section 240 (location of flow-through entities), for subsection (1) substitute—

After section 256 insert— In section 194 (total top-up amount for a territory), in subsection (3), for “section 256” substitute “sections 256 and 256A”.

Paragraph 2 of Schedule 16 (intra-group transfers before entry into regime) is amended as follows. In sub-paragraph (3)(b), after “limited to” insert “the lesser of the cap amount and the sum of—. For the purposes of determining the value of a deferred tax asset under sub-paragraph (3)(b)(i)— In sub-paragraph (5)(b), for “is” substitute “, and the value of deferred tax assets that arose in relation to the assets before their transfer, are”. In determining the tax expense of the transferor in relation to the transfer of the assets— In sub-paragraph (9)— In sub-paragraph (11), for “substantially the same economic effect as” substitute “a similar effect for accounting purposes to”. Where assets are transferred from one member of a multinational group to another member of that group as a result of a series of transfers that— that series is to be treated as a single transfer of assets that falls within sub-paragraph (1). This paragraph applies to that single transfer as if—

After Schedule 16 insert— In section 227 (application of Part to joint venture groups), in subsection (1), in the words before paragraph (a), for “Schedule 16” substitute “Schedules 16 and 16A”. For section 260 (transitional provision) substitute— In Schedule 15 (elections), in paragraph 2(1), after paragraph (k) (as inserted by paragraph 40(2) of this Schedule) insert—

In section 127(12) (excluded entities) for “pensions service” substitute “pension services”. In section 128 (responsible members)— In section 130 (change in composition of multinational group), in subsection (5)—

In section 185(2)(a) (inclusion of existing deferred tax assets and liabilities on entry into regime), after “asset” insert “or liability”. In section 186 (deferred tax assets recorded at less than minimum rate)— In section 187 (election for losses to be treated as special loss deferred tax assets), in subsection (6)—

In section 205 (election to carry forward and reduce collective additional amount)— In section 217(8) (post filing adjustments of covered taxes), in paragraph (a), at the beginning insert “the reduction of the covered tax balance of the member for the prior period resulting from”.

In section 271 (election to make one member of a group liable for amounts charged)— In section 272 (determining top-up amounts of entity that is a member of a group), in subsection (8)(c)(i) for “after subsection (1) there were inserted” substitute “for subsection (1A) there were substituted”. In section 273 (determining top-up amounts of entity that is not a member of a group), in subsection (4)—

The Films Act 1985 is amended as follows. In section 6 (certification of British films) (as amended by paragraph 2), omit “and film tax relief”. In Schedule 1 (certification of British films) (as amended by paragraph 2)—

In Schedule 24 to FA 2007 (penalties for errors), in paragraph 28(fa) (meaning of “corporation tax credit”), omit paragraphs (iv) to (ivb).

Part 15E of CTA 2009 (museum and gallery exhibition tax relief) is amended as follows.

In section 1218ZCC (European expenditure condition)— In each of the following provisions, for “European” (in each place it occurs) substitute “UK”— In section 1218ZFA (defined terms)— In Schedule 4 (index of defined expressions)— For transitional provision in relation to this paragraph, see paragraph 10.

In section 1218ZCG(2) (exclusion of expenditure eligible for R&D relief or other creative sector relief), in the words before paragraph (a), for the words from “(assuming” to the end substitute “the company would be able to claim”. That amendment has effect in relation to expenditure incurred on or after 1 April 2024.

In Part 4 of Schedule 36 to FA 2004 (transitional provisions and savings: other provisions), in paragraph 51 (individuals with pre-commencement entitlement to corresponding relief), in sub-paragraph (4), for “events that are benefit crystallisation events in relation to the individual” substitute “an event that is the individual becoming entitled to a benefit under a pension scheme”.

In Schedule 6 to FA 2014 (transitional provision relating to new standard lifetime allowance for the tax year 2014-15 etc), in Part 1 (“individual protection 2014”), paragraph 1 (the protection) is amended as follows. In sub-paragraph (1)(c), for “make provision for a lifetime allowance enhancement factor” substitute “apply on that date”. Chapter 15A of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) has effect in relation to the individual as if—

The Taxation of Pension Schemes (Transitional Provisions) Order 2006 (S.I. 2006/572) is amended as follows. In article 25A (conditions to be met by stand-alone lump sums), in paragraph (3), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. In article 25B (circumstances in which stand-alone lump sums are paid), in paragraph (2), for “paragraph 2 of Schedule 29” substitute “Chapter 15A of Part 9 of ITEPA 2003”. In article 25C (payment of stand-alone lump sums: tax consequences), for paragraphs (2) and (3A) substitute— After article 25C insert— In article 25D (stand-alone lump sums: further provisions)—

The Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Individual Protection 2014 Notification) Regulations 2014 (S.I. 2014/1842) are amended as follows. In the title, for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 1 (citation and commencement), for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 4 (the paragraph 1 notice), in paragraph (1), in sub-paragraph (f), for “make provision for a lifetime allowance enhancement factor” substitute “apply”. In regulation 13 (preservation of documents), in paragraph (2), for “benefit crystallisation event” substitute “relevant benefit crystallisation event within the meaning of section 637S of ITEPA 2003”.

This paragraph applies where— Where the individual’s lifetime allowance previously-used amount is equal to or greater than the individual’s lifetime allowance, none of the individual’s lump sum and death benefit allowance is available on the occurrence of the relevant benefit crystallisation event. Otherwise, the amount of the individual’s lump sum and death benefit allowance that is available on the occurrence of the relevant benefit crystallisation event is— or, if that produces a negative result, nil. Where— sub-paragraph (3) has effect as if the amount determined under paragraph (b) of that sub-paragraph were £375,000. In sub-paragraphs (3) and (3A) “the appropriate percentage” means— The conditions mentioned in sub-paragraph (4)(a)(ii) are— But sub-paragraphs (2) to (4A) do not apply if, at the relevant time, a transitional tax-free amount certificate is in force in relation to the individual. In such a case, the amount of the individual’s lump sum and death benefit allowance that is available on the occurrence of the relevant benefit crystallisation event is— or, if that produces a negative result, nil. In sub-paragraph (5) “the relevant time” means— For provision about the meaning of expressions used in this paragraph, see paragraph 129.

“Lump sum transitional tax-free amount”, in relation to an individual, means the total of— “Lump sum and death benefit transitional tax-free amount”, in relation to an individual, means the total of— For the purposes of sub-paragraph (2)— “Complete evidence”, in relation to an individual’s lump sum and death benefit transitional tax-free amount, means evidence of— that is comprised, or any part of which is comprised, in the individual’s lump sum and death benefit transitional tax-free amount. “Lifetime allowance previously-used amount”, in relation to an individual, means (subject to sub-paragraphs (4B) and (4C)) the amount that would have been the previously used amount for the purposes of section 219 of FA 2004 (availability of individual’s lifetime allowance) if a benefit crystallisation event (within the meaning of that section) had occurred in relation to the individual immediately before 6 April 2024. Sub-paragraph (4C) applies where— The amount determined under sub-paragraph (4A) is to be reduced (but not below zero) by the amount given by the following formula— where— “A” is the amount or (if more than one) the sum of the amounts mentioned in sub-paragraph (4B)(b); “B” is the individual’s lifetime allowance at the time the individual reached the age of 75. In paragraphs 125 to 128 and this paragraph— A reference in any of paragraphs 125 to 128 or this paragraph to a provision of FA 2004 is to that provision as it had effect immediately before 6 April 2024.

A rule of a registered pension scheme relating to a member’s entitlement to , or to the payment of, a lifetime allowance excess lump sum has effect, in relation to entitlements arising on or after 6 April 2024, and so far as possible, as a rule relating to the member’s entitlement to , or to the payment of, a pension commencement excess lump sum. The amendments ... made by or under this Schedule , and the amendments made by section 14, do not affect the interpretation of any relevant rule of a registered pension scheme. For the purposes of sub-paragraph (2), a rule of a registered pension scheme is “relevant” if the rule imposes a limit on the amount of a benefit payable under the scheme to, or in respect of, a member by reference to the member’s lifetime allowance, the standard lifetime allowance or the lifetime allowance charge. In this paragraph “member”, “lifetime allowance”, “standard lifetime allowance” and “lifetime allowance charge” have the same meaning as in Part 4 of FA 2004 as that Part had effect immediately before 6 April 2024. This paragraph ceases to have effect at the end of the tax year 2028-29.

In Part 2 of ITTOIA 2005—

In section 42(7)(e) of TMA 1970 (procedure for making claims etc), for “25A” substitute “25C”.

This paragraph applies for the purposes of section 95A of FA 1986 (depositary receipts: exception for replacement securities) where the securities mentioned in subsection (3)(a) of that section were issued before 1 January 2024. The amendments made by paragraphs 7 and 10 are to be disregarded.

This paragraph applies in relation to securities constituted by or transferable by means of an instrument issued before 1 January 2024. The amendments made by paragraph 23 are to be disregarded.

In section 122 (chargeable persons)— After section 232, insert— In section 259 (other definitions), in subsection (1) at the appropriate place insert— After section 268 insert— In section 269 (chargeable persons for domestic top-up tax)— In Schedule 14 (administration of multinational top-up tax)— general partner (in Schedule 14) paragraph 3(3) of Schedule 14 limited partnership (in Schedule 14) paragraph 3(3) of Schedule 14 partnership section 259(1);

Schedule 18 to FA 1998 (company tax returns etc) is amended as follows. In paragraph 10 (certain claims and elections to be included in tax return), omit sub-paragraphs (5) to (7). In paragraph 52 (recovery of excessive payments), in sub-paragraph (2B) (inserted by Schedule 6), omit paragraphs (b) to (d). In paragraph 83S (application of Part 9D), omit sub-paragraphs (a) to (c).

In paragraph 2 of Schedule 54A to FA 2009 (amounts of overpaid repayment interest recoverable as late payment interest), omit paragraphs (e) to (g).

Sub-paragraphs (2) to (5) apply if— The separate trade that the company is treated as carrying on in AP2 is to be treated as a continuation of the separate trade that the company was treated as carrying on in AP1. Accordingly, section 1179BA(2) of CTA 2009 does not apply. If a new period of account does not begin when AP2 begins, a new period of account is to be treated as beginning at that time for the purposes of— For the purposes of section 1179BB(3) of CTA 2009 as it applies in relation to AP2, the references to the corresponding amounts for the previous period are to be read as references to the corresponding amounts brought into account under section 1189, 1216BA or 1217BA of that Act for AP1.

The repeal of Parts 15 and 15A of CTA 2009 does not affect the requirement in section 1214(3) or 1216EB(3) of that Act, so far as it relates to entitlements in accounting periods beginning before 1 April 2027 (even if the “completion period” begins on or after that date).

In Chapter 4 of Part 9 of ITEPA 2003 (foreign pensions), section 574A (“pension”: relevant lump sums) is amended as follows. After subsection (2) insert— In subsection (3), in Step 3—

Schedule 34 to FA 2004 (non-UK schemes: application of certain charges) is amended as follows. In the heading, at the end insert “and protections etc”. After paragraph 12 (application of annual allowance provisions) insert—

In section 267— In consequence of the amendments made by sub-paragraph (1), in section 266(1) (qualifying entities) omit “or an investment entity”. In section 272 (determining top-up amounts of entity that is a member of a group)—

After section 273B (as inserted by paragraph 45) insert—

In section 132(2) (effective tax rate), in the words after paragraph (c) for “164” substitute “174”.

In section 194 (total top-up amount for a territory), in subsection (3), for “in”, in the third place it occurs, substitute “for”. In section 196 (eligible payroll costs), in subsection (3), for ““Employee”” substitute “In this section “employee””. In section 197 (eligible tangible asset amount)—

In section 220(3) (top-up amount of investment entity) for “section 33(2)” substitute “that Chapter”. In section 221(4) (substance based income exclusion for investment entity), for “Schedule 12” substitute “Schedule 14”. In section 229(3) (multi-parent groups), for “section 127(3)” substitute “section 128(3)”.

In Schedule 14 (administration)— In Schedule 15 (elections)— In Schedule 16 (multinational top-up tax: transitional provision), in paragraph 10— In Schedule 17 (index of defined expressions), in the table—

The amendments made by paragraph 1 extend to England and Wales, Scotland and Northern Ireland. The amendments made by paragraph 2 extend to— The other provisions of CDDA 1986, except for sections 13 to 15 (consequences of contravention), extend to Northern Ireland (as well as England and Wales and Scotland) so far as relating to applications and orders made, and undertakings accepted, under section 8ZF or 8ZG.

CTA 2009 is amended as follows. In section 1040ZA (restrictions on claiming other reliefs where R&D relief given), omit subsections (1) to (3). In section 1310(4) (orders and regulations subject to affirmative procedure), omit paragraphs (a) to (ej). In Schedule 4 (index of defined expressions), omit the following entries—; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; .

In Schedule 24 to FA 2016 (tax advantages constituting the grant of state aid), in Part 1, in the table headed “Creative tax reliefs”, omit the entries for film tax relief, television tax reliefs and video games tax relief.

In section 1217GC(2) (expenditure that is not “core expenditure” on theatrical production), in paragraph (a), for “or storage” substitute “, storage, or the provision of incidental goods or services to members of the audience”. That amendment has effect in relation to expenditure incurred on or after 1 April 2024.

In section 1217J(2) and (3) (amount of relief for theatrical production), for “European” substitute “UK”. For transitional provision in relation to this paragraph, see paragraph 12.

In section 1217KB (payment in respect of theatre tax credit), after subsection (4) insert—

This paragraph makes transitional provision in relation to paragraph 6. The amendments made by that paragraph have effect in relation to accounting periods ending on or after 1 April 2024. Sub-paragraph (4) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217J of CTA 2009 (amount of relief for theatrical production). The references in subsections (2) and (3) of that section (as amended by paragraph 6) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as— But if the theatrical production in relation to which sub-paragraph (4) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that production as if “2025” were substituted for “2024”. In this paragraph— For the purposes of sub-paragraph (5), a theatrical production “enters production” when core expenditure is first incurred on it.

In section 1218ZCD(7) (expenditure that is not “core expenditure” on museum or gallery exhibition), in paragraph (a), for “and promotional events” substitute “, promotional events, and the provision of incidental goods or services to visitors”. That amendment has effect in relation to expenditure incurred on or after 1 April 2024.

Section 1218ZCG (expenditure that qualifies for museums and galleries exhibition tax relief) is amended as follows. In subsection (1), after paragraph (b) (but before the following “and”) insert—. After subsection (2) insert— Those amendments have effect in relation to expenditure incurred on or after 1 April 2024.

After section 1218ZCL insert— That amendment has effect in relation to claims made on or after 1 April 2024.

CTA 2010 is amended in accordance with paragraphs 2 to 10.

Section 528 is further amended as follows. In subsection (4A)— After subsection (4C) (as inserted by paragraph 3) insert— In subsection (5) (as amended by paragraph 3)— After subsection (5) insert— After subsection (5C) (as inserted by paragraph 3) insert— In section 528ZA, in subsection (7), for the words from “which” to the end substitute “if a person acting on behalf of it would be an institutional investor as a result of section 528(4A)(c)”. In section 528ZB— In consequence of the other amendments made by this paragraph, in Schedule 5AAA to TCGA 1992, in paragraph 46(3)(a), for “section 528(4A)(a), (b), (c), (i) or (j)” substitute “section 528(4A)(i) or (j)“.

Section 544 (meaning of “property profits” and “property financing costs”) is amended as follows. In subsection (3)(a), for “property rental business of members of the group” substitute “the group's property rental business in the United Kingdom”. After subsection (3) insert— Section 544 has effect, and is to be deemed always to have had effect, with the amendments made by sub-paragraphs (2) and (3). After subsection (4) insert— The amendment made by sub-paragraph (5) has effect for accounting periods ending on or after 1 April 2023.

In section 551 (tax consequences of distribution to holder of excessive rights), in subsection (1)(a), for “(as” substitute “that is not an excluded holder (both as”. In section 553 (meaning of “holder of excessive rights”)—

If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning before 1 January 2024— If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning on or after 1 January 2024, the relevant existing regime does not apply in relation to that accounting period or any subsequent accounting period, subject to sub-paragraphs (3) and (4). If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning on or before but ending after the relevant closure date, it may further elect in the return for sub-paragraph (4) to apply. If it does so— Where, by virtue of this paragraph, different Parts of CTA 2009 apply in respect of different portions of an accounting period, the portions are to be treated as separate accounting periods for the purposes of— For the purposes of this paragraph— Nothing in this paragraph expands the circumstances in which the relevant existing regime can apply (except by making it apply in respect of a portion of an accounting period).

Sub-paragraphs (3) and (4) apply if— In those sub-paragraphs, the earliest accounting period within sub-paragraph (1)(a) is “AP2” and the latest accounting period within sub-paragraph (1)(b) is “AP1”. For the purposes of step 1 in section 1179CA(1) of CTA 2009 as it applies in relation to AP2, the reference to relevant global expenditure includes the amount that was “qualifying expenditure incurred to date” for the purposes of section 1200(1) or (2), 1216CG(1) or (2) or 1217CG(1) or (2) of that Act in relation to AP1. For the purposes of step 4 in section 1179CA(1) of CTA 2009 as it applies in relation to AP2, the reference to the company’s qualifying expenditure to date in the accounting period for which it was last entitled to, and claimed, an expenditure credit is to be read as a reference to the amount taken as ‘E’ for the purposes of section 1200(1) or (2), 1216CG(1) or (2) or 1217CG(1) or (2) of that Act in relation to AP1.

Sub-paragraphs (3) and (4) apply if— In this paragraph, “special video games relief” and “completion period” have the meanings given by section 1217E(1) of CTA 2009. Subsections (3) and (4) of section 1217EB of CTA 2009 apply as if the video game had been completed at the end of the accounting period preceding the opt-in period (and, accordingly, as if that period were the completion period). In section 1179FH of CTA 2009 as it applies in relation to the video game, the references to core expenditure are to be read as limited to core expenditure incurred in or after the opt-in period.

This paragraph makes transitional provision in relation to paragraph 6. The amendments made by that paragraph have effect in relation to accounting periods ending on or after 1 April 2024. Sub-paragraph (4) applies in a case where expenditure incurred before 1 April 2024 is to be taken into account as qualifying expenditure for the purposes of section 1217RE of CTA 2009 (amount of relief for orchestral concert). The references in subsections (2) and (3) of that section (as amended by paragraph 6) to so much of the qualifying expenditure incurred to date as is UK expenditure are to be read as references to so much of the qualifying expenditure incurred to date as— But if the orchestral concert or concert series in relation to which sub-paragraph (4) applies has entered production before 1 April 2024, the production company may elect for that sub-paragraph to have effect in relation to that concert or series as if “2025” were substituted for “2024”. In this paragraph— For the purposes of sub-paragraph (5), an orchestral concert or concert series “enters production” when core expenditure is first incurred on it.

This paragraph makes transitional provision in relation to paragraph 4. The amendments made by that paragraph do not have effect in relation to an exhibition if— Sub-paragraph (4) applies if— The company’s entitlement to— is unaffected by a failure to meet the UK expenditure condition so far as the entitlement derives from expenditure incurred before 1 April 2025. For the purposes of sub-paragraph (4), an entitlement to a tax credit under section 1218ZCH of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1218ZCI of that Act. Sub-paragraph (7) applies in relation to an exhibition in respect of which the separate exhibition trade continues on or after 1 April 2025. The reference in section 1218ZEA(1) of CTA 2009, as amended by paragraph 4(2)(c), to a statement having been made under section 1218ZE(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition. But the application of section 1218ZEA(1) of CTA 2009 as so amended is subject to sub-paragraph (4) (where that sub-paragraph applies). In this paragraph— For the purposes of this paragraph, an exhibition “enters production” when core expenditure is first incurred on it.

Sub-paragraph (2) applies if— Step 2 Deduct from that total the sum of— so much of that expenditure as was incurred in accounting periods before the opt-in period and that is not European expenditure (within the meaning of section 1217AE), and so much of that expenditure as was incurred in the opt-in period or any later accounting period and that is not UK expenditure (see section 1179AB).

This paragraph makes transitional provision in relation to paragraph 5. The amendments made by that paragraph do not apply in relation to an orchestral concert or concert series if— Sub-paragraph (4) applies if— The company’s entitlement to— is unaffected by a failure to meet the UK expenditure condition so far as the entitlement derives from expenditure incurred before 1 April 2025. For the purposes of sub-paragraph (4), an entitlement to a tax credit under section 1217RG of CTA 2009 derives from expenditure incurred before 1 April 2025 to the extent that it would arise if only costs incurred and income received before that date were taken into account in calculating the surrenderable loss of the company for the purposes of section 1217RH of that Act. Sub-paragraph (7) applies in relation to an orchestral concert or concert series in respect of which the separate orchestral trade continues on or after 1 April 2025. The reference in section 1217TA(1) of CTA 2009, as amended by paragraph 5(2)(c), to a statement having been made under section 1217T(2) of that Act includes reference to a statement having been made under that provision in relation to the European expenditure condition. But the application of section 1217TA(1) of CTA 2009 as so amended is subject to sub-paragraph (4) (where that sub-paragraph applies). In this paragraph— For the purposes of this paragraph, an orchestral concert or concert series “enters production” when core expenditure is first incurred on it.

Part 9 of ITEPA 2003 (pension income) is amended as follows.

The amendments made by section 14 and this Schedule have effect for the tax year 2024-25 and subsequent tax years.

A “transitional tax-free amount certificate” is a certificate relating to an individual that— An application for a certificate in relation to an individual— The certification administrator to whom an application is made must, before the end of the period of three months beginning with the date on which the the application is received, determine the application by— A certificate must (in addition to certifying the matter mentioned in sub-paragraph (1)(b)) contain the following information— A certificate may be in such form as the certification administrator may determine and may, in particular, be incorporated into any other document that is given to the applicant by the certification administrator. If at any time it appears to a person who is a certification administrator in relation to the individual that the amount specified on a certificate under sub-paragraph (4)(c) or (d) does not accurately reflect the individual’s lump sum transitional tax-free amount or (as the case may be) lump sum and death benefit transitional tax-free amount, they must cancel the certificate by giving notice of the cancellation to the applicant or, if the applicant is deceased, the applicant’s personal representatives. A certificate— The Commissioners for His Majesty’s Revenue and Customs may by regulations— For provision about the meaning of expressions used in this paragraph, see paragraph 129. Paragraph 127 of Schedule 9 to the Finance Act 2024

The scheme administrator of a registered pension scheme must provide a statement to each relevant person before the end of the tax year 2024-25. In sub-paragraph (1) “relevant person” means— The statement must contain the information in regulation 14(3) of the Provision of Information Regulations (percentage of standard lifetime allowance expended by benefit crystallisation events) in respect of benefit crystallisation events occurring before 6 April 2024. In this paragraph—

The Treasury may make transitional, transitory or saving provision (in addition to that contained in paragraphs 126 to 132) in connection with the coming into force of any amendment made by section 14 or this Schedule. Regulations under this paragraph may—

Chapter 3 of Part 2 of ITTOIA 2005 (trade profits: basic rules) is amended as follows.

In section 41(9)(a) of TCGA 1992 (restriction of losses by reference to capital allowances and renewals allowances), for the words from “calculating”, in the second place it occurs, to “effect” substitute “be construed in accordance with Part 2 of ITTOIA 2005 (see section 24A of that Act)”.

Section 90 (section 87: other exceptions) is amended as follows. In subsection (3C)— In subsection (3E) omit paragraph (b). In subsection (4)—

Chapter 15A—

Before section 24 insert the following italic heading—.

In the italic heading before section 93 (SDRT: depositary receipts), at the end insert “: depositary receipts”. In section 93—

Section 566 (nature of charge to tax on pension income and relevant definitions) is amended as follows. In subsection (3), for “16” substitute “15A”. In the table in subsection (4)—

Before section 25C (inserted by paragraph 5 of this Schedule) insert —

In section 94 (depositary receipts: supplementary), in subsection (1), in the words before paragraph (a), for “section 93 above” substitute “sections 93 and 97AC”.

For Chapter 15A substitute—

Before section 27 insert the following italic heading—.

In section 95 (depositary receipts: exceptions)—

Before section 30 insert the following italic heading—.

In section 95A (depositary receipts: exception for replacement securities)—

Before section 31 insert the following italic heading—.

Before section 96 (SDRT: clearance services) insert—. In section 96—

Section 97 (clearance services: exceptions) is amended as follows. In subsection (1), in the words after paragraph (b) omit “subject to section 97C,”. In subsection (3), in the words before paragraph (a) omit “or issue”. Omit subsections (4) to (6).

Section 97AA (clearance services: further exception) is renumbered section 97ZA. In that section—

Section 97A (clearance services: election for alternative system of charge) is amended as follows. In subsection (3), in paragraph (a) omit “or issue”. In subsection (4), in both places omit “, issue”.

After section 97A insert—

In section 97B (transfer between depositary receipt system and clearance system) omit subsection (1A).

Omit section 97C (transfers to non-EU depositary receipt and clearance services systems).

The Registered Pension Schemes (Authorised Payments) Regulations 2009 (S.I. 2009/1171) are amended as follows. Omit regulation 3A (which relates to payments made before 6 April 2015 and is therefore no longer of practical utility). In regulation 7 (meaning of “relevant accretion”) omit paragraphs (3) and (3A). In regulation 16 (payments of arrears of pension after death) omit paragraphs (5) and (6). In regulation 17 (pension commencement lump sums based on pension errors) omit paragraphs (4) and (5). In regulation 18 (pension commencement lump sums paid in error: money purchase arrangements) omit paragraphs (4) and (5). In regulation 19 (pension commencement lump sums paid after death) omit paragraphs (2) and (3). In regulation 20 (part refund payments relating to short service), in paragraph (1) for sub-paragraph (b) substitute—.

In Schedule 18 to FA 2011 (lifetime allowance charge), in Part 2 (commencement and transitional provision), paragraph 14 (fixed protection) is amended as follows. In sub-paragraph (1)(b), for “make provision for a lifetime allowance enhancement factor” substitute “apply on that date”. In sub-paragraph (1A)(b), for “make provision for a lifetime allowance enhancement factor” substitute “apply on that date”. Chapter 15A of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) has effect in relation to the individual as if—

Schedule 4 to FA 2016 (pensions: lifetime allowance: transitional provision) is amended as follows is amended as follows. In the heading, for “lifetime allowance” substitute “lump sum allowance and lump sum and death benefit allowance”. In Part 1 (“fixed protection 2016”)— In Part 2 (“individual protection 2016”), in paragraph 9 (the protection)— In Part 3 (reference numbers etc), in paragraph 14 (issuing of reference numbers for fixed or individual protection 2016), in sub-paragraph (3)(b), at the end insert “but before 6 April 2025”.

The Registered Pension Schemes (Lifetime Allowance Transitional Protection) Regulations 2011 (S.I. 2011/1752) are amended as follows. In the title, for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 1 (citation and commencement), for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 4 (the paragraph 14 notice), in paragraph (1)(c), for “make provision for a lifetime allowance enhancement factor” substitute “apply”. In regulation 13 (preservation of documents), in paragraph (1), for “benefit crystallisation event” substitute “relevant benefit crystallisation event within the meaning of section 637S of ITEPA 2003”.

In consequence of the repeals made by this Schedule, omit the following provisions (which insert or amend provisions repealed by this Schedule)—

This paragraph has effect for the purposes of construing references in the Income Tax Acts to the cash basis in relation to the calculation of the profits of a trade (but not a property business) for a tax year before 2024-25. Any reference to calculating the profits of a trade on the cash basis is to be read as a reference to doing so in accordance with section 25A of ITTOIA 2005. Any reference to the cash basis applying (or not applying) in relation to a trade for the tax year is to be read as a reference to an election under section 25A of ITTOIA 2005 having effect (or not having effect) in relation to the trade for the tax year.

Section 128 (responsible members) is amended as follows. In subsection (3), for paragraph (c) substitute— In subsection (4), after “for” insert —. In subsection (5), for paragraph (b) substitute— In subsection (6), after “for” insert —. In section 232, after subsection (3) insert—

For section 147 (accrued pension expense) substitute—

Section 152 is amended as follows. In subsection (2), for “formed part of the member’s tax expense amount” substitute “been included in the member’s covered tax balance”. For subsection (4) substitute—

Section 163 (election to spread capital gains over five years) is amended as follows. In subsection (1), for “collectively” substitute “and those preceding periods are referred to collectively as”. In subsection (2)— In subsection (3), omit “standard”.

After section 176C (as inserted by paragraph 8), insert— In Schedule 15 (elections), in paragraph 2(1), before paragraph (a) insert—.

Section 180 (blended CFC regimes) is amended as follows. In subsection (5)(a), after “C” insert “in relation to the CFC entity”. In subsection (7)— In subsection (8)(b) for sub-paragraph (ii) substitute—.

In section 196, in subsection (1)— In section 197, in subsection (5)—

In section 195 (calculation of substance based income exclusion), after subsection (7) insert— After section 197 insert—

In section 213 (investment entity tax transparency election), after subsection (6) insert—

Section 236 (investment funds and investment entities) is amended as follows. In subsection (2)— After that subsection insert—

In section 255 (meaning of Pillar Two rules)— In paragraph 2 of Schedule 16 (intra-group transfers before entry into regime)— In paragraph 3 of that Schedule—

Schedule 14 is amended as follows. In paragraph 51 (claims in relation to overpaid tax)— After paragraph 33 insert—

In Schedule 16 (transitional provision), at the end insert— In Schedule 15 (elections), in paragraph 2(1), after paragraph (j) insert—.

This paragraph has effect for the purposes of construing references in the Income Tax Acts to a change in the basis of calculation of the profits of a trade (but not a property business) for the tax year 2024-25. A person carrying on a trade “enters the cash basis” in relation to the trade in the tax year 2024-25 if— and related expressions are to be construed accordingly. A person carrying on a trade “leaves the cash basis” in relation to the trade in the tax year 2024-25 if— and related expressions are to be construed accordingly. For the purposes of this paragraph, the cash basis applies to a trade in relation to a tax year if the profits of the trade for the tax year are required by virtue of section 24A(1) of ITTOIA 2005 to be calculated in accordance with that section.

Paragraphs 48 and 49 apply to professions and vocations as they apply to trades.

Part 4 of FA 2004 (pension schemes etc) is amended as follows.

Part 2 of Schedule 36 to FA 2004 (transitional provision and saving: pre-commencement rights: lifetime allowance charge) is amended as follows.

In CDDA 1986, after section 8ZE insert—

The procedural rules for applications under section 8 of CDDA 1986 apply to HMRC disqualification applications as they apply to applications by the Secretary of State, subject to any necessary modifications. The procedural rules for applications under Article 11 of the Company Directors Disqualification (Northern Ireland) Order 2002 (S.I. 2002/3150 (N.I. 4)) apply to HMRC disqualification applications as they apply to applications by the Department for the Economy in Northern Ireland, subject to any necessary modifications. Sub-paragraphs (1) and (2) apply only if, and to the extent that, there are not otherwise procedural rules for HMRC disqualification applications. In this paragraph—

In section 244 (non-UK schemes: application of certain charges), after “under this Part” insert “, and under Part 9 of ITEPA 2003 (pension income),”.

In the heading, for “lifetime allowance charge” substitute “enhancement of allowances etc”.

For section 244A (overseas transfer charge) substitute—

Before paragraph 7 and the italic heading before it insert—

Section 244B (exclusion: member and receiving scheme in same country) is amended as follows. In subsection (1)— In subsection (3), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”.

For paragraph 7 (primary protection) substitute—

Section 244C (exclusion: receiving scheme in EEA state or Gibraltar, and member resident in UK or EEA state) is amended as follows. In subsection (2)— In subsection (3), in the words before paragraph (a), after “recognised transfer” insert “or relieved relevant non-UK scheme transfer”. In subsection (4), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”.

Paragraph 11 (primary protection: pension debit on or after 6th April 2006) is amended as follows. In sub-paragraph (1)(a), for “makes provision for the operation of a lifetime allowance enhancement factor” substitute “applies”. In sub-paragraphs (2) and (3), for “paragraph 7(3)” substitute “paragraph 7(5)”. In sub-paragraph (4), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. In this paragraph “relevant benefit crystallisation event” has the same meaning as in section 637S of ITEPA 2003 (availability of individual’s lump sum and death benefit allowance).

In section 244D (exclusion: receiving scheme is an occupational pension scheme), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”.

Paragraph 11A (primary protection: pension debit on or after 6th April 2006: lump sum death benefits) is amended as follows. In sub-paragraph (1)(a), for “makes provision for the operation of a lifetime allowance enhancement factor” substitute “applies”. In paragraphs (a) and (b) of sub-paragraph (4), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. In this paragraph “relevant benefit crystallisation event” has the same meaning as in section 637S of ITEPA 2003 (availability of individual’s lump sum and death benefit allowance).

In section 244E (exclusion: receiving scheme set up by international organisation), in subsection (1), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”.

Paragraph 12 (enhanced protection) is amended as follows. Where this paragraph applies in the case of an individual, Chapter 15A of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) and Part 4 of FA 2004 (pensions etc) have effect in relation to the individual with the modifications in sub-paragraphs (3B) to (3F). For the purposes of determining the income tax treatment of a lump sum or a lump sum death benefit— For the purposes of the modifications made by sub-paragraph (3B), the maximum amount of a serious ill-health lump sum or a lump sum death benefit that could have been paid in respect of an individual on 5 April 2024 under an arrangement that is a defined benefits arrangement is an amount equal to the appropriate limit, determined under paragraph 15(4), in relation to payment of the serious ill-health lump sum or the lump sum death benefit. For the purposes of the modifications made by sub-paragraph (3B) “authorised lump sum death benefit” means a lump sum death benefit authorised to be paid by the lump sum death benefit rule. Section 637P of ITEPA 2003 (individual’s lump sum allowance) applies as if the amount specified in that section were £375,000. Section 637R of ITEPA 2003 (individual’s lump sum and death benefit allowance) applies as if the amount specified in that section were an amount equal to the value of the individual’s uncrystallised pension rights on 5 April 2024. The Commissioners for His Majesty’s Revenue and Customs may by regulations make provision about how the value of the individual’s uncrystallised pension rights on 5 April 2024 is to be determined for the purposes of sub-paragraph (3F). Where this paragraph applies in the case of an individual, for the purposes of this Part a lump sum is not an uncrystallised funds pension lump sum (see paragraph 4A of Schedule 29) if the lump sum condition (see paragraphs 24(2) and (3), 25 and 26 of this Schedule) is met in relation to the individual.

In section 244F (exclusion: receiving scheme is an overseas public service scheme), in subsection (1), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”.

In paragraph 13 (enhanced protection: relevant benefit accrual), in sub-paragraph (b), for “a benefit crystallisation event or” substitute “the individual becomes entitled to any pension or lump sum or a”.

Section 244G (exclusions: avoidance of double charge, and transitional protections) is amended as follows. In subsection (2), in the words before paragraph (a), after “overseas transfer charge” insert “under section 244AC”. In subsection (3), after “overseas transfer charge” insert “under section 244AC”. After subsection (4) insert—

Paragraph 15 (enhanced protection: relevant benefit accrual: interpretation) is amended as follows. In sub-paragraph (2), in the words before paragraph (a)— In sub-paragraph (2) “relevant permitted transfer” means a permitted transfer that is not a transfer of sums or assets held for the purposes of, or representing accrued rights under, any of the relevant pension schemes so as to become held for the purposes of, or to represent rights under, a qualifying recognised overseas pension scheme in connection with the individual’s membership of that pension scheme.

In section 244H (power to provide for further exclusions)—

In paragraph 16 (post-commencement earnings limit), in subsection (3), for the words from “7.5%” to the end substitute “£135,000.”

In section 244I (circumstances in which exclusions do not apply), in subsection (1)—

For paragraph 18 (pre-commencement pension credits) substitute—

After section 244I insert—

Paragraph 19 (individuals permitted to take pension before normal minimum pension age) is amended as follows. In sub-paragraph (1), in the words before paragraph (a), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. Chapter 15A of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) has effect in relation to the individual with the modifications in sub-paragraphs (1B) and (2). Where the relevant benefit crystallisation event is the individual becoming entitled to a pension commencement lump sum, section 637P of ITEPA 2003 (individual’s lump sum allowance) applies as if the amount specified in that section were £268,275 reduced by the relevant percentage (see sub-paragraph (4). Where the event is a relevant benefit crystallisation event, section 637R of ITEPA 2003 (individual’s lump sum and death benefit allowance) applies as if the amount specified in that section were the amount determined under sub-paragraph (2A) reduced by the relevant percentage (see sub-paragraph (4). That amount is— In sub-paragraphs (3) and (4), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. Omit sub-paragraphs (5) and (6). In this paragraph “relevant benefit crystallisation event” has the same meaning as in section 637S of ITEPA 2003 (availability of individual’s lump sum and death benefit allowance).

Section 244J (persons liable to charge) is amended as follows. After subsection (1) insert— In subsection (4), in the words before paragraph (a), for “transfer” substitute “recognised transfer to a QROPS or an onward transfer”.

Paragraph 20 (pre-commencement pensions) is amended as follows. In sub-paragraph (1)— Section 637Q of ITEPA 2003 (availability of individual’s lump sum allowance) applies as if, immediately before the first relevant benefit crystallisation event occurring in relation to the individual on or after 6th April 2024— In sub-paragraph (2)—

After section 244J insert—

After paragraph 20 insert—

Section 244K (amount of charge) is amended as follows. For the heading substitute “Meaning of “transferred value””. For subsection (1) substitute— In subsection (2), in the words after paragraph (b), for “(5)” substitute “(6)”. In subsection (3), in the words after paragraph (b), for “(5)” substitute “(6)”. After subsection (3) insert— In subsection (4), in the words after paragraph (b), for “(5)” substitute “(6)”. Omit subsections (5) and (10).

In section 244M (repayments of charge on subsequent excluding events), in subsection (1), in paragraph (a), for “overseas transfer charge” substitute “the overseas transfer charge under section 244AC”.

Schedule 33 (overseas pension schemes: migrant member relief) is amended as follows. In paragraph 4 (meaning of “relevant migrant member”)— In paragraph 5 (meaning of “qualifying” overseas pension scheme)—

Schedule 34 (non-UK schemes: application of certain charges) is amended as follows. In paragraph 1 (member payment charges)— After paragraph 5 insert— Omit paragraphs 13 to 19 (lifetime allowance charge).

In Schedule 29 to FA 2004 (registered pension schemes: authorised lump sums: supplementary), paragraph 4A (uncrystallised funds pension lump sum) is amended as follows. In sub-paragraph (1)— Omit sub-paragraphs (3) to (6). For further provision about circumstances in which a lump sum is not an uncrystallised funds pension lump sum, see the following provisions of Part 2 of Schedule 36 (transitional provision and saving: pre-commencement rights: enhancement of allowances)—

In Chapter 3A of Part 2 of ITTOIA 2005 (trade profits: cash basis) omit—

Part 3 of Schedule 36 to FA 2004 (transitional provision and saving: pre-commencement benefit rights) is amended as follows.

In Schedule 22 to FA 2013 (transitional provision relating to reduction in standard lifetime allowance etc), in Part 1 (“fixed protection 2014”), paragraph 1 is amended as follows. In sub-paragraph (1)(b), for “make provision for a lifetime allowance enhancement factor” substitute “apply on that date”. Chapter 15A of Part 9 of ITEPA 2003 (pension income: lump sums under registered pension schemes) has effect in relation to the individual as if—

The Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006 (S.I. 2006/131) are amended as follows. In the title, for “Lifetime Allowance” substitute “Allowances”. In regulation 1 (citation and commencement), for “Lifetime Allowance” substitute “Allowances”. In regulation 2(1) (interpretation)— In regulation 3 (reliance on paragraph 7 of Schedule 36 (lifetime allowance enhancement: “primary protection”)), in the heading, for “lifetime allowance enhancement” substitute “enhancement of allowances”. In regulation 3A (reliance on paragraph 11A of Schedule 36 (lifetime allowance enhancement: “primary protection”: taking account of death benefit))— In regulation 4 (reliance on paragraph 12 of Schedule 36 (lifetime allowances: “enhanced protection”)), in the heading, for “lifetime allowances” substitute “enhancement of allowances”. In regulation 4A (reliance on paragraph 15A of Schedule 36 (lifetime allowances: “enhanced protection”: taking account of death benefit))— In regulation 5 (reliance on paragraph 18 of Schedule 36 (lifetime allowance enhancement: pre-commencement pension credits)— In regulation 6 (reliance on section 220 (lifetime allowance enhancement: registration of pension credits))— In regulation 7 (reliance on section 221 (lifetime allowance enhancement: relevant overseas individuals))— In regulation 8 (reliance on section 224 (lifetime allowance enhancement: transfer from recognised overseas pension scheme))— In regulation 15 (certificates: general), in paragraph (3), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”.

The Registered Pension Schemes and Relieved Non-UK Pension Schemes (Lifetime Allowance Transitional Protection) (Notification) Regulations 2013 (S.I. 2013/1741) are amended as follows. In the title, for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 1 (citation and commencement), for “Lifetime Allowance” substitute “Enhanced Allowances”. In regulation 4 (the paragraph 1 notice), in paragraph (1)— In regulation 13 (preservation of documents), in paragraph (1), for “benefit crystallisation event” substitute “relevant benefit crystallisation event within the meaning of section 637S of ITEPA 2003”.

Omit paragraph 23A (pre-commencement benefit rights: lump sums before normal minimum pension age) and the italic heading before it.

In paragraph 24 (pre-commencement benefit rights: lump sum rights exceeding £375,000: primary and enhanced protection), sub-paragraph (1) is amended as follows. In paragraph (a), after “Schedule 29” insert “and paragraph 12 of this Schedule”. For paragraph (b) substitute—.

For paragraph 27 (pre-commencement benefit rights: enhanced protection: permitted maximum) substitute—

Paragraph 28 (pre-commencement benefit rights: no enhanced protection: permitted maximum) is amended as follows. In sub-paragraph (1) omit “paragraph 2 of”. In sub-paragraph (2), after “paragraph 2” insert “of Schedule 29”. Otherwise, for paragraph 2 of Schedule 29 substitute—

For paragraph 29 (pre-commencement benefit rights: enhanced protection: applicable amount) substitute—

After paragraph 29 (substituted by paragraph 84) insert—

Omit paragraph 30 (pre-commencement benefit rights: exemption for pension commencement lump sum exceeding permitted maximum from being scheme chargeable).

For paragraph 34 (pre-commencement benefit rights: application of Schedule 29 to FA 2004 where paragraph 31 applies) substitute—

Omit paragraph 35 (pre-commencement benefit rights: winding-up lump sums paid by former approved superannuation funds) and the italic heading before it.

The Registered Pension Schemes (Provision of Information) Regulations 2006 (S.I. 2006/567) are amended as follows.

In regulation 2 (interpretation), in paragraph (1)—

In regulation 3 (provision of information by scheme administrator to the Commissioners for His Majesty’s Revenue and Customs), in paragraph (1), the Table is amended as follows. Omit the entries for the following reportable events— 24 Payment of lump sum or lump sum death benefit in relation to relevant benefit crystallisation event In relation to a relevant benefit crystallisation event, the scheme pays— a lump sum to the member of the scheme in relation to whom the relevant benefit crystallisation event occurs, or a lump sum death benefit to a person in respect of the death of that member. The information is— the member’s name and national insurance number, the nature and amount of the lump sum or lump sum death benefit giving rise to the relevant benefit crystallisation event, the date of the relevant benefit crystallisation event, confirmation of whether or not the payment of the lump sum or lump sum death benefit has resulted in the member’s lump sum allowance or lump sum and death benefit allowance being exceeded, so far as the payment of the lump sum or lump sum death benefit has resulted in the member’s lump sum allowance or lump sum and death benefit allowance being exceeded, confirmation that any amount of tax due on the excess as a result of the charge to tax on pension income under Part 9 of ITEPA 2003 has been paid, and each relevant reference number (if any).

Regulation 7 (percentage of standard lifetime allowance expended on the happening of a benefit crystallisation event) is amended as follows. For the heading substitute “Relevant benefit crystallisation events: amount of member’s allowances expended”. For paragraphs (1) and (2) substitute— In paragraph (3)(a) omit “, (2A), (2B)”. For paragraph (4) substitute— After paragraph (4) insert—

Regulation 8 (death: provision of information by scheme administrator to personal representatives) is amended as follows. In paragraph (1) omit “, (2A), (2B)”. In paragraph (2)— Omit paragraphs (2A) and (2B). In paragraph (3)—

Regulation 9 (death: provision of information by insurance company to personal representatives) is amended as follows. In paragraph (2)—

Regulation 10 (death: provision of information by personal representatives to the Commissioners for His Majesty’s Revenue and Customs) is amended as follows. In paragraph (1), in sub-paragraph (b)— Omit paragraphs (1A) and (1B). In paragraph (2)— Omit paragraphs (2A) and (2B). In paragraphs (3) and (5) omit “, (1A) or (1B)”.

Regulation 11 (information provided by member to scheme administrator: protections) is amended as follows. In the heading, for “enhanced lifetime allowance” substitute “enhanced allowances”. In paragraph (1)— After paragraph (1) insert— In paragraph (2)(a), for “Lifetime Allowance” substitute “Enhanced Allowances”.

Omit regulation 11B (information provided by members to scheme administrators: pension commencement lump sums).

In regulation 11BA (information provided by members to scheme administrators: recognised transfers), in paragraph (2), after paragraph (ac) insert—

In regulation 11BB (information provided by members to scheme administrators: overseas transfers), in paragraph (1)(b)—

Omit regulation 12 (information about scheme administrator’s liability for a lifetime allowance charge).

Regulation 12A (provision of information about liability for overseas transfer charge) is amended as follows. In the heading, at the end insert “etc”. In paragraph (1)— In paragraph (2)— In paragraph (3), in the words before sub-paragraph (a), for “overseas transfer charge” substitute “an overseas transfer charge under section 244AC”.

Regulation 14 (information provided to members by scheme administrators about benefit crystallisation events) is amended as follows. In the heading, for “benefit crystallisation events” substitute “relevant benefit crystallisation events”. In paragraph (1)(b), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”. In paragraph (2)(c) omit “(2A) or (2B)”. In paragraph (3)—

In regulation 14ZCA (further information provided by scheme administrators on recognised transfers to overseas schemes), in paragraph (2)—

Regulation 15 (information between scheme administrators) is amended as follows. In paragraph (2)—

Regulation 16 (pensions and annuities in payment: information provided to and by insurance companies) is amended as follows. In paragraph (2), for “total percentage of standard lifetime allowance” substitute “total amount of the member’s lump sum allowance, and the total amount of the member’s lump sum and death benefit allowance,”. In paragraph (3), for “percentage of the standard lifetime allowance” substitute “total amount of the member’s lump sum allowance, and the total amount of the member’s lump sum and death benefit allowance,”. In paragraph (4)(a), for “benefit crystallisation event” substitute “relevant benefit crystallisation event”.

Regulation 17 (payments to insurance companies from drawdown pension funds) is amended as follows. In paragraph (2), for “percentage of standard lifetime allowance” substitute “amount of the member’s lump sum allowance, and the amount of the member’s lump sum and death benefit allowance,”. In paragraph (3)— In paragraph (5)— In paragraph (7)—

Omit regulations 19 (lump sums to which paragraph 1B of Schedule 29 applies) and 20 (lump sums to which paragraph 1B of Schedule 29 fails to apply).

This paragraph applies where— Where the individual’s ... lifetime allowance previously-used amount is equal to or greater than the individual’s lifetime allowance, none of the individual’s overseas transfer allowance is available on the making of the transfer. Otherwise, the amount of the individual’s overseas transfer allowance that is available on the making of the transfer is— or, if that produces a negative result, nil. Sub-paragraph (5) applies where the individual’s lifetime allowance previously-used amount includes one or more amounts (“crystallised drawdown amounts”) that are attributable to the occurrence, before 6 April 2024, of benefit crystallisation event 1 (designation of money purchase funds for drawdown). The individual’s lifetime allowance previously-used amount is to be reduced for the purposes of sub-paragraphs (2) and (3) (but not below zero) by— The formula is— where— “A” is the crystallised drawdown amount in question; “B” is the individual’s lifetime allowance on the occurrence of the benefit crystallisation event to which the crystallised drawdown amount in question is attributable.

Sub-paragraph (2) applies where— The relevant person must send a copy of the certificate to each certification administrator within sub-paragraph (1)(b). Sub-paragraph (2) must be complied with— In the case of an obligation under sub-paragraph (2) relating to a pension scheme of which the individual is a member as a result of a block transfer, references in sub-paragraph (3) to the day on which the relevant person receives the certificate are to the later of that day and the day on which the relevant person receives notice of the block transfer. Sub-paragraph (6) applies where— The relevant person must send a copy of the notice to each certification administrator within sub-paragraph (5)(b). Sub-paragraph (6) must be complied with— In the case of an obligation under sub-paragraph (6) relating to a pension scheme of which the individual is a member as a result of a block transfer, references in sub-paragraph (7) to the day on which the relevant person receives notice of the cancellation are to the later of that day and the day on which the relevant person receives notice of the block transfer. Sub-paragraph (8B) applies where— The relevant person must send a copy of the certificate to the scheme administrator of the new pension scheme. Sub-paragraph (8B) must be complied with— In this paragraph—

The amendments made by or under this Schedule, and the amendments made by section 14, are to be disregarded for the purposes of determining— In this paragraph “transitional lump sum” means a lump sum to which a member of a registered pension scheme becomes entitled before 6 April 2024 and which is paid on or after that date. In sub-paragraph (2) “member” has the same meaning as in Part 4 of FA 2004.

This paragraph applies where any provision of or made under this Schedule re-enacts (with or without modification) a provision of the pensions tax code that is repealed by or under this Schedule. The repeal and re-enactment does not affect the continuity of the law. Anything done (including any subordinate legislation made) or having effect as if done, under or for the purposes of the repealed provision that could have been done under or for the purposes of the corresponding provision of the pensions tax code, if in force or effective immediately before the commencement of that corresponding provision, has effect thereafter as if done under or for the purposes of that corresponding provision. Any reference (express or implied) in any enactment, instrument or document to a provision of the pensions tax code shall be construed (so far as the context permits) as including, as respects times, circumstances or purposes in relation to which the corresponding repealed provision had effect, a reference to that corresponding provision. Any reference (express or implied) in any enactment, instrument or document to a repealed provision shall be construed (so far as the context permits) as respects times, circumstances or purposes in relation to which the corresponding provision of the pensions tax code has effect, as being or (according to the context) including a reference to that corresponding provision. This paragraph has effect subject to any specific transitional provision or saving contained in or made under this Schedule. In this paragraph a reference to an enactment being repealed includes its being substituted or revoked. In this paragraph “pensions tax code” means—

In section 127 (excluded entities), in subsection (5)—

In section 146 (adjustment for changes in accounting policies and prior period errors), in paragraph (b), for the words from “correction”, in the second place it occurs, to the end substitute “error results in a recalculation under section 217(5) (post filing adjustments of covered taxes)”.

Section 151 (adjustments for companies in distress) is amended as follows. In subsection (1)— In subsection (6)(c) for “deferred tax assets” substitute “local tax attributes”. After subsection (6) insert— For subsection (7) substitute— After that subsection insert—

Section 159 (permanent establishment income and expense attribution) is amended as follows. In subsection (1), for the words from “only” to the end substitute “— In subsection (2), for the words from “only” to the end substitute — In subsection (3), for the words from “only” to the end substitute — After that subsection insert—

In section 173 (covered taxes), in subsection (1)(c) for “of the member” substitute “in which the tax is imposed”.

Section 179 (controlled foreign company tax regimes) is amended as follows. In subsection (1), in paragraph (b), for “controlled foreign company” substitute “CFC entity”. In subsection (4), after the definition of “controlled foreign company tax regime” insert—. In section 180 (blended CFC regimes)— CFC entity section 179(4)

In section 196 (eligible payroll costs)— In section 197 (eligible tangible asset amounts) after subsection (6) insert—

In section 197, after subsection (7) insert—

In section 211 (transfer of assets or liabilities to a member of a multinational group)—

In section 227 (application of Part to joint venture groups), in subsection (2) for “the multinational group” substitute “each multinational group”.

For section 254 (use of currency) substitute— Step 4 Convert the result of Step 3 (which in accordance with section 254 will be expressed in the CFS currency) to sterling using the average exchange rate for the accounting period (if the CFS currency is not sterling).

In section 262 (power to amend to ensure consistency with Pillar Two) after subsection (1) insert—

Part 2 of Schedule 16 (transitional safe harbour) is amended as follows. The filing member of a multinational group may make a transitional safe harbour election for an accounting period in respect of a territory. The effect of the election is that all of the standard members of the group located in the territory are to be treated as not having top-up amounts or additional top-up amounts for the purpose of determining the liability of any member of the group to multinational top-up tax. In paragraph 4— In paragraph 6(6), for “if” substitute “unless”.