Finance Act 2026

• (1) ITTOIA 2005 is amended in accordance with subsections (2) to (4).

• (2) After section 23H (double taxation) insert—

(23I) (1) This section applies where— (a) an individual performs investment management services in any tax year directly or indirectly in respect of an investment scheme under any arrangements, and (b) under the arrangements, one or more sums of carried interest arise to the individual from an investment scheme in a tax year. (2) For income tax purposes— (a) the individual is treated as carrying on a trade, by virtue of the arrangements, for the tax year referred to in subsection (1)(b), (b) the amount to be treated as the profits of the trade for that tax year is the sum of the non-qualifying profits of the trade and 72.5% of the qualifying profits of the trade (see subsection (3)), and (c) the individual is treated as the person receiving or entitled to those profits. (3) In subsection (2)(b)— (a) the amount of the non-qualifying profits of the trade is— (i) the total amount of carried interest arising to the individual from any investment scheme in the tax year under the arrangements that is not qualifying carried interest, minus (ii) the proportion of any permitted deduction for the tax year (see section 23N) that is the same as the proportion of the total amount of carried interest that is not qualifying carried interest; (b) the amount of the qualifying profits of the trade is— (i) the total amount of qualifying carried interest arising to the individual from any investment scheme in the tax year under the arrangements, minus (ii) the proportion of any permitted deduction for the tax year that is the same as the proportion of the total amount of carried interest that is qualifying carried interest. (4) In Schedule A1— (a) Part 1 explains what it means for a sum arising to an individual from an investment scheme under arrangements to be “carried interest” for the purposes of this group of sections and that Schedule; (b) Part 2 sets out certain circumstances in which a sum arising to another person is treated as arising to the individual; (c) Part 3 sets out how to determine the extent to which carried interest arising to an individual from an investment scheme is qualifying carried interest; (d) Part 4 allows for an election to be made to treat carried interest as arising at an earlier time. (5) A sum of carried interest arising to an individual from an investment scheme in a tax year is to be treated for the purposes of this section as not being a sum of carried interest to the extent that— (a) it is chargeable to income tax on the individual by virtue of section 62 (earnings) or Part 7 of ITEPA 2003 (employment income relating to securities) in the tax year, or (b) an election made under section 23J that has effect for the tax year applies in relation to the sum. (23J) (1) An individual who performs investment management services directly or indirectly in respect of an investment scheme under arrangements mentioned in section 23I(1)(a) may make an election under this section. (2) Where an election made under this section has effect for a tax year, the election applies in relation to a sum of carried interest arising to the individual under the arrangements in the tax year to the extent that the carried interest would, ignoring this group of sections, be brought into account in calculating the profits of a trade of the individual for the purposes of income tax for any tax year. (3) An election made under this section— (a) must be made by notice given to an officer of Revenue and Customs, and (b) may not be revoked. (4) A notice making an election— (a) must state the tax year for which it is to have effect, and (b) may not be given after 31 January following the end of that tax year. (23K) (1) An individual who is treated as carrying on a trade for a tax year under section 23I is treated as carrying on the trade— (a) wholly in the United Kingdom, if all of the applicable workdays are UK workdays; (b) wholly outside the United Kingdom, if all of the applicable workdays are not UK workdays; (c) otherwise, partly in the United Kingdom and partly outside the United Kingdom. (2) Where the trade is treated as carried on partly in the United Kingdom and partly outside the United Kingdom, the amount to be treated as the profits arising from the part of the trade treated as carried on in the United Kingdom is the sum of the non-qualifying profits of that part of the trade and 72.5% of the qualifying profits of that part of the trade. (3) In subsection (2)— (a) the amount of the non-qualifying profits of the part of the trade treated as carried on in the United Kingdom is the proportion of the non-qualifying profits of the trade (determined in accordance with section 23I(3)(a)) that is the same as the proportion of the applicable workdays that are UK workdays (but see subsection (4)); (b) the amount of the qualifying profits of the part of the trade treated as carried on in the United Kingdom is the proportion of the qualifying profits of the trade (determined in accordance with section 23I(3)(b)) that is the same as the proportion of the applicable workdays that are UK workdays (but see subsection (5)). (4) For the purposes of subsection (3)(a) in a case where— (a) the individual is a non-UK resident for the tax year, and (b) any of the non-qualifying profits of the trade are anticipated qualifying profits, any UK workday in a non-UK tax year is not to be treated as a UK workday (but remains an applicable workday) for the purposes of determining the proportion of the anticipated qualifying profits that is an amount of non-qualifying profits of the part of the trade treated as carried on in the United Kingdom. (5) For the purposes of subsection (3)(b) in a case where the individual is a non-UK resident for the tax year, the following days are not to be treated as UK workdays (but remain applicable workdays)— (a) any UK workday prior to 30 October 2024; (b) any UK workday in a non-UK tax year; (c) any UK workday prior to a period of 3 or more non-UK tax years. (6) For the purposes of this section— (a) a day is an “applicable workday” if it is a day in the relevant period on which the individual performs any investment management services directly or indirectly in respect of an investment scheme (whether or not under the arrangements mentioned in section 23I(1)(a)); (b) a day is a “UK workday” if it is a day in the relevant period on which the individual spends more than 3 hours performing any investment management services directly or indirectly in respect of an investment scheme (whether or not under those arrangements) in the United Kingdom; (c) a year is a “non-UK tax year” if the individual is a non-UK resident for the tax year and there are fewer than 60 UK workdays in the year; (d) non-qualifying profits are “anticipated qualifying profits” if, on the first UK workday in the relevant period, it was reasonable to assume that they would be qualifying profits. (7) For the purposes of subsection (6) the “relevant period” is the period— (a) beginning with the later of— (i) the day on which the first external investor was admitted to any scheme from which the individual is entitled to carried interest under the arrangements mentioned in section 23I(1)(a), and (ii) the first day on which the individual performs any investment management services directly or indirectly in respect of an investment scheme under the arrangements; (b) ending with the earlier of— (i) the last day in the tax year for which the individual was treated as carrying on the trade under section 23I on which a sum of carried interest arose to the individual from an investment scheme under the arrangements for the purposes of that section, and (ii) the last day on which the individual performed any investment management services directly or indirectly in respect of an investment scheme under the arrangements. (8) For the purposes of subsection (6)— (a) investment management services performed by an individual in the course of travelling to or from the United Kingdom by air or sea or via a tunnel under the sea are assumed to be performed overseas even during the part of the journey in or over the United Kingdom, and (b) travelling to or from the United Kingdom is taken to— (i) begin when the individual boards the aircraft, ship or train that is bound for a destination in the United Kingdom or (as the case may be) overseas, and (ii) end when the individual disembarks from that aircraft, ship or train. (23L) (1) This section applies where— (a) the individual referred to in section 23I(1)(a)has died, and (b) as a result, one or more sums that would have been sums of carried interest arising to the individual from an investment scheme under the arrangements arise instead to another person in a tax year. (2) For the purposes of sections 23I and 23K— (a) the sums are treated as if they had arisen to the individual in the tax year in which they arose to the other person, (b) the other person is treated as carrying on the trade under section 23I for that tax year (instead of the individual), and (c) the other person is treated as the person receiving or entitled to the profits of that trade. (23M) (1) This section applies where, on the disposal of an asset by an individual who was temporarily non-resident in tax year 2025-26 or earlier, a gain accrued to the individual in the temporary period of non-residence under section 103KA(2) or (3) of TCGA 1992 (as it then had effect). (2) For income tax purposes— (a) the individual is treated as carrying on a trade for the period of return, (b) the amount to be treated as the profits of the trade for the period of return is 72.5% of the amount of the gain which accrued to the individual in the temporary period of non-residence, and (c) the individual is treated as the person receiving or entitled to those profits. (3) For the purposes of this section, “the period of return”, “temporarily non-resident” and “the temporary period of non-residence” have the meanings given by Part 4 of Schedule 45 to FA 2013 (statutory residence test: anti-avoidance). (23N) (1) For the purpose of section 23I the amount of any “permitted deduction” for a tax year is— (a) the amount of any consideration given by or on behalf of the individual wholly and exclusively for the entitlement to carried interest under the arrangements referred to in section 23I(1)(a), minus (b) the amount of any such consideration deducted in calculating the profits of a trade that the individual is treated as carrying on under section 23I for an earlier tax year by virtue of those arrangements. (2) In subsection (1), “consideration” means consideration in money or money’s worth but does not include the performance of any investment management services directly or indirectly in respect of an investment scheme. (3) For the purposes of this Act no other deduction may be made from the amount treated as the profits of the trade under section 23I. (23P) (1) In determining whether section 23I applies in relation to an individual, no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that that section does not to any extent apply in relation to— (a) the individual, or (b) the individual and one or more other individuals. (2) In determining whether an individual falls within paragraph (a) of section 23I(1), no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that the individual falls within that paragraph. (23Q) (1) Subsection (2) applies where— (a) an individual performs investment management services directly or indirectly in respect of an investment scheme under arrangements mentioned in section 23I(1)(a), and (b) the individual is entitled to carried interest under the arrangements. (2) No income tax is chargeable on the individual by virtue of the individual’s entitlement to carried interest other than— (a) income tax chargeable in respect of carried interest arising to the individual under the arrangements— (i) by virtue of section 23I or 23M, (ii) by virtue of section 62 (earnings) or Part 7 of ITEPA 2003 (employment income relating to securities), or (iii) where an election made under section 23J has effect for a tax year, otherwise under this Part, or (b) income tax chargeable in respect of— (i) the award of the entitlement to carried interest to the individual, or (ii) the individual’s acquisition of the entitlement to carried interest, whether by virtue of section 62 (earnings) or Part 7 of ITEPA 2003 (employment income relating to securities) or otherwise. (3) Subsection (4) applies where— (a) an individual is chargeable to income tax and national insurance contributions by virtue of section 23I or 23M in respect of a sum of carried interest arising to the individual from an investment scheme, and (b) at any time any other UK tax or national insurance contributions charged on any person— (i) in relation to the sum mentioned in paragraph (a), or (ii) or in respect of any person’s entitlement to that sum, has or have been paid and not repaid. (4) The individual may make a claim for one or more consequential adjustments to be made in respect of the profits chargeable by virtue of section 23I or 23M to take account of the amounts paid as mentioned in subsection (3)(b). (5) On a claim under this section an officer of Revenue and Customs must make such of the consequential adjustments claimed (if any) as are just and reasonable. (6) Consequential adjustments in respect of the profits chargeable by virtue of section 23I or 23M must not have the effect that— (a) the total of— (i) the amount of income tax and national insurance contributions charged on the adjusted profits by virtue of section 23I or 23M, and (ii) any amounts paid as mentioned in subsection (3)(b), is less than (b) the amount of income tax and national insurance contributions to which the individual was chargeable by virtue of section 23I or 23M in respect of the sum of carried interest before the making of any consequential adjustments. (7) Consequential adjustments may be made— (a) in respect of any period, (b) by way of an assessment, the modification of an assessment, the amendment of a claim, or otherwise, and (c) despite any time limit imposed by or under an enactment. (8) In this section “UK tax” means income tax, corporation tax, capital gains tax or inheritance tax. (9) For the purposes of section 9(2) of TIOPA 2010 (unilateral entitlement to credit for non-UK tax corresponding to capital gains tax), in a case where the capital gain mentioned in subsection (2)(b) of that section accrued on a sum of carried interest arising to an individual, the reference to capital gains tax calculated by reference to that gain is to be read as if it were a reference to income tax chargeable under section 23I in respect of the sum of carried interest. (23R) (1) In this section, this group of sections and Schedule A1— - “AIF” has the meaning given by regulation 3 of the Alternative Investment Fund Managers Regulations 2013 and includes—arrangements which permit an external investor to participate in investments acquired by the AIF without participating in the AIF itself, andarrangements under which sums arise to an individual performing investment management services in respect of the AIF without those sums arising from the AIF itself; - “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable); - “collective investment scheme” has the meaning given by section 235 of FISMA 2000 and includes—arrangements which permit an external investor to participate in investments acquired by the collective investment scheme without participating in the scheme itself, andarrangements under which sums arise to an individual performing investment management services in respect of the collective investment scheme without those sums arising from the scheme itself; - “external investor”, in relation to an investment scheme and any arrangements, means a participant in the scheme other than—an individual who at any time performs or is to perform investment management services directly or indirectly in respect of the scheme, ora person through whom sums are to, or may, arise directly or indirectly to such an individual from the scheme under the arrangements; - “investment management services”, in relation to an investment scheme, includes—the provision of investment advice,seeking funds for the purposes of the scheme from participants or potential participants,researching potential investments to be made for the purposes of the scheme,acquiring, managing or disposing of property for the purposes of the scheme,acting for the purposes of the scheme with a view to assisting a body in which the scheme has made an investment to raise funds, andany activity incidental or ancillary to any activity mentioned in paragraphs (a) to (e); - “investment scheme” means—a collective investment scheme, oran AIF, or any part of an AIF, that is not a collective investment scheme; - “participant”, in relation to an investment scheme, means a person taking part in the scheme, whether by becoming the owner of, or of any part of, the property that is the subject of the scheme or otherwise; - “sum” includes any money or money's worth (and other expressions are to be construed accordingly); - “this group of sections” means sections 23I to 23Q. (2) For the purposes of section 23K and Schedule A1, in determining what it is reasonable to assume in relation to an investment scheme, regard is to be had to all the circumstances including in particular any prospectus or other document which— (a) is made available to external investors in the investment scheme, and (b) on which external investors may reasonably be supposed to have relied or been able to rely.

• (3) In section 7 (income charged), in subsection (1), after “section 23E(1)” insert “, section 23I or section 23M”.

• (4) In section 845H (qualifying foreign income)—

• (a) in row 1 of the table at the end insert “other than profits of such a trade treated as carried on under section 23I”;

• (b) after row 1 of the table insert—

• (5) In Schedule 11—

• (a) Part 1 inserts Schedule A1 to ITTOIA 2005 (Carried interest: interpretation etc.);

• (b) Part 2 contains consequential and connected amendments.

• (6) The amendments made by this section and that Schedule have effect for the tax year 2026-27 and subsequent tax years (but in relation to investment management services whenever performed).

Pensions: abolition of the lifetime allowance charge

59

• (1) Paragraph 134 of Schedule 9 to FA 2024 (power to make further provision in connection with the abolition of the lifetime allowance charge) is amended as follows.

• (2) In sub-paragraph (2)—

• (a) for paragraph (b) substitute—

(b) have effect for the tax years 2024-25 and 2025-26 (as well as subsequent tax years);

• (b) in paragraph (d), at the end insert “(including any provision that could be made under paragraph 133)”.

• (3) In sub-paragraph (3) omit “that increase any person’s liability to tax”.

• (4) In sub-paragraph (4), for “5 April” substitute “30 June”.

Collective money purchase schemes and Master Trust schemes

60

• (1) Part 4 of FA 2004 (pension schemes) is amended in accordance with subsections (2) to (9).

• (2) In section 153 (registration of pension schemes), in subsection (5)—

• (a) omit the “or” at the end each of paragraphs (f), (g) and (h);

• (b) at the end of paragraph (i) insert

, or (j) the pension scheme is an unauthorised collective money purchase scheme.

• (3) In section 158 (grounds for de-registration), in subsection (1)—

• (a) omit the “or” at the end of each of paragraphs (ea), (f) and (g);

• (b) in paragraph (h), after “that the” insert “pension”;

• (c) at the end of paragraph (h) insert

, or (i) that the pension scheme is an unauthorised collective money purchase scheme.

• (4) For the italic heading before section 274ZA substitute “Master Trust schemes, collective money purchase schemes etc”.

• (5) Before section 274ZA (but after the italic heading) insert—

(274ZZA) (1) In this Part “Master Trust scheme” means (subject to subsections (2) to (4)) a Master Trust scheme within the meaning of PSA 2017 or PSA(NI) 2021. (2) Any provision of PSA 2017 or PSA(NI) 2021 under which a reference to a Master Trust scheme does not include a section of it that is a collective money purchase scheme (within the meaning of that Act) does not apply for the purposes of subsection (1). (3) Section 1(2) of PSA 2017 and section 1(2) of PSA(NI) 2021 (which restrict the meaning of “Master Trust scheme” in the case of schemes that provide benefits other than money purchase benefits) do not apply for the purposes of subsection (1). (4) Where, by virtue of section 40(2) of PSA 2017 or section 40(2) of PSA(NI) 2021, more than one pension scheme is treated as a single Master Trust scheme for the purposes of that Act, each of those pension schemes is a Master Trust scheme for the purposes of this Part. (5) For the purposes of this Part a pension scheme is an “unauthorised Master Trust scheme” if— (a) it is a Master Trust scheme the lawful operation of which, or of any section or part of which, requires authorisation under PSA 2017 or PSA(NI) 2021, or (b) it is not a Master Trust scheme but, by virtue of section 40(1)(a) of PSA 2017 or section 40(1)(a) of PSA(NI) 2021, the lawful operation of the pension scheme, or of any section or part of it, requires authorisation under that Act, and such authorisation has not been granted, or has been granted but has been withdrawn. (6) In this section— - “PSA 2017” means the Pension Schemes Act 2017; - “PSA(NI) 2021” means the Pension Schemes Act (Northern Ireland) 2021. (274ZZB) (1) In this Part “collective money purchase scheme” means (subject to subsection (2)) a collective money purchase scheme within the meaning of Part 1 or 2 of the Pension Schemes Act 2021. (2) A reference in this Part to a collective money purchase scheme is, in relation to a relevant divided pension scheme, a reference to the pension scheme as a whole (and is not a reference to any of its sections considered separately). (3) In this section “relevant divided pension scheme” means a pension scheme which is divided into sections at least one of which is a collective money purchase scheme under subsection (1). (4) For the purposes of this Part a pension scheme is an “unauthorised collective money purchase scheme” if— (a) the lawful operation of the pension scheme, or (in the case of a relevant divided pension scheme) of any section of it, requires authorisation under Part 1 or 2 of the Pension Schemes Act 2021, and (b) such authorisation has not been granted, or has been granted but has been withdrawn. (274ZZC) (1) The Commissioners for His Majesty’s Revenue and Customs may by regulations amend or otherwise modify any provision of this Part in its application in relation to— (a) a collective money purchase scheme, or (b) any benefits payable, or arrangements, under such a pension scheme. (2) Regulations under this section— (a) may make different provision for different cases; (b) may include transitional or saving provision.

• (6) Section 274ZA (National Employment Savings Trust and Master Trust schemes) is amended as follows—

• (a) for the heading substitute “Schemes treated as occupational pension schemes”;

• (b) after subsection (2) insert—

(3) This Part applies in relation to a pension scheme that— (a) is a collective money purchase scheme, and (b) is not an occupational pension scheme, as it applies in relation to an occupational pension scheme.

• (7) In section 279 (other definitions), omit subsections (1B) to (1D).

• (8) In section 280(2) (general index), in the table—

• (a) in the definition of “Master Trust scheme”, for the entry in the second column substitute “section 274ZZA”;

• (b) omit the definition of “unauthorised (in relation to a Master Trust scheme)”;

• (c) at the appropriate places insert—

• (9) In section 282 (orders and regulations), after subsection (1A) insert—

(1B) No regulations may be made under section 274ZZC (power to make provision about collective money purchase schemes) that increase any person’s liability to tax unless a draft of the statutory instrument containing them has been laid before, and approved by a resolution of, the House of Commons.

• (10) In FA 2018, in Schedule 3 (pension schemes), in paragraph 4 (Master Trust schemes registered before passing of FA 2018), in sub-paragraph (2), for “Section 274B(2) of FA 2004 (as inserted by paragraph 1(5))” substitute “Section 274ZA(2) of FA 2004”.

Corporate interest restriction: reporting companies

61

• (1) Schedule 7A to TIOPA 2010 (interest restriction returns) is amended as follows.

• (2) For paragraph 1 (appointment by a worldwide group of a reporting company) substitute—

(1) (1) An interest restriction return for a period of account of a worldwide group is of no effect unless it is submitted to an officer of Revenue and Customs by the reporting company of the group for that period. (2) A member of a worldwide group may appoint a company to be the group’s reporting company for a period of account. (3) The appointment is of no effect for the period of account unless— (a) the company to be appointed as the group’s reporting company for the period is an eligible company for that period, and (b) the appointment is authorised by more than half of the eligible companies for that period. (4) For this purpose a company is “eligible” if and only if the company— (a) was a UK group company at a time during the period of account, and (b) was not dormant throughout that period.

• (3) After that paragraph insert—

(1A) (1) This paragraph applies where a company has purported to submit to an officer of Revenue and Customs a return for a period of account of a worldwide group despite the fact it had not been appointed for the period of account at the time at which it purported to submit the return. (2) A member of the group may, in accordance with paragraph 1, appoint the company as the group’s reporting company for the period of account. (3) If an appointment is made as mentioned in sub-paragraph (2)— (a) the company is to be treated for the purposes of this Part of this Act as if it had been appointed under paragraph 1, and (b) the appointment is to be treated for the purposes of this Part of this Act as if it had been made at the time immediately before the return (or, if more than one, the first return) for the period of account was submitted. (4) But— (a) sub-paragraph (3) does not apply for the purposes of paragraph 11A, and (b) for the purposes of paragraph 6(2), the time of the appointment is taken to be the actual time at which the company was appointed as the group’s reporting company (rather than the time provided for by sub-paragraph (3)(b)).

• (4) For paragraph 2 (revocation by worldwide group of appointment under paragraph 1), substitute—

(2) (1) A member of a worldwide group may revoke an appointment previously made under paragraph 1 in relation to a period of account. (2) The revocation is of no effect for the period of account unless it is authorised by more than half of the eligible companies for that period. (3) For this purpose a company is “eligible” if and only if the company— (a) was a UK group company at a time during the period of account, and (b) was not dormant throughout that period. (4) The revocation of an appointment does not prevent the making of a further appointment under paragraph 1 (whether at the same time as the revocation, or later).

• (5) In paragraph 4 (appointment of reporting company by Revenue and Customs)—

• (a) for sub-paragraph (1) substitute—

(1) This paragraph applies where no interest restriction return in relation to a period of account of a worldwide group (“the relevant period of account”) has been submitted to an officer of Revenue and Customs before the end of the period of 18 months beginning with the end of the relevant period of account.

• (b) in sub-paragraph (4), at the end insert “and supersedes any appointment of a reporting company in relation to that period made under paragraph 1”,

• (c) in sub-paragraph (5), after paragraph (b) insert—

But the time limits provided by paragraph (a) or (b) do not apply where sub-paragraph (6A) applies.

, and

• (d) after sub-paragraph (6) insert—

(6A) If— (a) a company has purported to submit to an officer of Revenue and Customs a return for the relevant period of account despite the fact it had not been appointed for that period at the time at which it purported to submit the return, and (b) no appointment of the company as the group’s reporting company for that period has been made by a member of the group in reliance on paragraph 1A, an officer of Revenue and Customs may, by notice to the company, appoint it to be the group’s reporting company for that period, and sub-paragraphs (3) and (4) apply in relation to that notice and appointment. (6B) The company is to be treated for the purposes of this Part of this Act as if it had been appointed immediately before it submitted the return (or, if more than one, the first return) for the relevant period of account. (6C) But— (a) sub-paragraph (6B) does not apply for the purposes of paragraph 11A, and (b) for the purposes of paragraph 6(2), the time of the appointment is taken to be the actual time at which the company was appointed as the group’s reporting company (rather than the time provided for by sub-paragraph (6B)).

• (6) In paragraph 5 (appointment by officer of Revenue and Customs of replacement reporting company), in sub-paragraph (6)(a), omit sub-paragraph (ii) and the “and” before that sub-paragraph.

• (7) In paragraph 6 (obligation of reporting company to notify group members of its status)—

• (a) in sub-paragraph (2), for “the relevant time” substitute “the appointment is made”, and

• (b) omit sub-paragraphs (3) and (4).

• (8) In paragraph 7 (obligation of reporting company to submit interest restriction return)—

• (a) for sub-paragraphs (1) to (3) substitute—

(1) A reporting company appointed under paragraph 1 in relation to a period of account may submit a return for that period to an officer of Revenue and Customs. (2) A reporting company appointed under paragraph 4 in relation to a period of account must submit a return for that period to an officer of Revenue and Customs. (3) A reporting company appointed under paragraph 5 in relation to a period of account must submit a return for that period to an officer of Revenue and Customs unless a return for the period has already been submitted under sub-paragraph (1) or (2) or this sub-paragraph.

, and

• (b) in sub-paragraph (6), for paragraph (b) substitute—

(b) if the reporting company was appointed under paragraph 4 or 5, the later of— (i) the period mentioned in paragraph (a), and (ii) the end of the period of 3 months beginning with the day on which it was appointed.

• (9) Consequently, the italic heading before that paragraph becomes “Submission of interest restriction returns by reporting companies”.

• (10) In paragraph 8 (revised interest restriction return), in sub-paragraph (3), for paragraph (b) substitute—

(b) if the reporting company was appointed under paragraph 4 or 5, the later of— (i) the period mentioned in paragraph (a), and (ii) the end of the period of 3 months beginning with the day on which it was appointed.

• (11) In paragraph 10 (meaning of “consenting company” and “non-consenting company”)—

• (a) in sub-paragraph (2)—

• (i) in paragraph (a), for “the appropriate persons” substitute “the reporting company in relation to the period of account”, and

• (ii) in paragraph (b), for “the appropriate persons” substitute “the reporting company”, and

• (b) omit sub-paragraph (3).

• (12) Omit paragraph 11 (company authorising reporting company appointment treated as consenting company) together with the italic cross-heading before it.

• (13) After paragraph 11 insert—

(11A) (1) A company is liable to a penalty if the company has purported to submit to an officer of Revenue and Customs a return for a period of account of a worldwide group in circumstances where it had not been appointed for the period of account at the time at which it submitted the return. (2) The penalty is £1,000. (3) If a company becomes liable to a penalty under this paragraph, an officer of Revenue and Customs must— (a) assess the penalty, and (b) notify the company. (4) The assessment must be made within the period of 12 months beginning with the day on which a company is (after the time mentioned in sub-paragraph (1)) appointed as the group’s reporting company for the period of account. (5) A company may, by notice, appeal against a decision of an officer of Revenue and Customs that a penalty is payable under this paragraph. (6) Notice of appeal under this paragraph must be given— (a) within 30 days after the penalty was notified to the company, (b) to the officer of Revenue and Customs who notified the company. (7) A penalty under this paragraph must be paid before the end of the period of 30 days beginning with— (a) the day on which the company was notified of the penalty, or (b) if notice of appeal against the penalty is given, the day on which the appeal is finally determined or withdrawn. (11B) (1) Liability to a penalty under paragraph 11A does not arise if, in reliance on paragraph 1A, a company is, at any time up to the end of the period of 18 months after the end of the period of account, appointed as the group’s reporting company for the period of account. (2) Liability to a penalty under paragraph 11A also does not arise if— (a) without being prompted by an officer of Revenue and Customs to do so, the company notified an officer of Revenue and Customs of the circumstances mentioned in paragraph 11A(1), or (b) there is a reasonable excuse for failing to appoint a reporting company before the return was submitted. (3) If there is a reasonable excuse for the failure but the excuse has ceased, the excuse is to be treated as having continued if a reporting company is appointed without unreasonable delay after the excuse ceased.

• (14) In paragraph 20 (required contents of interest restriction return: full returns and abbreviated returns)—

• (a) in sub-paragraph (3)—

• (i) before paragraph (a) insert—

(za) state the name and (where it has one) the Unique Taxpayer Reference of the reporting company,

• (ii) in paragraph (c), at the end insert “and whether it authorised the appointment of the reporting company for the period of account”, and

• (iii) after that paragraph insert—

(ca) contain a statement that each of the companies authorising the appointment of the reporting company was an eligible company and that they together constituted more than half of the eligible companies,

, and

• (b) in sub-paragraph (5), for “(a) to (c)” substitute “(za) to (ca)”.

• (15) In paragraph 29 (penalty for failure to deliver return)—

• (a) in sub-paragraph (1)(a), at the beginning insert “submits or”, and

• (b) for sub-paragraph (4) substitute—

(4) The assessment must be made— (a) within the period of 12 months beginning with the day on which the return was received by an officer of Revenue and Customs, or (b) if no return is received by an officer of Revenue and Customs, the period of 12 months beginning with the filing date mentioned in sub-paragraph (1)(b).

• (16) In paragraph 44 (enquiry into return for wrong period or wrong group)—

(1A) Sub-paragraph (1) applies even if the company submitting the return had not been appointed as a reporting company for the period of account for which the return was submitted; and references to a reporting company in paragraph 40, and elsewhere in this Schedule where the context is an enquiry into the return, are to the company who submitted the return.

• (17) In paragraph 56 (power of Revenue and Customs to make determinations where no return filed etc), in sub-paragraph (4)(a), after “has effect” insert “under paragraph 4 or 5”.

• (18) In paragraph 61 (provision of information between members of group where no reporting company appointed), for sub-paragraph (2) substitute—

(2) Condition A is that no appointment of a reporting company in relation to the period of account has been made before the end of the period of 12 months beginning with the end of the period of account.

• (19) The amendment made by subsection (3) has effect in relation to periods of account ending on or after 31 March 2024 (except so far as it relates to the new paragraph 11A of Schedule 7A to TIOPA 2010).

• (20) The amendments made by subsection (14) have effect in accordance with provision made by regulations made by the Commissioners for His Majesty’s Revenue and Customs.

• (21) The remaining amendments made by this section have effect in relation to periods of account ending on or after 31 March 2026.

Corporate interest restriction: capital expenditure and tax-EBITDA calculation

62

• (1) In section 407 of TIOPA 2010 (amounts not brought into account in determining a company’s tax-EBITDA)—

• (a) in subsection (1)(b) (allowances or charges under CAA 2001), at the end insert “or capital expenditure for which a deduction is given under a relevant enactment”, and

• (b) after subsection (1) insert—

(1A) For the purposes of subsection (1)(b) “relevant enactment” means— (a) section 86A of CTA 2009 (contributions to flood and coastal erosion risk management projects); (b) section 142 of CTA 2009 (waste disposal site preparation expenditure); (c) section 145 of CTA 2009 (waste disposal site restoration payments); (d) section 147 of CTA 2009 (cemeteries and crematoria).

• (2) The amendments made by this section have effect in relation to periods of account ending on or after 31 December 2021.

• (3) An interest restriction return which is revised to take account of the amendments made by this section is, despite paragraph 8(3) of Schedule 7A to TIOPA 2010, of effect if the revised return is received by an officer of Revenue and Customs before 1 October 2026.

Avoidance schemes involving certain non-derecognition liabilities

63

• (1) In Part 20 of CTA 2009 (general calculation rules), in Chapter 1 (restriction of deductions), after section 1305A insert—

(1305B) (1) This section applies if— (a) assets (“the underlying assets”) are transferred to a relevant entity, (b) for accounting purposes following the transfer— (i) the underlying assets continue to be recognised to any extent by a member of the transferor group, and (ii) a liability is also recognised by a member of the transferor group in connection with the underlying assets or otherwise in connection with the transfer, (c) in calculating a company’s profits for corporation tax purposes a deduction would (ignoring this section) be allowed for a loss, expense or debit in connection with the liability mentioned in paragraph (b)(ii), and (d) the loss, expense or debit arises, to any extent, as a result of arrangements (whether or not they are or include the transfer mentioned in paragraph (a)) where the main purpose, or one of the main purposes, of any party to the arrangements in being a party to them is to secure a tax advantage for any person. (2) The deduction mentioned in subsection (1)(c) is not allowed so far as it is attributable on a just and reasonable apportionment to the purpose mentioned in subsection (1)(d). (3) For the purposes of the condition in subsection (1)(b) it does not matter whether the assets recognised as mentioned in subsection (1)(b)(i) and the liability recognised as mentioned in subsection (1)(b)(ii)— (a) are recognised immediately after the transfer or only later; (b) are first recognised at the same time or at different times; (c) are recognised by the same member of the transferor group as they were before the transfer. (4) For the purposes of subsection (1) the circumstances in which assets are “transferred” to a relevant entity include circumstances in which— (a) a right to income deriving from the assets is transferred to the relevant entity; (b) a contract is entered into to pay the relevant entity income deriving from the assets; (c) the assets, or income deriving from them, come to be held in trust for the benefit of the relevant entity. (5) In this section— - “arrangements” includes any scheme, arrangement or understanding of any kind, whether or not legally enforceable, involving a single transaction or two or more transactions; - “member of the transferor group” means any of the following—the person who transferred the underlying assets as mentioned in subsection (1)(a);a company that is connected with the person mentioned in paragraph (a) and is not the relevant entity mentioned in subsection (1)(a);a transparent entity in which the person mentioned in paragraph (a) or a company falling within paragraph (b) has an interest; - “relevant entity” means—a securitisation company within the meaning of Chapter 4 of Part 13 of CTA 2010, orany person that is a party to the same capital market arrangement (within the meaning of paragraph 1 of Schedule 2A to the Insolvency Act 1986) as such a company; - “transparent entity” means anything that—may be treated as an entity for accounting purposes, andis not chargeable to corporation tax or income tax as a person (ignoring any exemptions). (6) The following apply for the purposes of this section— - section 1122 of CTA 2010 (“connected” persons) - section 1139 of CTA 2010 (“tax advantage”).

• (2) The amendment made by this section has effect in relation to accounting periods beginning on or after 26 November 2025; and for that purpose an accounting period beginning before and ending on or after that date is treated as if so much of the period as falls before that date, and so much of the period as falls on or after that date, were separate accounting periods.

Energy (oil and gas) profits levy: decommissioning relief agreements

64

• (1) In section 80 of FA 2013 (decommissioning relief agreements), after subsection (4) insert—

(4A) No payment is to be made to a company under a decommissioning relief agreement by reference to the energy (oil and gas) profits levy. (4B) Every decommissioning relief agreement (whenever entered into) is to be read accordingly.

• (2) The amendment made by subsection (1) has effect in relation to claims under decommissioning relief agreements made in relation to decommissioning expenditure incurred on or after 26 November 2025.

Part 2 — Inheritance tax

Agricultural property relief and business property relief

Agricultural property relief and business property relief etc

65

Schedule 12 makes provision—

• (a) limiting agricultural property relief and business property relief, and

• (b) extending Schedule A1 to IHTA 1984 (overseas property not excluded property if value attributable to UK residential property) to UK agricultural property.

Pension interests

Tax to be charged on certain pension interests

66

In IHTA 1984, before section 151 (but after the italic heading that precedes it) insert—

(150A) (1) For the purposes of this Act a member of a registered pension scheme, a qualifying non-UK pension scheme or a section 615(3) scheme is treated as beneficially entitled immediately before their death to property (“notional pension property”) by reference to the arrangements under the scheme as they stand at that time. (2) The value of the member’s notional pension property in relation to the scheme is calculated as follows— - Step 1For each money purchase arrangement under the scheme add together—the value of any property that—is held in a pension pot, andmay or must be used to provide benefits under the arrangement on the death of the member, andthe value of any property that—is not held in a pension pot, andmay be and can reasonably be expected to be used to provide benefits under the arrangement on the death of the member,then deduct the value of any property within paragraph (a) or (b) that may only be used to provide an excluded benefit. - Step 2For each defined benefits arrangement under the scheme add together—the amount of any benefit that must be paid as a lump sum death benefit under the arrangement on the death of the member,the amount of any benefit not within paragraph (a) that may be and can reasonably be expected to be paid as a lump sum death benefit under the arrangement on the death of the member, andthe amount of any benefit that may be and, assuming that the maximum amount possible is paid as a lump sum death benefit, can reasonably be expected to be paid as a scheme continuation payment under the arrangement on the death of the member,then deduct the amount of any benefit within paragraph (a), (b) or (c) that may only be paid as an excluded benefit. - Step 3Add together each of the amounts given at Steps 1 and 2. (3) In determining for the purposes of subsection (2) any question as to what can reasonably be expected, regard is to be had (in particular) to appropriate actuarial assumptions. (4) Except under this section, no interest in or under a registered pension scheme, a qualifying non-UK pension scheme or a section 615(3) scheme is taken into account for the purposes of this Act in determining the value of the estate of a member of the scheme immediately before their death. (5) For the purposes of section 6 (excluded property), notional pension property in relation to a pension scheme is regarded as situated in the country or territory in which the scheme is established. (6) In subsection (2)— - “excluded benefit”, in relation to a pension scheme, means a benefit that may only be paid under the scheme as one or more of the following—a dependants’ scheme pension;a trivial commutation lump sum death benefit whose payment to a person extinguishes the person’s entitlement to a dependants’ scheme pension;a dependants’ annuity, or a nominees’ annuity, that was purchased together with a lifetime annuity payable to the member (and for that purpose “purchased together” is to be construed in accordance with paragraphs 17(1A) and 27AA(2) of Schedule 28 to the Finance Act 2004);any amount that—is payable as a benefit (in any form) in respect of a member of the scheme if the member is in employment or other work of a particular description immediately before their death, andis not payable as a benefit (in any form) in respect of a member of the scheme if the member does not meet those conditions; - “held in a pension pot” means available for the purpose of providing benefits to or in respect of one specific member of the scheme; - “scheme continuation payment” means a payment made—in relation to a registered pension scheme, in accordance with pension rule 2 in section 165(1) of the Finance Act 2004 (continuing payments after death);in relation to a qualifying non-UK pension scheme or a section 615(3) scheme, in such a way as would be in accordance with that rule if the scheme in question were a registered pension scheme. (7) Each of the following has the same meaning in this section as in Part 4 of the Finance Act 2004 (pension schemes etc)— - “arrangement” (see section 152(1) of that Act); - “defined benefits arrangement” (see section 152(6) of that Act); - “dependants’ annuity” (see paragraph 17 of Schedule 28 to that Act); - “dependants’ scheme pension” (see paragraph 16 of Schedule 28 to that Act); - “lifetime annuity” (see paragraph 3 of Schedule 28 to that Act); - “lump sum death benefit” (see section 168(2) of that Act); - “money purchase arrangement” (see section 152(2) of that Act); - “nominees’ annuity” (see paragraph 27AA of Schedule 28 to that Act); - “trivial commutation lump sum death benefit” (see paragraph 20 of Schedule 29 to that Act); but for the purposes of this section those definitions are to be read with any necessary modifications in applying them to a qualifying non-UK pension scheme or a section 615(3) scheme.

Liability for tax on pension interests

67

• (1) IHTA 1984 is amended as follows.

• (2) For section 210 substitute—

(210) (1) This section applies to any tax that is attributable to the value of notional pension property of a deceased member of a registered pension scheme, a qualifying non-UK pension scheme or a section 615(3) scheme. (2) For the purposes of this Part the tax is treated as also attributable to the value of— (a) any property held for the purposes of the scheme that is available for paying a benefit on the deceased’s death, except so far as the property may only be used to provide an excluded benefit, or an exempt benefit, on the deceased’s death, and (b) any property that is received by a person under the scheme as a benefit on the deceased’s death, other than an excluded benefit or an exempt benefit. (3) The persons liable for the tax (as well as including a person within section 200(1)(c) (person in whom property is vested etc))— (a) include the deceased’s personal representatives so far as they are not already liable under section 200(1)(a), (b) where the scheme is a registered pension scheme, include the scheme administrator where— (i) a benefit has been paid in breach of section 226A (withholding of benefits), or (ii) the scheme administrator has failed to comply with section 226B (direct payment of tax on receipt of notice), and (c) where the scheme is a registered pension scheme or a section 615(3) scheme, do not (despite section 200(1)(b) and (c)) include the trustees of the scheme (if there are any) or any other person who holds property for the purposes of the scheme in question. (4) Where the scheme administrator is liable for tax by virtue of subsection (3)(b)(ii) (and not by virtue of subsection (3)(b)(i)), their liability is limited to the amount of tax that they have failed to pay as required under section 226B. (5) Sections 271 to 272C of the Finance Act 2004 (liability of scheme administrator) apply in relation to a liability under this Act as they apply in relation to a liability under Part 4 of that Act. (6) Subsection (3)(c) does not prevent a person from being liable to tax— (a) under subsection (3)(b) in their capacity as scheme administrator, or (b) by virtue of subsection (5). (7) In this Act “exempt benefit”, in relation to a pension scheme and a deceased member of the scheme, means a benefit paid under the scheme if and so far as the payment renders the transfer of value made on the deceased’s death an exempt transfer. (8) For provision under which a payment of a benefit renders the transfer of value on death an exempt transfer to the extent of the payment, see— - section 18 (transfers between spouses or civil partners); - section 23 (gifts to charities or registered clubs); - section 24 (gifts to political parties); - section 24A (gifts to housing associations); - section 25 (gifts for national purposes etc); - section 27 (maintenance funds for historic buildings etc).

• (3) In section 211 (burden of tax on death), for subsection (3) substitute—

(3) If— (a) personal representatives pay an amount of tax, (b) the amount does not fall to be borne as part of the general testamentary and administration expenses of the estate, (c) property to whose value the tax is attributable is vested in someone other than the personal representatives (“the vestee”), and (d) the personal representatives cannot recover the amount by deducting it from any sums payable to the vestee out of the estate (whether because there are no sums so payable or because such sums are insufficient or have already been paid without deduction), the vestee must repay the amount to the personal representatives.

• (4) In section 212 (powers to raise tax), in subsection (1), for “or any part of it” substitute “, any property derived from that property, or any part of that property or of property derived from it”.

• (5) In section 239 (certificates of discharge), after subsection (4) insert—

(4A) If— (a) the personal representatives of a deceased person are given a certificate under subsection (2), and (b) further property is afterwards shown to have been included in the estate of the deceased immediately before their death by virtue of section 150A(1) (notional pension property), then despite subsection (4)(b) the personal representatives are not liable for any tax attributable to that further property unless the failure to disclose the property in the application under subsection (2) was due to carelessness on the part of the personal representatives.

Withholding of benefits and payment of tax by pension scheme administrator

68

In IHTA 1984, after section 226 insert—

(226A) (1) The personal representatives of a deceased person may give a notice to the scheme administrator of a registered pension scheme if they know that they are, or have reason to believe that they may be, liable for tax attributable to notional pension property of the deceased in relation to the scheme. (2) A prospective personal representative of a deceased person may give a notice to the scheme administrator of a registered pension scheme if they have reason to believe that, on becoming a personal representative, they would be, or might be, liable for tax attributable to notional pension property of the deceased in relation to the scheme. (3) In this section “withholding notice” means a notice under subsection (1) or (2). (4) While a withholding notice has effect, no benefit may be paid under the scheme to a person (“P”) if— (a) the total amount of benefits previously paid under the scheme to P on the deceased’s death exceeds 50% of P’s benefit entitlement, or (b) the payment of the benefit would result in the total amount of benefits paid under the scheme to P on the deceased’s death exceeding 50% of P’s benefit entitlement. (5) In subsection (4) a person’s “benefit entitlement” means so much of the value of the notional pension property of the deceased in relation to the scheme as is attributable on a just and reasonable apportionment, having regard to appropriate actuarial assumptions, to benefits that have been paid, or are or will be payable, to that person. (6) Subsection (4) does not apply to the payment of an excluded benefit or an exempt benefit. (7) A withholding notice has effect from the time when it is received by the scheme administrator until the earliest of the following— (a) any time when it is withdrawn by — (i) the personal representatives, or (ii) if the person who gave the notice was a prospective personal representative, that person; (b) any time when all the tax attributable to notional pension property of the deceased in relation to the scheme, and any interest due in respect of that tax, is paid; (c) 15 months after the end of the month in which the deceased died. (8) A withholding notice does not have effect unless it complies with any requirements prescribed by the Commissioners for His Majesty's Revenue and Customs as to form and content. (9) The rules of a registered pension scheme are void so far as they purport to require a benefit to be paid in breach of subsection (4). (10) A payment that would fall due but for a withholding notice instead falls due immediately after the notice ceases to have effect. (11) For the consequences if a benefit is paid in breach of subsection (4), see section 210(3)(b) (joint liability of scheme administrator). (12) In this section— - “prospective personal representative”, in relation to a deceased person, means a person who has reason to believe that they will become a personal representative of that person; - “registered club” has the same meaning as in Chapter 9 of Part 13 of the Corporation Tax Act 2010. (226B) (1) A person (“the taxpayer”) may by notice (a “payment notice”) require the scheme administrator of a registered pension scheme to pay any tax for which the taxpayer is liable and which is attributable to the value of the notional pension property of a deceased member of the scheme. (2) The scheme administrator must pay the amount of tax specified in a payment notice before the end of the period of 35 days beginning with the day on which they receive the notice, unless the notice— (a) is withdrawn by the taxpayer during that period (and before the amount is paid), or (b) does not comply with the requirements of subsection (3), or ceases to comply with them during that period (and before the amount is paid). (3) The requirements are— (a) that the payment notice specifies the amount of tax that it requires to be paid; (b) that the amount specified is not less than £1,000; (c) that the amount specified does not exceed the amount of tax for which the taxpayer is liable in respect of notional pension property of the deceased in relation to the scheme; (d) that where the taxpayer is a beneficiary the amount specified does not exceed the difference between— (i) the amount of the benefits payable to the beneficiary under the scheme on the deceased’s death, and (ii) the amount that has already been paid on the deceased’s death in benefits to or for the benefit of the beneficiary under the scheme, or that has already been specified in a payment notice given by the beneficiary in relation to the deceased; (e) that where the taxpayer is the deceased’s personal representatives the amount specified does not exceed the difference between— (i) the amount of the benefits payable under the scheme on the deceased’s death, and (ii) the amount that has already been paid on the deceased’s death in benefits under the scheme, or that has already been specified in a payment notice given by any person in relation to the deceased; (f) that the payment notice complies with any requirements prescribed by the Commissioners for His Majesty's Revenue and Customs as to form and content. (4) The references in subsection (3)(e) to benefits do not include excluded benefits or exempt benefits. (5) The references in subsection (3)(d) and (e) to the amount of benefits payable under the scheme— (a) include any amount that has been or will in future be payable, and (b) in a case where the exact amount of benefits that will in future be payable cannot be known, are to be read as references to the amount that, having regard (in particular) to appropriate actuarial assumptions, can reasonably be expected to be paid. (6) Where the scheme administrator pays an amount of tax under this section, a consequential adjustment may be made, on a basis that is just and reasonable having regard to appropriate actuarial assumptions and to any tax previously paid— (a) where the taxpayer is a beneficiary, to that beneficiary’s entitlement to benefits under the scheme on the deceased’s death; (b) where the taxpayer is the deceased’s personal representatives, to any person’s entitlement to benefits under the scheme on the deceased’s death. (7) Any repayment under section 241 (overpayments) of tax paid by the scheme administrator under this section may, regardless of who the taxpayer is, be paid to— (a) the deceased’s personal representatives, or (b) any of the beneficiaries to whom an officer of Revenue and Customs considers the overpayment of tax to relate (but may not be paid to the scheme administrator). (8) The rules of a registered pension scheme are void so far as they purport to prohibit or restrict— (a) the payment of tax by the scheme administrator as required under this section, or (b) the making of a consequential adjustment under subsection (6) to a person’s entitlement to benefits under the scheme. (9) In this section— - “beneficiary”, in relation to a deceased member of a pension scheme, means a person who receives or has a right to receive benefits under the scheme on the member’s death; - “tax” includes interest on tax. (10) The Treasury may by regulations made by statutory instrument amend the figure for the time being mentioned in subsection (3)(b). (11) A statutory instrument containing regulations under subsection (10) is subject to annulment in pursuance of a resolution of the House of Commons. (12) For the consequences if the scheme administrator fails to comply with this section, see section 210(3)(b) (joint liability of scheme administrator).

Connected amendments to IHTA 1984

69

• (1) IHTA 1984 is amended as follows.

• (2) Omit section 12A (pension drawdown fund not used up: no deemed disposition).

• (3) In section 18 (exemption for transfers between spouses or civil partners), after subsection (3) insert—

(3A) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property— (a) the value transferred is treated for the purposes of this section as also attributable to any property that the person’s spouse or civil partner receives, or has a present or future right to receive, under the scheme on the death of the member otherwise than as an excluded benefit; (b) the estate of the transferor’s spouse or civil partner is treated for the purposes of subsection (1) (so far as would not otherwise be the case) as increased by the value of any property that they receive, or have a right to receive, as mentioned in paragraph (a), and (c) subsection (3) does not apply in relation to the transfer of value.

• (4) In section 23 (gifts to charities or registered clubs), after subsection (5A) insert—

(5B) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property— (a) the value transferred is treated for the purposes of this section as also attributable to any property that on the death of the member is given under the scheme to charities or registered clubs, and (b) subsection (2) does not apply in relation to the transfer of value.

• (5) In section 24 (gifts to political parties), after subsection (4) insert—

(5) To the extent that the value transferred by a transfer of value made on the death of a member of a pension scheme is attributable to the member’s notional pension property— (a) the value transferred is treated for the purposes of this section as also attributable to any property that on the death of the member is given under the scheme to a political party qualifying for exemption under this section, and (b) section 23(2) does not (despite subsection (3)) apply in relation to subsection (1).

• (6) In section 24A (gifts to housing associations), after subsection (3) insert—