James Wild
MP for North West Norfolk · Conservative · United Kingdom
“The Minister failed to respond to any of the questions asked by the shadow Minister, my hon. Friend the Member for Reigate (Rebecca Paul), so I will try again: some companies have expressed an interest in the business, so what discussions is the Minister, or his colleagues, having with potential buyers?”
“Passengers on the Fen line from King’s Lynn are suffering repeated cancellations and an unacceptably poor level of service. Now that the Government control both the track and the trains, will the Transport Secretary intervene and demand a robust action plan to sort out this poor performance?”
“The Hunstanton coastguard rescue officers I have met responded to 150 emergency shouts last year, and the small payment helped them to perform this role for locals and visitors alike.”
“Friend the Member for Keighley and Ilkley spoke about the offensive nature of those letters and their dreadful impact on victims—telling them that in September the first wave of criminals will be released. Others will not yet have been informed.”
“I completely agree with my hon. Friend. The Lady Chief Justice appeared before parliamentary Committees to tell MPs that she could have more sitting days if only the Government would produce, I think, about £20 million of funding—a fairly minimal amount in the scheme of the £1.3 trillion that the Government spend every year—rather than go…”
“It is a privilege to follow my hon. Friend the Member for Keighley and Ilkley (Robbie Moore), whose incredibly powerful speech gave voice to the victims and the impact that the horrific abuse has had on them. He has led on this issue consistently in this House, and his words should carry incredible weight.”
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“Well, as my hon. Friend the Member for Wyre Forest says from a sedentary position, pandemics, wars and energy price shocks did have something to do with the impact, but the figure is a 0.25% rise over the forecast period. The Minister can boast about that growth and say he is going to beat the forecast, but that is the OBR forecast, in black and white, following the decisions in the Budget. The Minister’s comments almost tempt me to push my new clause to a vote, but on balance, I beg to ask leave to withdraw the motion. Clause, by leave, withdrawn.”
“Can he confirm whether the Bill moves us closer to the Government’s 25% reduction target, or further away from that goal?”
“More than 530 pages of the Bill are taken up with technical tax changes and a lot of detailed schedules. Those changes carry a real financial cost, as well as a time cost, as staff will have to focus on them rather than on growing their businesses. That will result in a loss of productivity, particularly in small and medium-sized firms that lack the resources necessary to keep up with the changes. That is precisely why we need a clear assessment of the Bill’s impact on the administrative burden facing businesses. What, if anything, do the Government intend to do to mitigate that? After all the pre-Budget speculation—the column inches, leaks, briefings and counter-briefings—will the Minister, if he does not want me to press the new clause to a vote, provide a combined estimate of how much all the measures in the Bill will cost UK industry?”
“A growing list of quangos are being created: Great British Energy, the Independent Football Regulator, Great British Railways. For every body that they scrap, they seem to create at least one more, and possibly two. Last week, an important National Audit Office report warned that the Government’s regulatory reforms risk doing the opposite of what is intended. It concluded that the cost of new legislation may well outweigh any reduction in administrative burden—that 25% reduction that the Government have committed to, despite not allocating the required savings amounts to Departments. Businesses will be no better off. I am sure that the Public Accounts Committee, of which my hon. Friend the Member for Mid Bedfordshire is a member, will look carefully at that report in holding regulators, Ministers and civil servants to account.”
“The Ministers speak with zeal for deregulation—the Business Secretary is a particular repeat offender—and about the Government’s ambition to cut the administrative burden of regulation by 25% by the end of this Parliament. We know that red tape and regulatory compliance costs out at about 3% to 4% of GDP, which is about £70 billion. We all want to see that cut; it is an issue I have focused on since coming into this House, as I did in my previous roles in the Department for Business, Innovation and Skills. The case for action could not be clearer. However, as is so often the case with this Government, there is a big gap between what they promise and what they deliver. They talk about cutting bureaucracy, but the reality tells a different story.”
“I beg to move, That the clause be read a Second time. New clause 36 would require the Chancellor of the Exchequer to review and report on the effects of the Bill on the administrative burden on businesses, including the impact on small and medium-sized businesses, and any mitigation measures that have been taken. Throughout the Bill’s passage, we have been reminded not only of its financial impacts on businesses and working people, but of the red tape and regulatory cost it piles on to them. Whether it is the new reporting requirements faced by charities, the complex international rules or the new levies, such as the vaping tax and carbon tax, businesses will once again face an increased burden.”
“I thank Billy Falcon in my office, who has done sterling work in pulling together all the evidence from industry and in scrutinising the Bill, helping me to put together my remarks. I know that my hon. Friend the Member for Wyre Forest, the shadow Minister, will want to thank William in his office, who has performed a similar job, at rather short notice as well. He has helped to ensure that we have scrutinised the Bill thoroughly. I am grateful to the Exchequer Secretary and to the City Minister for their responses to our points and our new clauses. I am not sure which one of them I will see in February in King’s Lynn on the dodgems—”
“I am surprised the Minister was able to say that last bit with a straight face when he was corpsing about carbon taxes earlier in Committee. As this will be the final time I speak in Committee, I thank you, Mrs Harris, along with Mr Efford and Sir Roger, for your time in the Chair. I thank the Clerks and officials, all the Members, who contributed so well to the Committee’s deliberations, and our Doorkeepers. I thank the Chartered Institute of Taxation, the Association of Taxation Technicians, the ICAEW and the many other organisations that provided valuable submissions on the provisions of the Bill. In particular, I thank the authors of the TIINs, which I have studied diligently. They do a very good job, but they do not do a review job.”
“Perhaps both—there we go. Any other Members would be welcome to join us as well. I look forward to that. Sadly, the Exchequer Secretary was unable to give me that global figure, so I intend to press the new clause to a vote. Question put, That the clause be read a Second time.”
“Of course, these higher rates come on top of higher employment costs, increased alcohol duties and the new tourist tax on hotels and bed and breakfasts, which UKHospitality warns could cost consumers £518 million, if the mayors take up the powers given to them by the Government. We would take a very different approach. We would deliver permanent 100% business rates relief for retail, hospitality and leisure businesses of up to £110,000, helping around 250,000 small businesses, and we would pay for it by controlling the welfare budget. We believe in backing those taking a risk, employing people and investing.”
“The standard multiplier will be 48p, and the high value multiplier will be 50.8p—an extra 2.8p in the pound. Big online warehouses, with a rateable value of at least £500,000, are supposedly the target, but twice as many retail sites, often acting as anchors for our high streets, will now face this higher rate. That is not what Labour promised before the election. It said it would replace the business rates system, raising the same revenue in a fairer way and levelling the playing field between high streets and online giants. Will the Minister explain why the Government are targeting anchor retail stores that are so important to our wider high streets?”
“It covers just 38,000 out of 750,000 hospitality and leisure businesses—barely one in 20—and it excludes restaurants, cafes, shops, hotels, theatres and all the venues that will have been in touch with members of the Committee. One in four pubs will still pay more overall, even after that relief, and guess what? That relief is only temporary—indeed, a sticking plaster. The Minister previously said there would be no further support for the wider sector. We all hope that he has to come back to the House with that package soon enough, or perhaps the Chancellor will actually do it herself when she delivers her spring update. The draft Local Government Finance Act 1988 (Calculation of Non-Domestic Rating High-Value Multiplier) (England) Regulations 2026 set the rate for the new high value multiplier.”
“Will the Minister tell us what the Government’s estimate—the Valuation Office Agency will undoubtedly have provided one to the Treasury— of the number of businesses that will not get the relief under the discretionary powers that were there in the first place? The rates of the small and standard multipliers are set in separate regulations, so I will not dwell on those, but two months on from the Budget, we have already seen a partial reversal of the plans the Chancellor set out, despite the promises of lower multipliers and lower bills. Ministers may point to their pubs and live music relief as if it solves the problem, but it does not: it is a sticking plaster when there is a major wound that the Chancellor has caused.”
“As the Conservative Party manifesto said, we would: “Continue to ease the burden of business rates for high street, leisure and hospitality businesses”, and our record is one of supporting the sector and the people creating jobs across the country. Under the new system set out in these regulations, combined with the revaluation, businesses across retail, leisure and hospitality face much higher bills, and fewer will benefit compared with the 40% relief, because under that scheme, as is set out in the explanatory notes, local authorities had more discretion over which premises benefited from the relief.”
“What will the result of that be? The Office for Budget Responsibility expects business rate receipts to increase by £3.5 billion next year, a 10% increase in a single year. For small and medium-sized businesses, that is incredibly challenging. The bill of the average independent pub will rocket from £4,000 in 2024-25 to nearly £10,000 by 2028-29, a rise of 144%. The position of shops, hotels and restaurants is even worse than that. At this point, it is usual for Ministers—indeed, for this Minister—to claim that the last Conservative Government would simply have abolished the relief overnight. Of course, that is utter nonsense, and I welcome the opportunity to get that on the record. It is simply a desperate attempt to deflect from what we can see are the bad political choices that the Chancellor and her Ministers have made.”
“That is why I, along with the shadow Housing Secretary and shadow Business Secretary, have written to the Office for Statistics Regulation, as it is statistically misleading to make the claim of record low taxes on the basis of the multipliers, as those are not the tax rates. I was pleased to have confirmation on Friday that the Office for Statistics Regulation is looking into this matter as we speak. I will now turn to the regulations. In their first Budget, the Labour Government chose to cut back retail, hospitality and leisure rate relief introduced by the last Conservative Government from 75% to 40%. That was a tax raise of £1.1 billion a year. Through these measures, they have axed that relief in its entirety, which means higher bills. The Government have also locked in automatic inflation-linked rises every single year.”
“It is a pleasure to see you in the Chair, Mr Mundell. The two sets of regulations together set out the new tiered business rates system for the 2026 financial year. In plain English, the first set of regulations defines who gets which business rates multiplier under the new system, and the second sets out how much large premises will pay. Of course, ahead of the election the now Prime Minister said that there would be a new regime of “permanently lower business rates”. Indeed, the Chancellor said at the Budget, referring to these measures, that these business rates were at their lowest level since 1991. The reality is proving somewhat different. Businesses are facing major increases, and claims to the contrary are false. Their bills are going up.”
“We all know that any fixed monetary threshold in legislation loses its real value over time, but if Ministers believe that £35,000 is the right level today, surely they accept that uprating in line with inflation is only fair. If the Minister will not support that principle outright, perhaps he will commit to supporting new clause 10, which simply asks for a review of the impact of doing so. Schedule 10 allows for the alteration of the limit, but there is no obligation on Ministers, as there is for other benefits, to review the level or uprate the limit.”
“From 2027-28, HMRC will move to in-year coding, meaning that pensioners could start paying back a benefit that they have not even received yet, based on HMRC’s best guess at their income. As we all know, the winter fuel payment is a one-off payment that is usually paid in November, but PAYE collection is spread throughout the year, so pensioners could be having money clawed back that they have not yet received. If that estimate turns out to be wrong, they will have money taken off and refunded later. That is a recipe for potential confusion and hardship, and it could lead to more calls to HMRC that may go unanswered. In the year of transition, some pensioners could face being charged twice in a single tax year. That is not a minor administrative issue. It needs to be addressed.”
“The Bill sets out that the Government’s approach relies heavily on data sharing between the DWP, devolved social security bodies and HMRC. There are some exemptions, for example for those who have been on means-tested benefits during the qualifying week or who have opted out of receiving the payment, but if that information is not shared swiftly and accurately, instances may occur of administrative issues causing distress and financial loss. Pensioners could also see an unexpected tax code on their pay slip, clawing back money that they should never have been charged. That might lead them to have to fight through an appeals process just to claim what is rightfully theirs. The plan to collect the charge through PAYE, as is set out in the clause, brings its own issues.”
“I turn to the points that the Chartered Institute of Taxation and the Low Incomes Tax Reform Group have raised about the clause and the schedule. If a pensioner’s income is £1 over the threshold, they will lose the entire winter fuel payment; there is no taper. Unlike other income-related charge-backs, such as the high-income child benefit charge or the tapering of the personal allowance, the winter fuel payment is based on total income, not adjusted net income. It will affect pensioners who are seeking relief on their charitable contributions. Will the Minister explain why the Government have opted for a system that measures income in inconsistent ways, with different rules from similar income-dependent clawback schemes?”
“The measure flows from one of the Chancellor’s first political choices, which was to remove the winter fuel payment from all pensioners except those in receipt of pensioner credit. That meant that pensioners living on incomes of around £13,000 a year lost their winter fuel support. Vital support was pulled from millions of pensioners across the country. In my constituency, 22,000 pensioners lost their entitlement overnight; the figure may have been similar in your constituency, Mr Efford. It was a deeply damaging move, which is why organisations such as Age UK and my party campaigned against it, and the Chancellor was forced to come back to the Dispatch Box to perform one of her U-turns. In response to the pressure, the Government announced that everyone would get the payment but that it would be clawed back.”
“However, the Chartered Institute of Taxation and the Low Incomes Tax Reform Group have raised concerns about the potential complexity of the clause; about how it could cause anxiety for people who have not had to navigate tax rules before; and about how the £35,000 per year cap will only diminish over time as inflation eats away at it. I have therefore tabled new clause 10, which would require the Government to review the case for uprating the £35,000 threshold by CPI each year, ensuring that it retains its value. I have also tabled amendment 41, which would go further and put that commitment squarely on the face of the Bill so that there can be no ambiguity about whether the level will increase. The Minister skated over a bit of the background to the clause.”
“It is a pleasure to see the Exchequer Secretary in his place. Some Committee members may have felt that his ministerial colleague the Economic Secretary dealt with some clauses rather briefly in our earlier sittings, so we look forward to the loquaciousness that the Exchequer Secretary displayed on the Floor of the House the other day. I shall speak to clause 55 and to amendment 41 and new clause 10 in my name. The clause is about clawing back the winter fuel payment from anyone whose total taxable income is above £35,000. According to the Budget costings, this measure will cost about £1.8 billion in 2025-26, settling at £1.3 billion the year after, but overall the changes that the Government have made with the removal of winter fuel payments will save £450 million.”
“She was wrong to remove the benefit from millions of pensioners. This clause helps her to correct her poor political choice.”
“My hon. Friend makes a valuable point. We want more certainty within the system, as far as possible. On earlier clauses, we debated the uncertainty that can come from having administrative rules that HMRC can interpret. Our amendment would give people confidence that their income and the benefit they receive would continue in real terms. Nobody disputes the need to focus support on those who need it most. Where the Chancellor got it wrong was in taking it away from people who are just over the £13,000 income threshold. If the Government insist on recovering payments, they need to get the fundamentals right, with clear definitions, robust data sharing and a simple route for challenging any mistakes that may have been made. Let us be clear. We welcome the Chancellor’s latest U-turn, reversing the very first decision she took in office.”
“I may not have read that manifesto as closely as the hon. Gentleman. [Laughter.] For the record, I did not say that. I think the record will also prove that that measure was not put into effect. We continued the winter fuel payment. The issue is that the Chancellor came along. She was given advice by Treasury officials—no offence to the Treasury officials in the room—suggesting this was a simple way to save some money and fill a fictional black hole. Foolishly and regrettably, she went along with that advice; happily, she is now correcting her mistake in part. I am looking to press amendment 41 to a vote, because it is important that we give pensioners certainty that the threshold will be protected.”
“It will leave us with one of the highest rates of tax on carried interest among competitive and competitor jurisdictions. We can see why some Labour MPs may be happy about having some of the highest levels of tax on fund managers, but these measures will fundamentally dampen the animal spirits in our economy at a time when we need to be unleashing them. That is why I contend that new clause 11 is essential to ensure that Ministers measure the real-world consequences of their choices before lasting damage is done to our economy.”
“I think that is an understatement; it could be a recipe for disputes and confusion. A further danger is double taxation. The sector has warned that under the rules, some managers could be taxed twice on the same carried interest in different jurisdictions. Can the Minister assure fund managers and the sector that the Treasury has appropriate double taxation agreements and treaties in place to ensure that their concern is ill-founded? If the Government get this wrong, we risk losing capital to countries that do offer such clarity. In debates on earlier clauses, we have spoken about wanting to encourage enterprise and investment, to compete internationally, and to support growth in high-value businesses, but clause 56 sends the opposite signal.”
“For the Minister’s benefit—because he was not in the Committee’s earlier sittings—we have tabled new clauses that would require reviews because a TIIN is a prediction of what might happen, not a review. We are assured that the Treasury keeps all measures under review, so if those reviews are happening, what is the problem with publishing them and giving that information to Parliament? As well as on the principle, we need answers on the implementation. HMRC will now be expected to verify the average holding period of thousands of complex investment portfolios. What additional resources and guidance will be provided to HMRC to do that? How will it cope if receipts are lumpy and unpredictable? UK Private Capital has warned that the measure will be challenging to manage.”
“What would that mean for wider tax receipts, for the thousands of jobs that funds support and those who rely on them, and for the UK’s standing as a global financial hub? TheCityUK and PwC published a significant report at the beginning of this week about measures that need to be taken to ensure that London remains a pre-eminent finance hub. The measures in the clause run counter to that. That is why I have tabled new clause 11, which would require a review of the clause’s impact on UK competitiveness in attracting and retaining fund managers, the level and composition of investment into the UK, and the revenues collected compared with forecast revenues.”
“This measure is a substantial tax rise designed to reclassify carried interest as remuneration, rather than a general return on capital. That may sound tidy in theory, but it misunderstands what carried interest is. As UK Private Capital puts it, carried interest is “fundamentally different” from a salary or a bonus because it is paid only when investments succeed, often many years later and quite often not at all—that is the nature of risk. The famous tax information and impact note expects the measure to raise £145 million in 2027-28 and £80 million in the following year, but there is a risk of driving talent and investment abroad. Can the Minister share his assessment on what happens if fund managers start relocating to other tax regimes such as Dublin, Luxembourg or New York?”
“The precise rate will vary depending on the average holding of the underlying investment; longer holds will receive slightly fairer treatment. Does anyone think that sounds like a measure that is likely to attract talent and investment into the country? As we have discussed in previous sittings, those are things that everyone is signed up to, but many measures in the Bill do not deliver on them. Carried interest is not some mysterious perk; it is a share of profits that fund managers receive only when their investments do well. It is long term, risk based and uncertain. According to UK Private Capital, in most cases it takes seven years or more before a fund pays a penny of carried interest, and quite frequently it never does.”
“I will speak to clause 56, the schedule and new clause 11, which is tabled in my name. The Minister talks of reform; indeed, clause 56 fundamentally changes how carried interest is taxed. New clause 11 proposes a thorough assessment, given the significance of those reforms. Until now, carried interest has been taxed as a capital gain up to 28%. Under clause 56, however, a full 72.5% of qualifying carried interest will be treated as trading income and taxed at income rates that could reach up to 45% plus class 4 national insurance contributions. The effective rate, therefore, would be around 34%. The Minister spoke about competitiveness, but that rate is far above other jurisdictions in Europe—for example, 26% in Italy and 25% in Spain.”
“In the debate on the first clause that we considered in Committee, there was a commitment to keep corporation tax at 25% across this Parliament. Can the Minister at least commit to not further increase the rate of tax on carried interest in this Parliament?”
“What safeguards will be in place to prevent a scheme being authorised by one regulator but not recognised by the other? What steps are in place to ensure that savers—our constituents—are not caught in the middle?”
“That potentially risks creating unfair outcomes for savers in otherwise identical positions. I would be grateful if the Minister could clarify how the Government intend to address that concern raised by the experts. We also know that, under the new guided retirement model expected from 2027, trustees will be making complex decisions on behalf of their members yet, as the Chartered Institute of Taxation notes, trustees will hesitate to act without sufficient flexibility such as limited opt-out periods or conversion options. Those safeguards are notably absent from the clause. Has the Minister, or potentially his colleague the Minister for Pensions, been engaging with the sector on those points? A further practical point, which I hope the Minister will be able to tidy up, concerns the co-ordination between HMRC and the Pensions Regulator.”
“The aim is straightforward: to ensure the alignment of the tax and regulatory frameworks so that only properly supervised schemes benefit from the generous pension tax reliefs. That is a principle that we would all support. Well-regulated CDC—collective defined contribution—schemes could play an important role in the future of workplace pensions, particularly as the next generation of whole-of-life, multi-employer and retired CDC models develop. If done right, that could help savers manage their transition from work to retirement more smoothly, but it will work only if the rules are clear, consistent and fair with the existing annuity structures. As the Chartered Institute of Taxation has highlighted, the current framework does not allow for reductions in pension payments that vary between different groups of members.”
“Clause 57 updates HMRC’s pension rules to align them with the Pension Regulator’s authorisation regime for collective money purchase schemes. Such schemes pool members’ contributions into a single fund, with the benefits linked to the performance of that shared pot rather than a guaranteed payout, as Members will be aware. Master trusts operate on a similar principle, but manage pension savings on behalf of multiple, unconnected employers, each with its own ringfenced section. The clause goes a little further than just a technical update; it gives HMRC new and wide-ranging powers to refuse or remove the tax registration of those schemes, and to change the underlying tax rules through secondary legislation.”
“If the calculation of tax-EBITDA has accidentally penalised spending on projects such as flood defence, waste treatment or crematoriums, are there are other sectors that the Treasury has looked at that might face similar unintended consequences? Are there sectors where the Government think there might be similar distortions, or were others considered and dismissed? How will HMRC manage amended tax returns and claims retrospectively back to 2021? Does it have the resources and processes in place to do that officially? Finally, will the Minister commit to a wider review of the corporate interest restriction rules to ensure that the system generally supports the long-term environmental and infrastructure investment that our economy and our constituencies need?”
“The measure applies retrospectively to periods ending on or after 31 December 2021. On the face of it, this is a sensible change that ensures that the rules operate as intended, and we support the principle behind it. The Government describe this as a largely technical fix, which is broadly correct. It does correct the distortion in the corporate interest restriction rules that discourage capital investment in environmental and infrastructure projects. The Budget documents suggest the fiscal impact is limited, allowing qualifying businesses to claim interest deductions they were previously denied. But it does raise some other questions.”
“Does HMRC have discretion not to apply the penalty automatically, so that it can take into account any mitigating factors? Clause 59 makes a targeted but important change to the way in which companies calculate tax-EBITDA under the corporate interest restriction rules. The clause adjusts the calculation so that certain types of capital expenditure related to cemeteries and crematoriums and environmental and infrastructure spending—such as waste disposal, flood prevention and coastal erosion management—are excluded from the limits on how much interest a group can deduct for tax purposes. In practice, that means that when a company makes large one-off investments in public interest infrastructure, such as new flood defences, those up-front costs will no longer unfairly reduce the amount of interest they are permitted to deduct.”
“Clause 58 makes changes to the corporate interest restriction rules, which limit how much interest large companies can deduct from taxable profits each year. It aims to fix an administrative problem that has frustrated many businesses. Under the CIRR, each group must appoint a reporting company—that is, a UK group member responsible for submitting a group’s interest restriction to HMRC—and the clause simplifies that process, which is obviously welcome. At the same time, the clause introduces a new £1,000 penalty where a group submits a return without any company having been validly appointed to act as the reporting company. That is a small fixed penalty designed to encourage groups to get the appointment right. Can the Minister assure us that this will be applied with some common sense?”
“Can he give the Committee a flavour of how prevalent he thinks that bending or breaking of the rules is? The provisions of this clause seek to correct any rule-breaking by denying tax deductions where their main purpose is to seek to gain a tax advantage by exploiting non-derecognition accounting. The Opposition strongly support efforts to tackle avoidance and close loopholes that undermine trust in the tax system, and efforts to bring the tax gap down—as the last Government successfully did, and this Government are, I am sure, continuing to seek to do—but, as always, the details matter.”
“As the Minister said, the clause introduces a new anti-avoidance provision aimed at arrangements involving non-derecognition liabilities. These are complex structures whereby a company transfers assets to another entity, but under accounting rules continues to recognise those assets and related liabilities on its own balance sheets. Such structures are of course common in securitisations, which are an important part of the UK’s financial landscape. In these arrangements an originating company passes on the economic risks and rewards with an asset, yet maintains the asset on its books. Used properly, these arrangements serve a legitimate commercial purpose. However, as the Minister said, there are examples of people bending or breaking the rules.”
“The Government themselves have acknowledged that we will need oil and gas for decades to come, with about 75% of the UK’s energy still coming from oil and gas and 10 billion to 15 billion barrels required by 2050. Offshore Energies UK has shown that we can produce more than that at home, through tax reform in tandem with a pragmatic approach to decommissioning and licensing, instead of importing more energy and exporting the jobs. That is why new clause 12 would require a proper assessment of the impact on the areas that I have set out. The Chancellor likes to describe the energy profits levy as temporary, but there is nothing temporary about the damage that is being done to jobs, investment and energy security in the North sea.”
“That is important because of the context. The reality in the North sea is stark. Investment has sunk to record lows and, according to research from Robert Gordon University, jobs are being lost at a rate of 1,000 a month. Offshore Energies UK has warned that the Government’s decision in the Budget to reject replacing the energy profits levy in 2026 will cost tens of thousands of jobs, cripple investment and undermine Scotland and its energy security. The decommissioning reliefs to which this clause refers were designed to give long-term certainty on tax treatment in the basin, precisely so that companies could plan for responsible decommissioning.”
“I will speak to clause 61 and new clause 12, tabled in my name. They concern reliefs and the energy profits levy, which the Chancellor increased to 78%—a very high level. When it was introduced, prices were much higher than they are now. Clause 61 clarifies that payments under decommissioning relief agreements—long-term agreements under which the Government guarantee a minimum level of tax relief for decommissioning costs—cannot be claimed by reference to the EPL; and it makes it clear that companies cannot seek refunds or payments when decommissioning costs arose on or after 26 November 2025. New clause 12 is about ensuring that the impact of these changes on decommissioning, employment and capital expenditure in the oil and gas sector, production and demand and the Scottish economy is considered by the Treasury and the Chancellor.”
“The measures that the Government are taking will undermine what we all want to see, which is more money being brought back into the UK and invested in our country. What conversations has the Minister had with groups such as Foreign Investors for Britain about these changes? How would he respond to their concerns?”
“Following the 2024 Budget, the Government decided to implement a long-term residency test for inheritance tax. That is a 10-year residency in a 20-year time period. Clause 70 imposes an inheritance tax charge where there has been a change in the settlor’s long-term residence status. While this is not the 20% exit tax—one of the kites that was flown by someone near the Treasury ahead of the Budget—there is a risk about the message that it sends about encouraging people to this country. The Chartered Institute of Taxation has pointed out that individuals faced with the prospect of UK inheritance tax on their overseas trusts may already have decided to leave the UK and/or wind up the trust, an issue that was debated on Tuesday afternoon in relation to the clauses that pertain to non-doms.”