Finance Act 2026

• (ii) the amount of reduction given by reducing by 5% the next £100,000 of that total,

• (c) that the amounts produced by this are added together and the resulting amount is lowered by £5,000 (but not below nil),

• (d) that this lowered amount is the settlement amount, unless it is more than £70,000 lower than P’s loan charge gross liability, and

• (e) that, if that lowered amount is more than £70,000 lower than P’s loan charge gross liability, the settlement amount is instead P’s loan charge gross liability minus £70,000.

• (7) In this section—

• “loan charge amount” means an amount which—arises in connection with a Schedule 11 or 12 to F(No. 2)A 2017 loan or quasi-loan,is not an amount of inheritance tax,is payable, or becomes payable in the future, to the Commissioners under or by virtue of any enactment or under a contract settlement, andhas not yet been paid;

• “loan charge gross liability”, in relation to a person, means the total of the loan charge amounts the person was liable to pay before any payment of those amounts.

• (8) A reference in this section to a Schedule 11 or 12 to F(No. 2)A 2017 loan or quasi-loan is to—

• (a) a loan or quasi-loan (within the meaning of paragraph 2 of Schedule 11 to F(No. 2)A 2017) by reason of which a person is treated, under paragraph 1 of Schedule 11 to F(No. 2)A 2017, as taking a relevant step for the purposes of Part 7A of ITEPA 2003, or

• (b) a loan or quasi-loan (within the meaning of paragraph 2 of Schedule 12 to F(No. 2)A 2017) which is treated for the purposes of sections 23A to 23H of ITTOIA 2005 as a relevant benefit by reason of paragraph 1 of Schedule 12 to F(No. 2)A 2017.

• (9) In this section—

• “the Commissioners” means the Commissioners for His Majesty’s Revenue and Customs;

• “contract settlement” has the meaning given by section 25 of CRCA 2005;

• “shadow director” has the meaning given by section 251 of the Companies Act 2006.

Loan charge settlement scheme: inheritance tax

26

• (1) The scheme may provide that, if a person enters into a settlement agreement, amounts of inheritance tax payable by the person which—

• (a) arise as a result of transfers of value and other occasions of charge occurring—

• (i) in connection with a settlement (within the meaning of section 43 of IHTA 1984) used as part of arrangements under which the relevant Schedule 11 or 12 to F(No. 2)A 2017 loans and quasi-loans were made, and

• (ii) before the end of 3 months after the date on which the settlement offer, in relation to the settlement agreement, was made to the person, and

• (b) have not yet been paid,

cease to payable by the person.

• (2) The scheme may provide, if a person enters into a settlement agreement, for adjustments in amounts of inheritance tax payable by other persons which—

• (a) arise as mentioned in subsection (1)(a),

• (b) are attributable to property used for making the relevant Schedule 11 or 12 to F(No. 2)A 2017 loans and quasi-loans, and

• (c) have not yet been paid.

• (3) The scheme must provide that, if a person enters into a settlement agreement, no relevant Schedule 11 or 12 to F(No. 2)A 2017 loan or quasi-loan is to be treated as a liability for the purposes of section 5(3) of IHTA 1984.

• (4) In this section, references to relevant Schedule 11 or 12 to F(No. 2)A 2017 loans and quasi-loans are to the Schedule 11 or 12 to F(No. 2)A 2017 loans and quasi-loans to which the loan charge amounts to which the settlement agreement applies are connected.

• (5) Expressions used in this section and section 25 have the same meaning in this section as they have in section 25.

• (6) In this section, “transfer of value” has the same meaning as in IHTA 1984 (see, in particular, section 3 of that Act).

Loan charge settlement scheme: supplementary

27

• (1) The scheme may make provision—

• (a) about the process of making settlement offers and entering into settlement agreements;

• (b) for settlement offers to be conditional upon the persons to whom they are made doing specified things;

• (c) about the terms which may, must or may not be included in settlement agreements;

• (d) supplementing—

• (i) provision made under section 25(6) about the calculation of settlement amounts, and

• (ii) the definitions in section 25(7) of “loan charge amount” and “loan charge gross liability”;

• (e) adapting provision made under section 25(6), in cases where a settlement offer is made to a person who is not an individual, about the calculation of settlement amounts (including provision for the calculation to be different to what is required by section 25(6));

• (f) for the use of estimates in relation to any amount;

• (g) about liabilities which are incidental to, or otherwise connected with, loan charge amounts;

• (h) for amounts paid by a person towards the person’s loan charge gross liability to be credited against a liability of the person to pay a settlement amount (but to no greater extent than discharging that liability);

• (i) for anything else the Treasury consider appropriate for the purpose of the scheme.

• (2) The things specified under subsection (1)(b) may include, for example, a person to whom a settlement offer is made entering into a contract settlement in relation to amounts specified in the settlement offer which—

• (a) are not loan charge amounts,

• (b) are payable, or become payable in the future, to the Commissioners by the person under or by virtue of any enactment, and

• (c) have not yet been paid.

• (3) The provision which may be made under subsection (1)(d)(ii) includes provision setting out the descriptions of amounts which arise in connection with a Schedule 11 or 12 to F(No. 2)A 2017 loan or quasi-loan.

• (4) The provision which may be made under subsection (1)(g) includes provision—

• (a) treating penalties, or other amounts which are not loan charge amounts but are connected with them, as never having arisen or ceasing to be payable, and

• (b) crediting amounts paid towards such liabilities against other liabilities to pay a settlement or other amount to the Commissioners or for the Commissioners to repay those paid amounts.

• (5) The scheme may make—

• (a) different provision for different purposes or cases;

• (b) provision generally or for specified cases;

• (c) provision subject to exceptions;

• (d) incidental, supplementary, consequential or transitional provision.

• (6) Regulations providing for the scheme are to be made by statutory instrument and are subject to annulment in pursuance of a resolution of the House of Commons.

• (7) A settlement agreement is a contract settlement for the purposes of sections 25 and 25A of CRCA 2005.

• (8) Expressions used in this section and section 25 or 26 have the same meaning in this section as they have in section 25 or 26.

Capital allowances and other reliefs for businesses

Main rate of writing-down allowances for expenditure on plant or machinery

28

• (1) In section 56 of CAA 2001 (amount of plant and machinery allowances), in subsection (1) (which specifies the main rate of writing-down allowances), for “18%” substitute “14%”.

• (2) The amendment made by subsection (1) has effect in relation to chargeable periods beginning on or after the relevant day, that is to say—

• (a) for corporation tax purposes, 1 April 2026, and

• (b) for income tax purposes, 6 April 2026.

• (3) The amendment made by subsection (1) also has effect in relation to chargeable periods beginning before and ending on or after the relevant day but as if the reference to 14% were a reference instead to X%.

• (4) For this purpose X is found by adding (18 x BRD/CP) to (14 x ARD/CP).

• (5) Where X would be a figure with more than 2 decimal places, it is to be rounded up to the nearest second decimal place.

• (6) In subsection (4)—

• “BRD” means the number of days in the chargeable period before the relevant day,

• “ARD” means the number of days in the chargeable period on and after the relevant day, and

• “CP” means the number of days in the chargeable period.

First-year allowance for main rate expenditure on plant or machinery

29

• (1) Part 2 of CAA 2001 (plant and machinery allowances) is amended as follows.

• (2) In section 39 (first-year allowances available for certain types of qualifying expenditure only), after the entry relating to section 45S insert—

section 45U	expenditure on plant or machinery in cases not falling within section 45S etc

• (3) After section 45T insert—

(45U) Expenditure is first-year qualifying expenditure if— (a) it is incurred on or after 1 January 2026, (b) it is not special rate expenditure, (c) it is expenditure on plant or machinery which is unused and not second-hand, and (d) it is not excluded by section 45V (exclusion of expenditure under disqualifying arrangements) or 46 (general exclusions). (45V) (1) Expenditure is not first-year qualifying expenditure under section 45U if the expenditure is incurred directly or indirectly in consequence of, or otherwise in connection with, disqualifying arrangements. (2) Arrangements are “disqualifying arrangements” for the purposes of this section if— (a) the main purpose, or one of the main purposes, of the arrangements is to secure a tax advantage connected with expenditure being first-year qualifying expenditure under section 45U, and (b) it is reasonable, taking account of all the relevant circumstances— (i) to conclude that the arrangements are, or include steps that are, contrived, abnormal or lacking a genuine commercial purpose, or (ii) to regard the arrangements as circumventing the intended limits of relief under this Act or otherwise exploiting shortcomings in this Act. (3) In this section “arrangements” include any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

• (4) In section 46 (general exclusions)—

• (a) in subsection (1), after the entry relating to section 45S insert—

section 45U	(expenditure on plant or machinery in cases not falling within section 45S etc)

, and

• (b) after subsection (4A) insert—

(4B) General exclusion 6 does not prevent expenditure being first-year qualifying expenditure under section 45U if— (a) the plant or machinery is provided for leasing to a lessee for use by the lessee wholly, or almost wholly, for the purpose of earning income which is within the charge to tax, or (b) the plant or machinery is provided for leasing to a lessee who is resident in the United Kingdom where the circumstances are such that the plant or machinery is not for use (to a significant extent) by the lessee for the purpose of earning income which is from a source outside the United Kingdom and which is outside the charge to tax. (4C) For the purposes of subsection (4B) income is to be regarded as being outside the charge to tax if the income arises to a person who under— (a) double taxation arrangements, or (b) unilateral relief arrangements, is afforded or is entitled to claim any relief from the tax chargeable on the income. (4D) For this purpose “double taxation arrangements” and “unilateral relief arrangements” have the same meaning as they have in Part 2 of the Taxation (International and Other Provisions) Act 2010 (see sections 2(4) and 8(1) respectively). (4E) For the purposes of subsection (4B) it is to be presumed that, unless the contrary is shown, a lessee has made every claim or election for relief from tax, and every claim or election for an exemption from tax, which the lessee is entitled to make. (4F) For the purposes of subsection (4B), if there is more than one lessee, references to the lessee are to each of the lessees. (4G) For the purposes of subsections (4B) to (4F), any reference to leasing or a lessee includes sub-leasing and a sub-lessee.

• (5) In section 52 (first-year allowances), in subsection (3), in the table, at the end insert—

Expenditure qualifying under section 45U (expenditure on plant or machinery in cases not falling within section 45S etc)	40%

Expenditure on zero-emission cars and electric vehicle charging points

30

In—

• (a) section 45D of CAA 2001 (expenditure on zero-emission cars), in subsection (1B)(a) and (b) (which specify the date on or before which expenditure must be incurred to qualify for a first-year allowance), and

• (b) section 45EA of that Act (expenditure on plant or machinery for electric vehicle charging point), in subsection (3)(a) and (b) (which specify the date on or before which expenditure must be incurred to qualify for a first-year allowance),

for “2026” substitute “2027”.

Payments for surrender of expenditure credits

31

• (1) In section 1042N of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—

(5) Subsection (6) applies (in addition to subsection (3)) if— (a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and (b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member. (6) The payment is not to be— (a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or (b) regarded for corporation tax purposes as a distribution.

• (2) In section 1179CE of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—

(5) Subsection (6) applies (in addition to subsection (3)) if— (a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and (b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member. (6) The payment is not to be— (a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or (b) regarded for corporation tax purposes as a distribution.

• (3) The amendments made by this section have effect in relation to payments made on or after 26 November 2025.

Transition from video games tax relief

32

• (1) Schedule 2 to FA 2024 (expenditure credits for films, television programmes and video games) is amended as follows.

• (2) After paragraph 24 insert—

(24A) (1) Sub-paragraph (2) applies if— (a) a company makes an election under section 1179B(1) of CTA 2009 in relation to a video game in its company tax return for an accounting period, and (b) in an earlier accounting period, the company was entitled to, and claimed, special video games relief (within the meaning of section 1217E(1) of CTA 2009) in respect of that video game. (2) Section 1179CA(1) of CTA 2009 (amount of expenditure credit) has effect as if for Step 2 there were substituted— Step 2 Deduct from that total the sum of— 1. 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 2. 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).

• (3) In paragraph 18 (opting into new regime during transitional period), in sub-paragraph (5)(b), for “24” substitute “24A”.

• (4) The amendments made by this section have effect in relation to elections made under section 1179B(1) of CTA 2009 in relation to any opt-in period commencing on or after 26 November 2025.

Special credit for visual effects

33

• (1) Section 1179EC of CTA 2009 (special credit for visual effects) is amended as follows.

• (2) In subsection (2)—

• (a) omit the “and” after paragraph (a),

• (b) after that paragraph insert—

(aa) a claim for Chapter 3 credit has been made for the last accounting period in the AVEC period (which may be the claim period) in which the company incurred relevant global expenditure (see section 1179CA(2)) that is UK expenditure (see section 1179AB), and

, and

• (c) in paragraph (b)—

• (i) omit “where a claim has been made for Chapter 3 credit (whether for the claim period or earlier),”, and

• (ii) for “such claims” substitute “Chapter 3 credit claims in respect of the film or television programme”.

• (3) In subsection (3)(b) for paragraph (i) substitute—

(i) the adjusted VFX portion of Chapter 3 credits claimed in respect of the film or television programme, and

• (4) In subsection (4)—

• (a) in the words before Step 1, for “previously claimed Chapter 3 credits” substitute “Chapter 3 credits claimed in respect of the film or television programme”, and

• (b) in Step 1—

• (i) in the words before paragraph (a) omit “(see section 1179CA(2))”, and

• (ii) in that paragraph omit “(see section 1179AB)”.

• (5) After subsection (6) insert—

(6A) Where a production company has claimed an additional amount of audiovisual expenditure credit for an accounting period and makes a claim for Chapter 3 credit for a subsequent accounting period— (a) the additional amount is to be calculated for that subsequent accounting period, and (b) if that additional amount is negative, the amount of Chapter 3 credit to which the company is entitled for that period is to be reduced by the additional amount. (6B) Where Chapter 3 credit claimed by a company for an accounting period is reduced as a result of subsection (6A)(b), for the purposes of the application of subsections (3) and (4) in relation to the company for any subsequent accounting period— (a) the sum of the additional amounts of audiovisual expenditure credit previously claimed (as referred to in subsection (3)(b)(ii)) is to be reduced by the additional amount referred to in subsection (6A)(b), and (b) in determining the sum of Chapter 3 credits claimed by the production company for the purposes of Step 4 in subsection (4), ignore the reduction of any Chapter 3 credit resulting from the application of subsection (6A)(b).

• (6) The amendments made by this section have effect in relation to any claim made for Chapter 3 credit, or an additional amount of audiovisual expenditure credit, for accounting periods beginning on or after 26 November 2025.

R&D undertaken abroad: Chapter 2 relief only

34

• (1) In section 1138A(1)(b) of CTA 2009, at beginning insert “for the purposes of relief under Chapter 2”.

• (2) The amendment made by subsection (1) has effect in relation to claims made on or after 30 October 2024.

Chargeable gains

Restriction of relief on disposals to employee-ownership trusts

35

• (1) Section 236H of TCGA 1992 (disposals to employee-ownership trusts) is amended as follows.

• (2) For subsection (2) substitute—

(2) Where this section applies, section 17(1) (disposals and acquisitions treated as made at market value) does not apply to the disposal and, taking account of that disapplication— (a) if a gain accrues, subsection (2A) applies, or (b) if no gain accrues, subsection (3) applies. (2A) Where this subsection applies— (a) only 50% of the gain is a chargeable gain, (b) the disposal is not to be regarded as a qualifying business disposal for the purposes of Chapter 3 of Part 5 (business asset disposal relief), (c) the ordinary share capital disposed of is to be regarded, immediately before the disposal, as comprised wholly of excluded shares for the purposes of Chapter 5 of that Part (investors’ relief), and (d) the acquisition by the trustees is to be treated for the purposes of this Act as made for the consideration for the disposal less an amount equal to so much of the gain as is not a chargeable gain as a result of paragraph (a).

• (3) In subsection (3), for “The”, in the first place it occurs, substitute “Where this subsection applies, the”.

• (4) The amendments made by this section have effect in relation to disposals made on or after 26 November 2025.

Anti-avoidance: collective investment scheme reconstructions

36

• (1) TCGA 1992 is amended as follows.

• (2) In section 103G (exchange of units for those in another collective investment scheme), in subsection (4), for “section 103K(1)” to the end of the subsection substitute “section 103K (anti-avoidance)”.

• (3) In section 103H (scheme of reconstruction involving issue of units), in subsection (5), for “section 103K(1)” to the end of the subsection substitute “section 103K (anti-avoidance)”.

• (4) In section 103I (scheme of reconstruction involving conversion scheme), in subsection (4), for “section 103K(1)” to the end of the subsection substitute “section 103K (anti-avoidance)”.

• (5) In section 103K (restriction on application of sections 103G, 103H and 103I)—

• (a) at the end of the heading insert “: anti-avoidance”;

• (b) for subsection (1) substitute—

(1) This section applies in respect of arrangements relating to an exchange or scheme of reconstruction as regards which section 103G, 103H or 103I applies if the main purpose, or one of the main purposes, of the arrangements is to reduce or avoid liability to capital gains tax, corporation tax or income tax. (1A) Any such reduction or avoidance that would (in the absence of this section) arise from such arrangements is to be counteracted by the making of such adjustments as are just and reasonable (in light of the reduction or avoidance). (1B) This includes, in an appropriate case, disapplying section 103G, 103H or 103I insofar as is required to counteract the reduction or avoidance. (1C) Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of— (a) an assessment, or (b) the modification of an assessment.

• (c) omit subsections (2) and (3);

• (d) in subsection (4)—

• (i) for “subsection (1) above” substitute “this section”;

• (ii) in paragraph (a), after “chargeable participant” insert “as part of the exchange or scheme of reconstruction”;

• (e) after subsection (6) insert—

(7) In this section, “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

• (6) The amendments made by this section have effect in relation to arrangements involving an issue of units in a collective investment scheme on or after 26 November 2025.

• (7) But those amendments do not have effect in a case where—

• (a) a participant in a collective investment scheme has made an application under section 138(1) of TCGA 1992 (as applied by section 103K(6) of that Act) before 26 November 2025,

• (b) the Commissioners for His Majesty’s Revenue and Customs have notified the participant of their satisfaction, or the tribunal has notified the participant of its satisfaction, in relation to the application under section 138(1) or (4) of TCGA 1992, and

• (c) the issue of units in a collective investment scheme in respect of which the application was made occurs before 26 January 2026 or, if later, before the end of the period of 60 days beginning with the day on which the notification mentioned in paragraph (b) was made.

Anti-avoidance: company reconstructions

37

• (1) TCGA 1992 is amended as follows.

• (2) In section 135 (exchange of securities for those in another company), in subsection (6), for “section 137(1)” to the end of the subsection substitute “section 137 (anti-avoidance)”.

• (3) In section 136 (scheme of reconstruction involving issue of securities), in subsection (6), for “section 137(1)” to the end of the subsection substitute “section 137 (anti-avoidance)”.

• (4) In section 137 (restriction on company reconstruction provisions)—

• (a) at the end of the heading insert “: anti-avoidance”;

• (b) for subsection (1) substitute—

(1) This section applies in respect of arrangements relating to an exchange or scheme of reconstruction as regards which section 135 or 136 applies if the main purpose, or one of the main purposes, of the arrangements is to reduce or avoid liability to capital gains tax or corporation tax. (1A) Any such reduction or avoidance that would (in the absence of this section) arise from such arrangements is to be counteracted by the making of such adjustments as are just and reasonable (in light of the reduction or avoidance). (1B) This includes, in an appropriate case, disapplying section 135 or 136 insofar as is required to counteract the reduction or avoidance. (1C) Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of— (a) an assessment, or (b) the modification of an assessment.

• (c) omit subsections (2) and (3);

• (d) in subsection (4)—

• (i) for “subsection (1) above” substitute “this section”;

• (ii) in paragraph (a), after “chargeable person” insert “as part of the exchange or scheme of reconstruction”;

• (e) after subsection (6) insert—

(7) In this section, “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

• (5) In section 138 (procedure for clearance in advance)—

• (a) in subsection (1)—

• (i) for “shall not affect the operation of section 135 or 136” substitute “does not apply”;

• (ii) after “the issue” insert “of shares or debentures mentioned in section 135(1) or 136(1)”;

• (iii) for “section 137(1)”, in the first place it appears, substitute “section 135(1) or 136(1)”;

• (iv) for “for bona fide” to the end of the subsection substitute “without arrangements in respect of which section 137 applies.”;

• (b) after subsection (5) insert—

(6) In this section, references to shares or debentures include references to any interests or options to which this Chapter applies by virtue of section 135(5), 136(5) or 147.

• (6) The amendments made by this section have effect in relation to arrangements involving an issue of shares in, or debentures of, a company on or after 26 November 2025.

• (7) But those do not have effect in a case where—

• (a) a company has made an application under section 138(1) of TCGA 1992 before 26 November 2025,

• (b) the Commissioners for His Majesty’s Revenue and Customs have notified the company of their satisfaction, or the tribunal has notified the company of its satisfaction, in relation to the application under section 138(1) or (4) of TCGA 1992, and

• (c) the issue of shares or debentures in respect of which the application was made occurs before 26 January 2026 or, if later, before the end of the period of 60 days beginning with the day on which notification mentioned in paragraph (b) was made.

Anti-avoidance: reconstructions involving transfer of business

38

• (1) In section 139 (reconstruction involving transfer of business)—

• (a) after subsection (4) insert—

(4A) Subsection (4B) applies in respect of arrangements relating to a reconstruction as regards which this section applies if the main purpose, or one of the main purposes, of the arrangements is to reduce or avoid liability to capital gains tax, corporation tax or income tax. (4B) Any such reduction or avoidance that would (in the absence of this subsection) arise from such arrangements is to be counteracted by the making of such adjustments as are just and reasonable (in light of the reduction or avoidance). (4C) This includes, in an appropriate case, disapplying this section insofar as is required to counteract the reduction or avoidance. (4D) Any adjustments required to be made under subsection (4B) (whether or not by an officer of Revenue and Customs) may be made by way of— (a) an assessment, or (b) the modification of an assessment.

• (b) in subsection (5)—

• (i) for the words from the beginning of the subsection to “operation of this section” substitute “Subsections (4A) to (4D) do not apply”;

• (ii) for “for bona fide” to the end of the first sentence substitute “without arrangements in respect of which subsection (4B) applies.”;

• (c) in subsections (6) and (7), for “subsection (5)” substitute “subsection (4B)”;

• (d) after subsection (9) insert—

(10) In this section, “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

• (2) The amendments made by this section have effect in relation to arrangements involving the transfer of assets of a business on or after 26 November 2025.

• (3) But this section does not have effect in relation to a case where—

• (a) a company has made an application under section 139(5) of TCGA 1992 before 26 November 2025,

• (b) the Commissioners for His Majesty’s Revenue and Customs have notified the company of their satisfaction under that subsection, or the tribunal has notified the company of its satisfaction under section 138(4) of TCGA 1992 (as applied by section 139(5) of that Act), in relation to the application, and

• (c) the transfer of assets in respect of which the application was made occurs before 26 January 2026 or, if later, before the end of the period of 60 days beginning with the day on which notification mentioned in paragraph (b) was made.

Incorporation relief: requirement to claim

39

• (1) Section 162 of TCGA 1992 (roll-over relief on transfer of business) is amended as follows.

• (2) In subsection (1)—

• (a) the words from “a person who is not a company” to the end of the first sentence of the subsection become paragraph (a);

• (b) after that paragraph insert

, and (b) the person makes a claim in respect of the transfer, including such information as the Commissioners may require, on or before the first anniversary of the 31 January following the tax year in which the transfer of the business took place.

• (3) After subsection (5) insert—

(6) In this section, “the Commissioners” means the Commissioners for His Majesty’s Revenue and Customs.

• (4) Omit section 162A of TCGA 1992 (election for section 162 not to apply).

• (5) The amendments made by this section have effect in relation to transfers of businesses made on or after 6 April 2026.

Non-residents: cell companies

40

• (1) Part 4 of Schedule 1A to TCGA 1992 (anti-avoidance relating to assets deriving 75% of value from UK land) is amended as follows.

• (2) For the heading of the Part substitute “Cell companies and anti-avoidance”.

• (3) Before paragraph 11 insert—

(10A) (1) In the application of this Schedule in relation to the disposal of an asset consisting of a right or an interest in a cell company, each cell of the company is to be treated as if it were an individual company. (2) For the purposes of this paragraph— (a) a company is a “cell company” if under the law under which the company is formed, under the company’s articles of association or other document regulating the company or under arrangements entered into by or in relation to the company— (i) some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and (ii) some or all of the members of the company, and some or all of its creditors, have rights primarily, or only, in relation to particular assets of the company; (b) “cell”, in relation a cell company, means an identifiable part of the company that carries on distinct business activities and to which particular assets and liabilities of the company are primarily or wholly attributable.

• (4) The amendments made by this section have effect in relation to disposals made on or after 26 November 2025.

Non-residents: double taxation relief relating to collective investment vehicles

41

• (1) In paragraph 2 of Schedule 18 to FA 1998 (duty to give notice of chargeability to corporation tax), after sub-paragraph (2) insert—

(2A) Where sub-paragraph (1A) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).

• (2) In section 55A of FA 2004 (exception to duty to give notice to coming within charge to corporation tax), after subsection (4) insert—

(5) Where subsection (1) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).

• (3) In Schedule 2 to FA 2019—

• (a) in the heading before paragraph 10 (no return required in respect of disposal connected to CIS), for “schemes” substitute “vehicles”;

• (b) in paragraph 10—

• (i) for “scheme” substitute “vehicle”;

• (ii) after sub-paragraph (2) insert—

(3) If, by virtue of sub-paragraph (1), a person is not required to make or deliver a return under this Schedule in respect of a disposal, the person is not required to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of the disposal (despite subsection (6) of that section).

• (c) in paragraph 11(1)(a)—

• (i) for “CIS” substitute “CIV”;

• (ii) for “scheme” substitute “vehicle”;

• (d) in paragraph 11(1)(b), for “subject of the scheme” substitute “subject of or held by the vehicle”;

• (e) in paragraph 12(1)(a), for “CIS” substitute “CIV”.

• (4) The amendments made by subsections (1) and (2) have effect in relation to disposals made on or after 1 April 2026.

• (5) The amendments made by subsection (3) have effect in relation to disposals made on or after 6 April 2026.

Non-UK residents etc

Abolition of notional tax credit on distributions received by non-UK residents

42

• (1) Omit section 399 of ITTOIA 2005 (tax treated as paid on distributions received by non-UK resident persons).

• (2) In ITA 2007—

• (a) in section 425 (total amount of income tax to which individual charged for a tax year), in subsection (5)(a), omit sub-paragraph (i);

• (b) in section 1026 (meaning of “non-qualifying income”), omit paragraph (a).

• (3) In TMA 1970—

• (a) in section 9 (returns to include self-assessment), in subsection (1), in the closing words, omit “or section 399(2)”;

• (b) in section 59B (payment of income tax and capital gains tax), in subsection (1), in the closing words, omit “or section 399(2)”.

• (4) In the Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I.‌ 2013/2819), in regulation 12 (treatment of income of an exempt unauthorised unit trust), omit paragraph (3)(b).

• (5) The amendments made by this section have effect for the tax year 2026-27 and subsequent tax years.

Non-resident, and previously non-domiciled individuals

43

• (1) Part 1 of Schedule 3 makes provision about income tax and capital gains tax in connection with whether an individual has been non-UK resident or domiciled outside the United Kingdom, including—

• (a) provision about the reliefs for qualifying new residents,

• (b) provision about the residency of personal representatives, and

• (c) provision about former users of the remittance basis.

• (2) Part 2 of that Schedule makes provision amending Schedule 10 to FA 2025 (temporary repatriation facility).

• (3) Part 3 of that Schedule makes provision about individuals who have been temporarily non-resident.

Trust protections etc: minor amendments and transitional protection

44

• (1) In Chapter 5 of Part 5 of ITTOIA 2005 (settlements), in section 643C (meaning of “available protected income”)—

• (a) in subsection (1), in Step 5, after “within” insert “Step 2 or”;

• (b) in subsection (3)(b), at the end insert “and not exempt from income tax by virtue of any of sections 737 to 742A of that Act”.

• (2) In Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad), in section 733 (benefits charge: amount of deemed income), in subsection (2B)—

• (a) in paragraph (a), for “732(2)” substitute “721, 728 or 732”;

• (b) in the words after paragraph (b), omit “under section 731”.

• (3) In section 87HA of TCGA 1992 (onward gifts from non-residents or qualifying new residents), in subsections (2) and (3), omit “capital”.

• (4) In FA 2025, in Schedule 12 (trust protections), in Part 4 (commencement and transitional provision), after paragraph 70 insert—

(70A) (1) This paragraph applies for the purposes of section 643A of ITTOIA 2005 if an individual’s untaxed benefits total in relation to a settlement for the tax year 2024-25 exceeded the available protected income up to the end of that tax year. (2) In determining under section 643B of that Act the individual’s untaxed benefits total for the tax year 2025-26 or a later tax year, any benefit provided to the individual in the tax year 2024-25 or an earlier tax year is to be disregarded at Step 1 in subsection (1). (3) In this paragraph “untaxed benefits total” and “available protected income”, in relation to an individual, a settlement and a tax year, are to be construed in accordance with sections 643B and 643C of ITTOIA 2005 (as they have or had effect for the tax year in question).

• (5) The amendments made by subsection (1) come into force on 6 April 2026.

• (6) The amendments made by subsections (2) to (4) are treated as having come into force on 6 April 2025.

PAYE for treaty non-residents etc.

45

• (1) Schedule 4—

• (a) makes provision for employer PAYE notifications in respect of treaty non-resident employees, and

• (b) makes other amendments to sections 690 to 690E of ITEPA 2003 in relation to the making of employer PAYE notifications and HMRC PAYE directions.

• (2) The amendments made by Schedule 4 have effect for the tax year 2026-27 and subsequent tax years (but see paragraph 8(2) of that Schedule).

Other international matters

Unassessed transfer pricing profits

46

• (1) Schedule 5 provides—

• (a) for a power of His Majesty’s Revenue and Customs to assess “unassessed transfer pricing profits”,

• (b) for those profits to be subject to a higher rate of corporation tax (rather than the main or any other rate), and

• (c) for the abolition of diverted profits tax (which is superseded).

• (2) The amendments made by that Schedule have effect in relation to accounting periods beginning on or after 1 January 2026.

Transfer pricing reform

47

Schedule 6 makes provision about, and in connection with, transfer pricing.

International controlled transactions

48

• (1) The Commissioners for His Majesty's Revenue and Customs may by regulations make provision—

• (a) requiring persons specified for the purposes of this paragraph (“reporting entities”) to provide an officer of Revenue and Customs with information of specified descriptions in connection with specified international controlled transactions;

• (b) requiring reporting entities to provide the information—

• (i) at specified times,

• (ii) in relation to specified periods of time, and

• (iii) in a specified form and manner;

• (c) imposing obligations on reporting entities (including obligations to obtain information from specified persons for the purposes of complying with requirements imposed by virtue of paragraph (a));

• (d) about contravention of, or non-compliance with, the regulations (including provision imposing penalties);

• (e) about appeals in relation to the imposition of any penalty.

• (2) The regulations may—

• (a) make different provision for different purposes;

• (b) make provision by reference to things specified in a notice published by the Commissioners (as revised or replaced from time to time) in accordance with the regulations;

• (c) allow any requirement, obligation or other provision that may be imposed or made by reference to subsection (1)(a) to (c) to be made by specific or general direction given by the Commissioners;

• (d) make provision under which the Commissioners or other persons may exercise discretions.

• (3) For the purposes of subsection (1)—

• (a) “specified” means specified in the regulations, and

• (b) a transaction is an international controlled transaction if the transfer pricing condition or the permanent establishment condition is met in relation to it.

• (4) The transfer pricing condition is that—

• (a) the transaction, or a series of transactions of which the transaction forms part, is the means by which provision (within the meaning of Part 4 of TIOPA 2010) has been made or imposed between two persons,

• (b) the participation condition (within the meaning of that Part) is met in relation to that provision,

• (c) one of those persons is—

• (i) a UK resident company,

• (ii) a non-UK resident company within the charge to corporation tax as a result of it falling within paragraph (a), (c) or (d) of section 5(2) of CTA 2009 (deals in or develops UK land, carries on a UK property business or has other UK property income), or

• (iii) a partnership whose members include a company within the charge to corporation tax, and

• (d) the other person is a non-UK resident person or is a partnership whose members include a non-UK resident person.

• (5) The permanent establishment condition is that the transaction is relevant to the determination of—

• (a) exemption adjustments made under section 18A of CTA 2009, or

• (b) the profits of a non-UK resident company that are (for the purposes of the Corporation Tax Acts) attributable to a permanent establishment of the company in the United Kingdom.

• (6) References in this section to a transaction includes any transaction that may be treated to have occurred for the purposes of applying Chapter 3A or 4 of Part 2 of CTA 2009 (profits of permanent establishments).

Permanent establishments

49

Schedule 7 makes provision about permanent establishments, including for the purposes of giving effect to certain provisions of the Model Tax Convention on Income and on Capital published by the Organisation for Economic Co-operation and Development in 2017.

Pillar two

50

Schedule 8 contains amendments to F(No.2)A 2023, and other connected provision, relating to multinational top-up tax and domestic top-up tax.

Controlled foreign companies: interest on reversal of state aid recovery

51

• (1) This section applies if a repayment of interest (“the relevant repayment”) is, or has been at any time, made to a company in consequence of the cancellation of an interest charging notice given to the company under Schedule 7ZA to TIOPA 2010 (recovery of unlawful state aid).

• (2) Interest must be paid to the company in respect of the relevant repayment.

• (3) The amount of interest payable under this section is the amount that would have been payable by virtue of section 826 of the Income and Corporation Taxes Act 1988 (interest on tax overpaid) in respect of the relevant repayment if, at the time of the relevant repayment—

• (a) the relevant repayment had been among the repayments and payments listed in subsection (1) of that section, and

• (b) the material date for the purposes of that section, in relation to the relevant repayment, had been the date on which the interest mentioned in subsection (1) above was paid by the company.

• (4) Interest payable under this section must be paid—

• (a) in respect of a relevant repayment made before 2 December 2025, as soon as reasonably practicable;

• (b) in respect of a relevant repayment made on or after that day, at the same time as the relevant repayment.

• (5) Nothing in paragraph 10(1) of Schedule 7ZA to TIOPA 2010 (Treasury duty to make regulations where Commission Decision is revoked or annulled) requires the Treasury to make any further provision in relation to the repayment of interest paid by virtue of that Schedule.

• (6) References in this section to Schedule 7ZA to TIOPA 2010 are to the Schedule treated as inserted in that Act by paragraph (b) of Schedule 4 to the Taxation (Post-transition Period) Act 2020.

• (7) This section is treated as having come into force on 2 December 2025.

Offshore income gains

52

• (1) In the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—

• (a) in regulation 20 (application to gains of non-resident settlements), omit paragraphs (2) to (5);

• (b) in regulation 21 (application of transfer of assets abroad provisions), omit paragraphs (4) to (6).

• (2) In consequence of the amendments made by subsection (1)—

• (a) in section 734 of ITA 2007 (reduction in amount charged: previous capital gains tax charge), in subsection (5), omit “20 and”;

• (b) in Schedule 7 to FA 2008 (remittance basis), omit paragraphs 100 to 102;

• (c) in the Offshore Funds (Tax) Regulations 2009—

• (i) in regulation 18 (charge to tax on disposal of asset: further provisions), in paragraph (5), omit sub-paragraph (c);

• (ii) in regulation 19 (income treated as arising under regulation 17: remittance basis), omit paragraph (5);

• (iii) omit regulation 130 (amendments of FA 2008);

• (iv) in Part 2 of Schedule 3 (index of defined expressions), omit the entry for “OIG amount”;

• (d) in Schedule 10 to FA 2025 (temporary repatriation facility)—

• (i) in paragraph 3(7), for “paragraphs 4 and 5” substitute “paragraph 5”;

• (ii) in paragraph 3(9), for “paragraphs 4 and 5” substitute “paragraph 5”;

• (iii) omit paragraph 4;

• (iv) in paragraph 5(7), for “paragraphs 3 and 4” substitute “paragraph 3”;

• (v) in paragraph 10, omit sub-paragraphs (7) and (8).

• (3) Section 53 makes provision preserving in certain cases the effect of the law as it applied before the amendments made by this section.

• (4) This section—

• (a) is to be treated as having come into force on 6 April 2025;

• (b) has effect for the tax year 2025-26 and subsequent tax years.

Offshore income gains: savings

53

• (1) This section applies in relation to an offshore income gain arising to the trustees of a settlement in a case where Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to that gain for the tax year 2025-26 or any subsequent tax year because of the amendments made by section 52.

• (2) If the offshore income gain arose in a tax year before the tax year 2025-26 and, by reason of that offshore income gain or a part of it, an offshore income gain was treated as arising in a tax year before the tax year 2025-26 to an individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—

• (a) Chapter 2 of Part 13 of ITA 2007 is to be treated as not applying in relation to the offshore income gain arising to the trustees or that part of that gain, and

• (b) references in section 734 of ITA 2007 to chargeable gains treated as accruing to an individual are to be treated as including the offshore income gain treated as arising to the individual.

• (3) An individual is not chargeable to income tax under Chapter 2 of Part 13 of ITA 2007 on income treated as arising to the individual under section 732 of ITA 2007 by reason of the offshore income gain to the extent that the income, without the amendments made by section 52(1) and (2)(b)—

• (a) would have been treated as arising to that individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and

• (b) would have been non-chargeable income (see subsections (4), (5) and (6)).

• (4) The income would have been non-chargeable income if, without the amendments made by section 52(1) and (2)(b)—

• (a) the income would have been treated as arising by reason of—

• (i) the matching of a capital payment received (or treated as received) by the individual before 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or

• (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising before 6 April 2008, and

• (b) paragraph 100 of Schedule 7 to FA 2008 would have applied to the income.

• (5) The income would have been non-chargeable income to the extent that, without the amendments made by section 52(1) and (2)(b), it would have exceeded the relevant proportion of income—

• (a) which would have been treated as arising to the individual by reason of—

• (i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or

• (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, and

• (b) to which paragraph 101 of Schedule 7 to FA 2008 would have applied,

and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (9) to (18) of paragraph 126 of that Schedule as they would have been modified by sub-paragraph (3) of paragraph 101 of that Schedule.

• (6) The income would have been non-chargeable income to the extent that, without the amendments made by section 52(1) and (2)(b), it would have exceeded the relevant proportion of income—

• (a) which would have been treated as arising to the individual by reason of—

• (i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or

• (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008,

• (b) to which paragraph 102 of Schedule 7 to FA 2008 would have applied, and

• (c) to which paragraph 101 of that Schedule would not have applied,

and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (4) to (7) of paragraph 127 of that Schedule as they would have been modified by sub-paragraph (4) of paragraph 102 of that Schedule.

• (7) Subsection (3) does not prevent Chapter 2 of Part 13 of ITA 2007 from having effect as though the income not chargeable to tax under that subsection had been charged to tax under section 731 of that Act.

• (8) Accordingly—

• (a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of that income will be deducted at Step 2 and at paragraph (a) of Step 5, and

• (b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of that income will be deducted at paragraph (b) of Step 5.

• (9) In section 733 of ITA 2007, after subsection (2D) insert—

(2E) See subsections (7) and (8) of section 53 of FA 2026 (offshore income gains: savings relating to amendments made by section 52 of that Act) for special provision about income that is treated as arising under section 732 but that is not chargeable to income tax under subsection (3) of that section.

• (10) This section—

• (a) is to be treated as having come into force on 6 April 2025;

• (b) has effect for the tax year 2025-26 and subsequent tax years.

Charities

Legacies to charities to be within scope of tax

54

• (1) Part 10 of ITA 2007 (special rules about charitable trusts etc) is amended in accordance with subsections (2) to (4).

• (2) In section 518 (overview), in subsection (1), for “523” substitute “523A”.

• (3) After section 523 (but beneath the same italic heading) insert—

(523A) (1) This section applies to a gift of property— (a) that is made by will to a charitable trust, and (b) that is not charged to income tax, apart from this section. (2) Income tax is charged on the gift. (3) It is charged on the total value of the property so received in the tax year; and for that purpose the value of any property other than money is its market value as at the time of the death of the person by whose will the gift of the property is made. (4) But property is not taken into account in calculating total income so far as it is applied to charitable purposes only. (5) The trustees of the charitable trust are liable for any tax charged under this section. (6) A gift of property made to a charitable trust is treated for the purposes of this section as made by will if— (a) the gift is made to the trust by virtue of the variation, after a person’s death, of a disposition of property effected by the person’s will, and (b) the variation is treated under section 142 of IHTA 1984 (alteration of dispositions taking effect on death) as having been effected by the deceased. (7) In this section— - “property” includes rights and interests of any description; - “will” includes a testament, a codicil and any testamentary disposition of property.

• (4) In section 562 (excess expenditure), in subsection (5) (definition of “non-taxable sums”), omit “, legacies”.

• (5) In ITTOIA 2005, in section 636 (settlements: calculation of undistributed income), in subsection (7), at the appropriate place insert—

• section 523A (legacies)

• (6) Part 11 of CTA 2010 (charitable companies etc) is amended in accordance with subsections (7) to (9).

• (7) In section 466 (overview), in subsection (1), for “474” substitute “474A”.

• (8) After section 474 (but beneath the same italic heading) insert—

(474A) (1) This section applies to a gift of property— (a) that is made by will to a charitable company, and (b) that is not chargeable to corporation tax apart from this section. (2) The value of the property that is the subject of the gift is treated as an amount in respect of which the charitable company is chargeable to corporation tax, under the charge to corporation tax on income. (3) For that purpose the value of any property other than money is its market value as at the time of the death of the person by whose will the gift of the property is made. (4) But the value attributable to property is not taken into account in calculating total profits so far as the property is applied to charitable purposes only. (5) A gift of property made to a charitable company is treated for the purposes of this section as made by will if— (a) the gift is made to the company by virtue of the variation, after a person’s death, of a disposition of property effected by the person’s will, and (b) the variation is treated under section 142 of the Inheritance Tax Act 1984 (alteration of dispositions taking effect on death) has having been effected by the deceased. (6) The exemption under subsection (4) requires a claim. (7) In this section— - “property” includes rights and interests of any description; - “will” includes a testament, a codicil and any testamentary disposition of property.

• (9) In section 515 (excess expenditure), in subsection (5) (definition of “non-taxable sums”), omit “, legacies”.

• (10) The amendments made by this section have effect in relation to gifts received on or after 6 April 2026.

Approved charitable investments: purpose test

55

• (1) Section 558 of ITA 2007 (approved charitable investments) is amended in accordance with subsections (2) to (5).

• (2) The existing text becomes subsection (2).

• (3) Before that subsection insert—

(1) For the purposes of section 543 “approved charitable investment” means an investment— (a) that is of a type listed in subsection (2) and is made for an allowable purpose, or (b) that is not of a type listed in subsection (2) but that is approved under subsection (3).

• (4) In subsection (2)—

• (a) for the words before Type 1 substitute “The following are the types of investment mentioned in subsection (1)(a)—”;

• (b) omit Type 12.

• (5) At the end insert—

(3) An officer of Revenue and Customs may approve a loan or other investment under this subsection if satisfied, on a claim, that it is made for an allowable purpose. (4) For the purposes of this section an investment is made “for an allowable purpose” if it is reasonable to draw the conclusion, from all the circumstances of the case, that the investment is made— (a) for the sole purpose of benefiting the charitable trust, or (b) for that purpose and one or more ancillary or incidental purposes, and is not made for the avoidance of tax (whether by the trust or any other person).

• (6) Section 511 of CTA 2010 (approved charitable investments) is amended in accordance with subsections (7) to (10).

• (7) The existing text becomes subsection (2).

• (8) Before that subsection insert—

(1) For the purposes of section 496 “approved charitable investment” means an investment— (a) that is of a type listed in subsection (2) and is made for an allowable purpose, or (b) that is not of a type listed in subsection (2) but that is approved under subsection (3).

• (9) In subsection (2)—

• (a) for the words before Type 1 substitute “The following are the types of investment mentioned in subsection (1)(a)—”;

• (b) omit Type 12.

• (10) At the end insert—

(3) An officer of Revenue and Customs may approve a loan or other investment under this subsection if satisfied, on a claim, that it is made for an allowable purpose. (4) For the purposes of this section an investment is made “for an allowable purpose” if it is reasonable to draw the conclusion, from all the circumstances of the case, that the investment is made— (a) for the sole purpose of benefiting the charitable company, or (b) for that purpose and one or more ancillary or incidental purposes, and is not made for the avoidance of tax (whether by the company or any other person).

• (11) The amendments made by this section have effect in relation to investments made on or after 6 April 2026.

Tainted charity donations: replacement of purpose test with outcome test

56

• (1) Section 809ZJ of ITA 2007 (tainted donations) is amended in accordance with subsections (2) and (3).

• (2) For subsection (5) substitute—

(5) Condition B is that a linked person who is not a charity receives financial assistance— (a) under or in connection with the arrangements, and (b) directly or indirectly from the charity to which the donation is made or from a connected charity.

• (3) In subsection (8), at the appropriate place insert—

• “financial assistance” includes a loan, a guarantee, an indemnity or any form of investment (in each case, whether or not on arm’s length terms);

• (4) Section 939C of CTA 2010 (tainted donations) is amended in accordance with subsections (5) and (6).

• (5) For subsection (5) substitute—

(5) Condition B is that a linked person who is not a charity receives financial assistance— (a) under or in connection with the arrangements, and (b) directly or indirectly from the charity to which the donation is made or from a connected charity.

• (6) In subsection (8), at the appropriate place insert—

• “financial assistance” includes a loan, a guarantee, an indemnity or any form of investment (in each case, whether or not on arm’s length terms);

• (7) Schedule 9 contains amendments connected with those made by this section in relation to tainted charity donations.

• (8) The amendments made by this section and by Schedule 9 have effect in relation to relievable charitable donations made on or after 6 April 2026.

• (9) In a case where an associated donation is made on or after 6 April 2026 in relation to a tainted donation made before that date, the tainted donation is regarded for the purposes of sections 809ZMB of ITA 2007, section 939FB of CTA 2010 and section 257B of TCGA 1992 as having “become” a tainted donation at the time when it was made.

• (10) In subsections (8) and (9)—

• “associated donation” means an associated donation within the meaning of section 809ZMB of ITA 2007 or section 939FB of CTA 2010 (as inserted, in each case, by Schedule 9);

• “relievable charitable donation” means a relievable charity donation within the meaning of Chapter 8 of Part 13 of ITA 2007 or Part 21C of CTA 2010;

• “tainted donation” means a tainted donation within the meaning of Chapter 8 of Part 13 of ITA 2007 or Part 21C of CTA 2010.

Miscellaneous

Winter fuel payment charge

57

Schedule 10 contains provision for and in connection with a winter fuel payment charge.

Carried interest

58