Dan Tomlinson
MP for Chipping Barnet · Labour · United Kingdom
“I hope that once this Great British summer savings period ends on 1 September, we will review that and look at the impact. Of course, the challenge with any VAT reduction is whether it will be passed on to consumers. To be clear, I do not begrudge businesses having more margin, but the objective of the hon.”
“There are a whole range of challenges and also benefits from the protocol and the Windsor framework. I agree with the hon. Member that they do not provide constraints on the policy choice on VAT.”
“The Barnett formula is applied in the normal way to those changes, so the Northern Ireland Executive received £185 million in consequentials as a result of those decisions.”
“I understand that Members are specifically talking about Northern Ireland, but across the country as a whole—some hon. Members did mention the broader campaign around reductions in VAT across the UK—a reduction to 10% in VAT for hospitality would cost around £11 billion a year, which is equivalent to the total expenditure on the Royal Nav…”
“Right now, we are engaging in what could be seen as a similar proposal to the one put forward today. We are doing a time-limited reduction in VAT, not for one sector and one part of the country, but for particular leisure and hospitality activities and consumption across the country as a whole.”
“The fact that I am not announcing this change today does not mean that the Government do not take this issue seriously and understand the representations being made. We are also not standing aside.”
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“We are also supporting a co-ordinated release of collective International Energy Agency oil reserves, the release of which has helped to stabilise international oil markets.”
“As the Prime Minister has made clear, our priority will always be the national interest through protecting British nationals and supporting our allies. This Government recognise that the conflict is not just a matter of foreign policy, and that it also has direct consequences for individuals and families here in the UK. Movements in global energy markets are likely to put upward pressure on inflation, and the longer this conflict continues, the greater the risk it poses to both economic stability and the cost of living in the UK. That is why the Government are clear that rapid de-escalation remains the best way to protect people from further fuel price increases. We are working with our international partners to support efforts to secure key energy routes and guarantee the security of vessels passing through the strait of Hormuz.”
“I thank hon. Members for their contributions throughout the debate. I thank the hon. Member for Mid Buckinghamshire (Greg Smith) in particular for his winding-up, as well as the Tory Whips for giving me the opportunity to remind the House of his support for Liz Truss as PM. My Parliamentary Private Secretary, my hon. Friend the Member for Hastings and Rye (Helena Dollimore), has just passed me the 10 reasons the hon. Gentleman set out for supporting Liz Truss for PM—I do not know whether that is something he now regrets. I will turn to the serious matter at hand. We are debating this issue at a time of significant international uncertainty. As the House is aware, we are now in our third week of the conflict in Iran and across the middle east.”
“I will come on to talk about fuel duty; I was just setting out the context at the opening of my speech. The Government’s approach is to focus squarely on the British national interest and the economic interests of British households. The Opposition have clearly taken a different approach, choosing instead at times to egg on military action, focusing more on posturing and trying to get one up on the Government than on looking after our own at home and abroad.”
“As I said in a Westminster Hall debate, which some in this Chamber attended, I am always happy to receive representations on whether that scheme should be widened. The hon. Member for Gordon and Buchan (Harriet Cross) asked about the electric vehicle excise duty change that will be introduced in the coming years, and whether it will be extended. No, it will not. The plan is as set out at the Budget last year. Government Members think that it is fair that all vehicles that contribute to the wear and tear on our roads should also contribute towards the repair costs and to the public finances, and they will do so at a lower rate of 3p rather than 6p, which was the average amount paid by those who pay fuel duty.”
“Their plans, which were set out in the official forecast in the run-up to the general election, said that fuel duty would increase by 5p last year—by RPI last year—and then by RPI again this year. We have instead chosen to freeze fuel duty both last year and this year and to maintain the 5p cut until September of this year. The Liberal Democrat spokesperson, the hon. Member for Westmorland and Lonsdale (Tim Farron), and other Members made very important points about the impact of fuel price increases on those in rural communities. He will be aware, as I believe it applies to his constituency and to some of the others mentioned today, of the rural fuel duty relief scheme, which does provide a reduction to motorists in those parts of the country that are more rural.”
“Taken together with decisions made since the 2024 Budget, the Government’s fuel duty freeze will save the average motorist more than £90 compared with the plans that we inherited. Conservative Members, who have made contributions in this debate, stood in the July 2024 general election on spending plans that would have had fuel duty increase by 5p— [Interruption.] Yes, it is true. Unless the Conservatives are disowning the official forecasts that were published before the general election and the manifesto on which they stood—which, by the way, did not mention plans for fuel duty—I think we are again discovering that there were further black holes in the Conservatives’ spending plans.”
“My hon. Friend is right: the Opposition are totally on the wrong side of common-sense public opinion in this country. On the most important of tests, they have failed. He is also right to point out that the fuel duty increase is pencilled in for September, as the Chancellor set out in last year’s Budget. I think it is worth reminding the House that fuel duty right now is lower than it was in 12 of the 14 years of the Conservative Government. In 2010, 2011, 2012 and all the way up to 2022, fuel duty was higher than it is now. In the 2025 Budget, we extended the temporary 5p per litre cut in fuel duty until the end of August this year, and we cancelled the inflation-linked increase that had been planned for 2026-27.”
“It is the right plan, and this Government will stick to it for the good of the British people and this great country that we all serve. Question put (Standing Order No. 31(2)), That the original words stand part of the Question.”
“The Government will continue to take the right decisions, protecting the public finances and supporting families with the cost of living. The previous Government left us with the worst living standards stagnation in memory. A Reform Government would crash the economy just like Liz Truss did, with wild unfunded promises. The Greens would push up energy bills by blocking clean power. This Government reject the chaos offered by Opposition parties. We have an economic plan that is the right one for Britain. Our plan means that we are more prepared for this shock than otherwise, with borrowing falling by 1% of GDP last year, our power supply now less reliant on the gas rollercoaster, living standards rising, inflation falling, and the big and right decision to take £117 off annual energy bills in April yet to come.”
“The EVED charge is on electric cars because they do not pay fuel duty. Petrol cars do pay fuel duty, which, because it is on a litre of petrol, is a charge that is determined by how much someone drives. The hon. Member for Brighton Pavilion (Siân Berry) made some good points about public transport. I congratulate her on getting through the speech after the very large number of interventions that she had to respond to—and she responded to them well. I point out that this Government are introducing the first rail fares freeze in 30 years and that we are investing £38 million to roll out 319 new zero emission buses across England—lots of good things. As ever, decisions on taxation will be taken at the appropriate time, based on the best evidence and with careful regard to the public finances.”
“52(1)(b)), That provision (including provision having effect for the tax year 2025-26) may be made revoking— (a) paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009, and (b) paragraphs (4) to (6) of regulation 21 of those Regulations.— (Dan Tomlinson.) Question agreed to.”
“This technical amendment allows for the introduction of regulations required as part of the abolition of the lifetime allowance, in order to have a retrospective effect going back to the point when the lifetime allowance was originally abolished. That ensures that the changes we are making operate as intended. It is a small and technical measure, but I take the hon. Member’s point that it adds a new part to the Bill and means that a new resolution has been brought forward. I hope that—notwithstanding the valid points raised by the hon. Member—Members will understand that position, and I commend the motion to the House. Question put and agreed to. Finance (No.2) Bill: Ways and Means (Offshore income gains) Motion made, and Question proposed (Standing Order No.”
“I thank the hon. Member for Aberdeen North (Kirsty Blackman) for her remarks, as well as for her scrutiny of this process, which I appreciate no matter where it comes from. The hon. Member is right to flag that this is not the typical process. For future Finance Bills, I will—if I am in my position—endeavour to ensure that Ways and Means motions are not brought at this late stage. She is also right to point out that this debate—although I do not believe that there are any other bobbers—and any debate on the subsequent motion could go on for 45 minutes, and that discussions may ensue. I would be happy to consider the process.”
“That is very significant and means that our borrowing is coming down, as part of our plan to bring stability back to the public finances.”
“As yet, no other Opposition Front Bencher has offered me such an enticing prospect as a visit to their constituency, but I look forward to those invitations. Before I turn to individual amendments, I wish to reflect briefly on the Budget that was delivered in November by my right hon. Friend the Chancellor of the Exchequer. That Budget took fair and necessary decisions to deliver on the Government’s promise of change, to support cuts in the cost of living, to enable NHS waiting lists to continue falling, and to ensure that our national debt fell as a share of GDP and that borrowing falls over the course of this Parliament. As the Chancellor said in this place yesterday and on Monday, Government borrowing—public sector net borrowing—has fallen from 5.2% to 4.3% of GDP, which is a fall of 1 percentage point.”
“I am glad to return to the Commons to debate the Finance Bill on Report. Although I am sure that it would have been of interest to Members on both sides of the House, I am also glad that we have not just had a set of two 45-minute debates on the Ways and Means motions. The opportunity was there, but I am glad that Members did not take it in full. We now have ample time for this important Report stage. I thank Members on both sides of the House for their contributions in Committee. I thank in particular the shadow Exchequer Secretary to the Treasury, the hon. Member for North West Norfolk (James Wild), for his scrutiny and challenge, and for the invitation to his wonderful constituency, which I hope to take up one day.”
“I ask the hon. Member to consider whether his party wishes to identify £66 billion of expenditure cuts or borrow £66 billion more. I do not think that either option is what the British public want; they want us to bring borrowing down and get public finances under control, after they were spun out of control by Liz Truss and the previous Government. The public understand the need for fair and responsible increases in taxation to ensure that we can invest in our public services and in the future of our country.”
“Amendments 49, 50 and 52 are consequential amendments to schedule 3 and clause 43. They remove references to omitted legislation and insert wording to clarify reference to the Taxation of Chargeable Gains Act 1992. Amendment 53 to clause 49 makes clear that a person concluding contracts on behalf of a non-resident company must be present in the UK when concluding those contracts in order to create a permanent establishment in the UK. Amendments 56 to 61 to schedule 11 concern the rules preventing fund managers from circumventing the revised carried interest tax regime. These amendments ensure that the provision operates as intended, where two connected persons work in the same business, with each connected person only taxed on their own carried interest.”
“The Government are making a number of minor and technical amendments to help provide greater clarity and address important points that have been raised by stakeholders, particularly during the passage of the Bill. These amendments simply put the original legislative intent beyond doubt. Amendments 12 and 13 ensure that clause 23 will apply only to general earnings for the tax year 2026-27 and subsequent tax years that are paid on or after 6 April 2026. Amendment 14 tightens the existing provisions under clause 24 to ensure that those rules do not catch legitimate agency structures. Amendments 48 and 51 remove legislation that is not necessary under clause 43 and ensure that the TRF legislation works as intended, so that beneficiaries from overseas trusts are able to make designations in connection with offshore income gains.”
“The amendments also simplify the existing treatment of offshore non-reporting funds held by offshore structures for all taxpayers. New clause 6 introduces transitional provisions for offshore income gains arising before 6 April 2025. Following the abolition of the lifetime allowance, new clause 7, as we were just discussing, ensures that multiple different regimes do not apply, providing clarity for pension schemes and members. It ensures that any necessary regulations can have a retrospective effect back to 6 April 2024, clarifies the scope of the original power, extends the power by a further three months and ensures that regulations are subject to the affirmative parliamentary procedure.”
“I want to clarify that these powers are not designed to penalise responsible tax advisers who act in good faith, and in that specific scenario, a tax adviser would not be penalised under His Majesty’s Revenue and Customs’ stronger powers. The Government are committed to ensuring that the tax system works effectively for everyone, which is why we are introducing a number of amendments on Report to ensure that the tax system is working effectively and as intended. I turn to the first group of Government amendments. New clause 5 removes specific provisions that could prevent offshore income gains from being designated under the temporary repatriation facility, or TRF, to ensure that they can be designated as intended.”
“We are also providing stability for businesses by keeping to important commitments in our corporate tax road map to keep our corporation tax rate at 25%—the lowest in the G7—rather than having it chop and change up and down, like it did during previous Administrations. I thank all those who have submitted written evidence throughout the Bill’s passage. Following concerns raised by professional bodies and concerns discussed in the Public Bill Committee, I would like to take this opportunity to reiterate my reassurances to the sector that measures that directly impact tax advisers are intended to create a fairer tax advice market. I have heard concerns that tax advisers might be penalised if they file a client’s tax return late when their client has not provided their approval for filing the return on time.”
“As the Chancellor set out last week in responding to the Office for Budget Responsibility’s spring forecast, it is more important than ever that the Government continue to deliver on our economic plan. The choices that we have made at previous Budgets will fix long-standing issues in the taxation system, restore economic and fiscal stability, and lay the economic foundations that we need for higher growth and higher living standards across our fantastic country. The Bill legislates to deliver on those choices, all while sticking to our commitment not to raise the main rates of income tax, employee national insurance contributions or VAT.”
“I strongly agree with my hon. Friend. I thank him for making his representations again and for his ability to mention Harlow in his interventions. It is a fantastic part of the country, not too far from my constituency in north London, and I know just how strongly he seeks to represent it and to make sure that the public services in his patch—the local hospitals and schools—get the investment they need. That is why he and I are able to proudly support this Government’s decisions to bring the public finances back into good order, as well as to invest in our public services and to get borrowing down. Of course, though, since the Budget, and particularly in recent days, the world has changed.”
“The hon. Gentleman raises an important point. We need to do all that we can to ensure that we are simplifying our tax code in order to make it easier for tax advisers, individuals and businesses. I have also asked that question, but I am reassured by my officials—I am sure that the hon. Member could consult Hansard too—that this is a typical number of amendments to be made to a Finance Bill. This is a long Finance Bill, but there are a whole range of important changes that the Government wish to introduce and to make progress on. I am sure Members from all parties have enjoyed poring over the changes to the tax legislation. I do take his point about simplification, though; it is something that I wish to focus on. If hon. Members have good ideas in that space, they would genuinely be welcome to write to me.”
“These ensure that excluded and exempt benefits are not subject to inheritance tax, nor to the new withholding and payment notices. I am sure that Members from all parts of the House have enjoyed that run-through of those minor and technical amendments. I can provide them with the good news that that run-through has now concluded. I sincerely hope and expect that the proposed amendments will ensure that the legislation that was set out, and that has been discussed and scrutinised, works as intended, and that HMRC—the organisation that I am proud to be the Minister with responsibility for—has the powers to responsibly collect tax and revenue, which funds the vital public services on which our country relies. I therefore commend new clauses 5, 6 and 7 and Government amendments 12 to 66 to the House, and I look forward to hon.”
“There will be those who engaged in the use of disguised remuneration schemes from before 2010, and with them, as with all taxpayers, this Government are very clear that individuals do have a responsibility to pay their tax. Amendments 54 and 55, and 62 to 66, are minor amendments to the definitions of business property qualifying for relief. They ensure that the replacement property provisions relating to reorganisation or amalgamation of unquoted shares reflect the new legislation, and that unquoted securities, such as loan notes, continue to qualify for relief only where they are part of a controlling interest in a company. Amendments 15 to 47 to clauses 63 to 67 make a series of minor technical changes to ensure that the provisions on inheritance tax and pensions operate as intended.”
“I thank the hon. Gentleman for his intervention and for his engagement in the Public Bill Committee. The loan charge is an important issue. I focused on it after receipt of Ray McCann’s independent review into the loan charge, which was commissioned by my predecessor. The scope of that review and the decisions made by the Government are such that only those who are directly affected by the loan charge will have the opportunity to take up the new settlement that was recommended by McCann, to which the Government have added a £5,000 further deduction. The Government’s position was that, because the loan charge was an exceptional decision made by the previous Government, it was right that the changes proposed by McCann would apply only to that group.”
“These amendments therefore pose a significant risk to the sustainability of our public finances and to our ability to fund the NHS and the public services that we all rely on. I therefore urge the House to reject them.”
“I thank all Members for their contributions at this stage of the Bill’s passage—we are almost there. I will take some time to respond directly to the amendments that have been discussed today. I will first address amendments 1 to 4, 5 and 7, which were spoken to by the shadow Exchequer Secretary, the hon. Member for North West Norfolk (James Wild). Amendments 1 to 4 would remove the increase in dividend, savings and property income tax rates; amendment 5 would prevent income tax thresholds from staying at their current levels until 2030; and amendment 7 would remove reforms to the inheritance tax treatment of pensions. Based on costings that have been certified by the OBR, the direct impact of these amendments would cumulatively reduce forecast revenue raised in 2029-30—the year of relevance for our fiscal rules—by a whopping £12 billion.”
“It is the Government’s understanding that there are very few, if any, goods and electricity companies in Northern Ireland that are close to the current enterprise management incentive limits, and we therefore think there will be minimal impact from these companies being subject to the previous scheme limits.”
“and learned Member for North Antrim (Jim Allister) around amendments 112 to 139, which would have the effect of removing the distinction between the options available in respect of “specified Northern Ireland companies” and other companies from clauses 13, 14 and 15. The hon. and learned Gentleman has made his views known very clearly both today and on Second Reading. I will make the same point that the Economic Secretary to the Treasury made on Second Reading: as he will be aware—although he did not, I believe, mention this in his speech —service companies are able to benefit from the increase in the threshold.”
“If the Conservatives had credible plans and a credible history of reining in welfare spending, then I would, of course, be interested in taking them seriously. However, it was the shadow Chancellor, the right hon. Member for Central Devon (Sir Mel Stride), who was the Work and Pensions Secretary when the welfare budget exploded. We are now trying to get on top of that. I will not address new clauses 15 to 19 directly. The Government have set out our position on them at previous stages, although I do urge the House to reject them today. I will now turn to the points raised by the hon.”
“If we were to adopt those amendments, we would weaken the public purse by about £300 million a year. It would also leave a status quo that contributes to the very largest estates paying lower average effective inheritance tax rates than the smallest estates. I therefore urge the House to reject those amendments. The hon. Member for Keighley and Ilkley asked for clarity on payment deadlines in the inheritance tax system. The Government’s position is that the six-month point is the right one. It has applied for a long time, and it is not our position to change that timeline when these changes come into force.”
“I am just stating a fact, which is that there are few—if any—businesses near the relevant thresholds. The hon. and learned Member made the point that the Government’s decision may be hampering growth and investment; I do not think that is the case. I am proud to be a member of a Government who are seeking to deepen and strengthen our ties with the European Union so that we in this country can increase our productivity through better flowing trade, working together with our partners. I therefore urge the House to reject amendments 112 to 139. Amendments 6 and 8 relate to the changes to business property relief and agricultural property relief as raised by the shadow Exchequer Secretary as well as the hon. Members for Weald of Kent (Katie Lam) and for Keighley and Ilkley (Robbie Moore).”
“I am sure this issue was considered before the policy was announced, and I have considered it too since I have been in post. It is worth pointing out that HMRC already offers several payment options to help personal representatives pay inheritance tax. That allows banks, building societies or investment providers to pay some or all the inheritance tax due from the deceased person’s accounts before probate is granted. There are a range of ways available to people to enable them to pay IHT within six months. I therefore urge the House to reject amendment 88.”
“It is worth pointing out that the drafting of the amendments risks those tenancies falling outside the allowance entirely so that, rather than providing 100% relief, the Government are concerned that the drafting would mean that the relief might well be capped at 50% for those with joint tenancies. That is certainly a reason to reject those amendments.”
“The president of the National Farmers Union mentioned in his speech to the farmers’ conference just a few weeks ago that he was glad of my engagement with farmers—he personally called out that engagement. I took a trip to the constituency of my hon. Friend the Member for Hexham (Joe Morris), after being invited there by him, and I was glad to meet farmers there and learn about their experiences. Amendments 89 to 94 seek to exclude the value of any joint interest in certain agricultural business tenancies from the £2.5 million allowance for 100% relief.”
“I will not address in detail new clause 12 or amendments 67 to 87, 95 to 100 and 108 to 111, as the Government have set out their position on those amendments at previous stages, and I urge the House to reject them. My hon. Friends the Members for Stoke-on-Trent Central (Gareth Snell), and for Halesowen (Alex Ballinger), both made important contributions on the amendments relating to gambling duty. I have twice met the Minister from Gibraltar mentioned by my hon. Friend the Member for Stoke-on-Trent Central and have been in correspondence with him. I understand that there are significant impacts on the economy in Gibraltar, and I hope to keep engaging on and discussing that.”
“If the right hon. Member will forgive me, I will make progress, having spoken for eight minutes already. Amendments 102 to 107 would mean that unlimited 100% agricultural property relief would be available on agricultural land rented out for at least 10 years. The Government’s position is that the House should reject these amendments. The hon. Member for Witney (Charlie Maynard) also spoke to new clause 11. The Government have decided on a range of thresholds that will continue to be frozen until the end of the decade. We have made the decision across the piece, as was mentioned earlier, to sustainably and fairly raise revenue to fund our public services and get borrowing down. I therefore urge the House to reject amendments 102 to 107.”
“We will, of course, continue to engage with Ministers in Gibraltar. It would not be appropriate for me to write future Budgets at this Dispatch Box today, but we have made a significant change when it comes to gambling taxation. Rather than make further changes, the Government will monitor the impact of that change. I also thank my hon. Friend the Member for Halesowen for his contributions and representations. The hon. Member for Aberdeen North (Kirsty Blackman) made a helpful speech— with not much notice, I understand. She raised the matter of alcohol duty. It is worth pointing out that the uprating in alcohol duty just keeps the revenue in line with inflation. We have seen reductions in alcohol consumption, driven not by the tax staying in line with inflation, but changes in consumers’ consumption habits.”
“It causes misery to those caught up in the schemes, and deprives our public services of vital revenue. The Government are taking action via this Finance Bill to crack down on them. I confirm to the House that the measures introduced in clauses 156 to 162 apply equally to those promoting avoidance schemes online, including on social media, and to those promoting them through more traditional routes. I can also confirm that the promoter action notice in clauses 163 to 173 will also apply. I would also like to reassure my hon. Friend that we are publishing guidance on these matters, and I will ensure that it is clear throughout that the Government’s intention is to capture anyone who is promoting tax avoidance. This includes social media influencers who are making a monetary gain through clicks, as highlighted by my hon.”
“It is very complicated, and there would be knock-on impacts on other sectors if the Government were to proceed with that. I have met representatives from the sector recently, and I will continue to engage with them. Finally, I turn to new clause 4, which requires the Chancellor to report on how the regulations in the prohibition address the harm to individuals and businesses from online tax avoidance promotion, and the steps that His Majesty’s Revenue and Customs should take to inform the public of the risk posed by online tax avoidance. I thank my hon. Friend the Member for Walthamstow (Ms Creasy) for raising the important issue of avoidance promotion. I agree with her that it is appalling that these individuals promote tax avoidance schemes and get away with it.”
“I will not get into specific worked examples. The general point is that the Government have made changes both to business property relief and to agricultural property relief, in order to raise additional revenue from the very wealthiest estates. We have sought to do that because we want to put fairness into our tax system. The CBAM was mentioned by the Opposition, and by my hon. Friend the Member for Mid and South Pembrokeshire (Henry Tufnell). I thank him for his strong advocacy for his constituency, and the thousand people who work in the refinery there. The Government said at the Budget that we recognise the important role that refineries play in our energy security, and we are now considering the feasibility and impact of including refined products in the CBAM in future.”
“New Clause 11 Uprating of allowance amounts for agricultural property “The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”— (Charles Maynard.) Brought up, and read the First time. Question put, That the clause be read a Second time.”
“New Clause 7 Pensions: abolition of the lifetime allowance charge “(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”.” — (Dan Tomlinson.) Brought up, read the First and Second time, and added to the Bill.”
“(9) In section 733 of ITA 2007, after subsection (2D) insert— “(2E) See subsections (7) and (8) of section (Offshore income gains: savings) of FA 2026 (offshore income gains: savings relating to amendments made by section (Offshore income gains) of that Act) for special provision about income that is treated as arising under section 732 but that is not chargeable to income tax under subsection (3) of that section.” (10) This section— (a) is to be treated as having come into force on 6 April 2025; (b) has effect for the tax year 2025-26 and subsequent tax years.” — ( Dan Tomlinson .) Brought up, read the First and Second time, and added to the Bill.”
“(7) Subsection (3) does not prevent Chapter 2 of Part 13 of ITA 2007 from having effect as though the income not chargeable to tax under that subsection had been charged to tax under section 731 of that Act. (8) Accordingly— (a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of that income will be deducted at Step 2 and at paragraph (a) of Step 5, and (b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of that income will be deducted at paragraph (b) of Step 5.”
“(6) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income— (a) which would have been treated as arising to the individual by reason of— (i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, (b) to which paragraph 102 of Schedule 7 to FA 2008 would have applied, and (c) to which paragraph 101 of that Schedule would not have applied, and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (4) to (7) of paragraph 127 of that Schedule as they would have been modified by sub-paragraph (4) of paragraph 102 of that Schedule.”