Lucy Rigby
MP for Northampton North · Labour · United Kingdom
“Border communities rely on strong transport links, and my hon. Friend is a strong advocate for the interests of his constituency and those in the surrounding area. The Government are delivering for people in all parts of the UK, including investments that will benefit those on both sides of the English-Welsh border.”
“Nothing was snuck out. A third runway at Heathrow means more than 60,000 good local jobs, and more than £40 billion for the British economy. The hon. Lady’s question rather highlights the Lib Dems’ curious approach to growth.”
“My right hon. Friend the Member for Makerfield (Andy Burnham) will speak for himself, but I am confident that his view is that growth extends far beyond the area that the hon. Gentleman referred to.”
“Effective transport links are vital to the prosperity and wellbeing of people across the country, including in our border communities. We have been working closely with the Welsh Government to deliver a plan for Welsh rail, and we continue to work with devolved Governments to ensure that border communities stay connected.”
“We have been clear that Heathrow expansion needs to benefit everyone, not just London. The Department for Transport has shown that expansion would deliver UK-wide support for trade, with 40% of the estimated GDP benefits from expansion being outside London and the south-east.”
“The Pride in Place programme provides £5.8 billion of support to 284 neighbourhoods right across the country, including five places in my hon. Friend’s constituency, which she does so much to advocate for. We will set out more details of further funding in the Budget.”
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“On the points made by the shadow Minister, the hon. Member for Wyre Forest, we have listened very carefully indeed to the sector’s concerns and have responded. That is exactly why we are delaying the proposed changes to employee car ownership schemes until 2030. That is the reasoning behind the delay. The Government are firmly committed to our modern industrial strategy, and specifically to the automotive sector. That is why in the past year we have committed £2.5 billion to automotive investment and research and development, increased flexibilities in the ZEV mandate, funded the roll-out of more charge points and announced plans to cut electricity costs for energy-intensive manufacturers.”
“It will also make a consequential amendment to foreign employment relief, commonly known as overseas workday relief, to ensure that this clarification also applies to UK residents who claim it. I commend clauses 20 to 23 to the Committee.”
“These tax changes will have an impact only on a small subset of workers, as the vast majority of such payments are taxable under existing legislation. The measure confirms that payments received in the event that a shift is altered at short notice are taxable in all scenarios, including in relation to agency workers and workers employed under umbrella companies. Clause 23 puts beyond doubt the answer to whether earnings for duties not performed should be treated as UK earnings or overseas earnings for non-UK residents. The clause will establish a general principle to determine the tax treatment of earnings that relate to duties that have not been performed.”
“The Exchequer impact is negligible, but this change will allow employers to support staff without having to handle the sourcing and provision of minor items themselves. This will reduce time and resource costs. Clause 21 relates to homeworking expenses. It will remove the process by which employees can claim an income tax deduction from HMRC if they have incurred additional household costs when required to work from home. The changes introduced by the clause aim to address concerns around non-compliance and to ensure fairness across the tax system. Clause 22 will introduce changes that confirm the income tax treatment of payments made by zero-hour or similar limited-hour workers for a cancelled, moved or curtailed shift. This measure will put the tax treatment of such a shift beyond doubt.”
“Clauses 20 to 23 relate to other employment income. Clause 20 will simplify the rules on common workplace health and equipment costs, reducing administrative burdens for employers and giving greater clarity to the tax treatment of these costs. It will exempt reimbursements for accommodations, supplies or services used in performing employment duties, such as homeworking equipment; it will extend the existing exemptions for eye tests and corrective appliances to cover reimbursements; and it will introduce a new exemption for both the direct provision and the reimbursement of flu vaccinations. Uptake will depend on employer practice, but these changes will make the rules simpler and fairer for those affected.”
“They are paid in lieu of the payment that workers would have received had they completed the shift, and as such they are taxable in all relevant scenarios, irrespective of the arrangement or the employment structure. Question put and agreed to. Clause 20 accordingly ordered to stand part of the Bill. Clauses 21 to 23 ordered to stand part of the Bill. Clause 24 Umbrella companies”
“It is important to be clear that clause 21 will not impact employers’ existing ability to reimburse employees for costs relating to home working, where eligible, without deducting income tax and national insurance contributions. The question of national insurance was raised in relation to clause 22 on payments for cancelled shifts. These payments will be subject to national insurance. My hon. Friend the Member for Burnley was entirely right to refer to the Employment Rights Act and its significance. I think I am right in saying that a question was also raised about the taxable nature of payments for cancelled shifts. I can confirm that payments received for short-notice shift cancellations or changes are regarded as earnings.”
“The shadow Minister, the hon. Member for Wyre Forest, and my hon. Friend the Member for Burnley referred to vaccinations and asked about the extent to which covid vaccinations might be part of the scheme. We are limiting relief to flu vaccinations because employers have consistently highlighted them as a common relief in relation to which reimbursement would be helpful. Flu vaccinations are low in cost, seasonal and widely offered by employers as part of routine health support to employees. By contrast, other vaccinations vary significantly in cost and frequency. Importantly, however, many of them can be accessed free through the NHS. As you might expect, Sir Roger, I completely reject the shadow Minister’s assertion that any of these measures is an attack on private sector workers. Not at all—far from it.”
“(5) In this section ‘CRCA 2005’ means the Commissioners for Revenue and Customs Act 2005.” This amendment permits disclosures (whether or not permitted as a result of provision elsewhere) to persons who may be jointly and severally liable as a result of new Chapter 11 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003.”
“(3) Information disclosed in reliance on subsection (2) may not be further disclosed without the consent of the Commissioners for His Majesty’s Revenue and Customs (which may be general or specific). (4) Where a person contravenes subsection (3) by disclosing information relating to a person whose identity— (a) is specified in the disclosure, or (b) can be deduced from it, section 19 of CRCA 2005 (offence of wrongful disclosure) applies in relation to the disclosure as it applies in relation to a disclosure in contravention of section 20(9) of that Act.”
“(2) The officer may at any time disclose to the person such information as the officer considers appropriate (whether or not such a disclosure would otherwise be permitted under section 18(2)(a) of CRCA 2005 or any other enactment) for the purposes of informing the person about that liability (‘the joint liability’) including— (a) the identity of any person who is an umbrella company, a purported umbrella company or the worker in relation to the arrangements to which the joint liability relates, and (b) information about the nature and extent of the liability of an umbrella company or a purported umbrella company that (by virtue of this Chapter) results, or may result, in the joint liability.”
“I beg to move amendment 5, in clause 24, page 28, line 25, at end insert— “61Z2 Disclosures to liable persons (1) Subsection (2) applies where an officer of Revenue and Customs considers that a person is, or may be, jointly and severally liable to pay an amount as a result of this Chapter.”
“This will ensure that HMRC is able to recover underpayments of tax from businesses that are within scope of the new rules because they purport to be umbrella companies, in the same manner that underpayments will be recovered from the other businesses that are within scope of the new rules. Amendment 5 will ensure that HMRC is able to keep taxpayers informed about its investigations concerning sums to which they are jointly and severally liable. That will help taxpayers to take action to mitigate their exposure to unpaid liabilities. I commend clause 24, together with Government amendments 5 to 8, to the Committee.”
“Clause 24 will make changes to ensure that recruitment agencies are responsible for accounting for pay-as-you-earn on payments made to workers that are supplied via umbrella companies. Many umbrella companies operate diligently and support their employees, but a significant number are used to facilitate non-compliance, including tax avoidance and fraud. Clause 24 is intended to encourage increased due diligence among businesses that choose to use umbrella companies to engage workers. It will do so by introducing joint and several liability for the PAYE taxes that umbrella companies are required to remit to HMRC. Government amendments 5 to 8 will ensure that the legislation works as intended by making a small technical change.”
“Amendment 8, in clause 24, page 29, line 34, leave out from first “to” to “as” in line 35 and insert “that amount”.— (Lucy Rigby.) This amendment is consequential on Amendment 6. Clause 24, as amended, ordered to stand part of the Bill. Clause 25 Loan charge settlement scheme”
“Employment is a fundamental characteristic of how most umbrella company workers are engaged and is the key aspect in determining when this legislation will apply. I think that will be the key legal test. Amendment 5 agreed to. Amendments made: 6, in clause 24, page 29, line 31, leave out “a ‘relevant party’ for the purposes” and insert “jointly and severally liable to pay an amount as a result”. This amendment makes sure that HMRC can use their power to make determinations about PAYE income in relation to persons who are jointly and severally liable to amounts of PAYE income under new section 61Z1 of the Income Tax (Earnings and Pensions) Act 2003. Amendment 7, in clause 24, page 29, line 32, leave out from “ITEPA” to end of line 33 and insert “(umbrella companies)—”. This amendment is consequential on Amendment 6.”
“We think it—and it sounds like the shadow Minister agrees—that that has contributed to the proliferation of non-compliance in the umbrella company market. It is important that agencies take steps to ensure that their labour supply chains are compliant, and some agencies already do. HMRC has published guidance on how to undertake checks. The shadow Minister asked about which agencies may be treated as umbrella companies, given the breadth, or otherwise, of the definition. We are, of course, aware that some agencies engage workers as employees, and where that is the case, and they meet the other conditions of the legislation, they will be treated in the same way as umbrella companies and this measure will apply.”
“On the shadow Minister’s final question, I am afraid that I do not know what discussions have taken place with the organisation he referred to, but I can write to him and let him know. Ultimately, whether to use an umbrella company when supplying a worker to a client is a commercial decision for agencies. That commercial decision has been incentivised not just by the ability to outsource administration to umbrella companies, but by the shielding from exposure to tax risk that that model provides. It is good to hear the shadow Minister welcome the impetus behind the changes in that regard. The current legal framework provides few incentives for agencies to ensure that the umbrella companies they use are compliant.”
“I beg to move amendment 9, in clause 25, page 30, line 21, at end insert “, or (ii) a director or shadow director of such a person.” This amendment expands the persons to whom the Commissioners are not required to make a loan charge settlement offer so as to include directors and shadow directors of a promoter or introducer.”
“I am sure that everyone will be aware that the loan charge is already subject to significant parliamentary scrutiny. HMRC officials and Treasury Ministers routinely provide updates on their work to the Treasury Committee and the Public Accounts Committee, and the Treasury Committee asked the HMRC permanent secretary about this topic just last month. I therefore urge the hon. Member for Maidenhead not to move his new clauses, and commend clauses 25 to 27, and Government amendments 9 to 11, to the Committee.”
“The Government published a comprehensive response to the review, setting out our position, at the Budget. That outlined the decisions the Government made to help draw this matter to a close for those impacted, and explained why the scope of the review had been set as it had. It explained that the settlement opportunity will apply to disguised remuneration use between December 2010 and April 2019, because that is the period to which the loan charge applies. While people who used tax avoidance schemes outside that period will not be able to access the scheme, HMRC will work sensitively and pragmatically to help people to resolve their cases, including by taking account of people’s means and offering generous payment terms where appropriate.”
“Clause 25 makes provision for the exclusion of tax avoidance promoters from the settlement opportunity. Amendments 9 and 10 tighten those provisions to ensure that HMRC is able to prevent the controlling minds behind promoter companies from inappropriately accessing the settlement opportunity, in line with the Government’s announcements at the Budget. Amendments 9 to 11 also clarify that where an employer still exists, it can enter into a settlement on behalf of its employees who used disguised remuneration schemes. New clauses 25 and 26, which would require HMRC to publish a report on the operation and scope of the loan charge settlement opportunity and a report on the treatment of disguised remuneration arrangements falling outside the scope of the loan charge, are unnecessary.”
“In addition to removing late payment interest and inheritance tax, and allowing for generous tax deductions to represent amounts assumed to have been paid to promoters, the Government will also write off the first £5,000 of each individual’s liability. Because of these changes, around 30% of people within scope of the review could see their liabilities removed entirely, while most other individuals will see their liabilities reduced by at least half. Turning to Government amendments 9 to 11, HMRC is aware of a number of promoters who have made use of their own disguised remuneration schemes and would be within scope of the settlement opportunity. I am very clear that it would be wrong for those individuals to be able to access the generous settlement terms on offer rather than paying every penny that they owe.”
“Clauses 25 to 27 provide for the Government to create a settlement opportunity in line with their response to the independent review of the loan charge, and to encourage those who have not yet settled with HMRC to come forward and do so. Clause 25 sets out some of the main features of the scheme, including how the new settlement amount will be calculated. Clause 26 will ensure that inheritance tax is not charged as part of any settlement where it relates to disguised remuneration arrangements in scope of the loan charge. Clause 27 makes supplementary provision for the settlement scheme to ensure that it can operate as intended. In some places, the Government have gone further than the review recommended.”
“The settlement opportunity being provided is substantially more generous than any opportunity HMRC has previously offered and will substantially reduce the outstanding liabilities of people who have yet to settle with HMRC, particularly those with the lowest liabilities. Most individuals, as I said, could see reductions of at least 50% in their outstanding loan charge liabilities. We estimate that 30% of individuals could have their liabilities written off entirely.”
“The purpose of the review, as I think is well known, was to bring the matter to a close for those who had not yet settled and paid their loan charge liability to HMRC. That by its very nature meant focusing on open cases and outstanding liabilities. The Liberal Democrat spokesman, the hon. Member for Maidenhead, referred to something like this happening again. I think we would all agree that we hope it does not. However, we would probably also agree that it is crucial that any resolution to this issue is fair to the wider tax-paying population that has never avoided tax. The Government believe that this settlement opportunity is the most pragmatic solution to draw a line under the issue for as many individuals with outstanding liabilities as possible.”
“Clause 27 Loan charge settlement scheme: supplementary Amendment made: 11, in clause 27, page 33, line 15, at end insert— “(da) adapting provision made under section 25(6), in cases where a settlement offer is made to a person who is not an individual, about the calculation of settlement amounts (including provision for the calculation to be different to what is required by section 25(6));”.— (Lucy Rigby.) This amendment clarifies that the loan charge settlement scheme can provide for the calculation of the settlement amount to be adapted where a settlement offer is made to a person who is not an individual. Clause 27, as amended, ordered to stand part of the Bill.”
“Amendment made: 10, in clause 25, page 32, line 12, at end insert— “‘shadow director’ has the meaning given by section 251 of the Companies Act 2006.”— (Lucy Rigby.) This amendment inserts a definition for the purpose of Amendment 9. Clause 25, as amended, ordered to stand part of the Bill. Clause 26 ordered to stand part of the Bill.”
“I managed to give way just before the end of my speech. The shadow Minister raises a good question and a fair point. Through the new measures and existing rules, HMRC will have powers that can result in criminal prosecution of promoters of tax avoidance, including the new universal stop regulation proposal, which will ban the promotion of the most fanciful schemes outright and allow the HMRC commissioners to ban by regulation the promotion of other arrangements that HMRC thinks will not work. We will consult on further measures to target promoters in early 2026—indeed, it is 2026 already, so the shadow Minister may assume that that will happen soon. Amendment 9 agreed to.”
“Although the fiscal climate limits what we can do now, the new first-year allowance moves us closer to that goal in a responsible way. New clause 2 seeks to mandate reporting the impacts of clause 28 to the House. The Government have published documents much loved by the shadow Minister, the hon. Member for North West Norfolk—tax information and impact notes—setting out the impact of the reduction to main rate writing-down allowances, alongside the introduction of the new 40% first-year allowance. I therefore reject new clause 2 and commend clauses 28 and 29 to the Committee.”
“Clause 29 will introduce the new 40% first-year allowance, which will support future investment. The new allowance is available for expenditure on plant and machinery, including assets bought for leasing and assets bought by unincorporated businesses, from 1 January 2026. The changes made by clauses 28 and 29 will raise approximately £1.5 billion per year by the end of the scorecard. The changes are UK-wide and will impact businesses with pools of historic main rate expenditure, which predate the introduction of the super-deduction or full expensing regimes for companies, as well as historic expenditure or future main rate expenditure that does not qualify for first-year allowances, or where first-year allowances were not claimed. We have heard the calls to expand full expensing to more assets and businesses.”
“Clause 28 will reduce the main rate writing-down allowance for corporation tax and income tax, and clause 29 introduces a new first-year allowance available for expenditure on plant and machinery. As I am sure all hon. Members are aware, capital allowances allow businesses to write off the costs of capital assets, such as plant or machinery, against their taxable income. The UK continues to offer one of the most generous capital allowances systems globally and ranks top among OECD countries for plant and machinery capital allowances. Clause 28 will reduce the main rate writing-down allowance from 18% to 14%, starting on 1 April 2026 for corporation tax and 6 April 2026 for income tax. That allows the Government to fund a new first-year allowance while also fairly raising revenue to protect the public finances.”
“The shadow Minister referred to the new 40% first-year allowance, which is bringing forward relief for the leasing sector and unincorporated businesses, which have historically been carved out of the first-year allowance. In doing so, it allows for immediate relief on a significant amount of their investment from their corporation tax or income tax bill in the year in which they make that investment. As the Chancellor has repeatedly made clear, the fiscal environment is challenging. We cannot make unfunded commitments on tax. The shadow Minister referred earlier to being an adviser to the previous Government, which is not, I suspect, to suggest that he had a role in creating the fiscal environment that we unfortunately inherited from the previous Government. We have heard the calls to expand full expensing to more assets and businesses.”
“My hon. Friend makes a very good point. The shadow Minister asked about working with businesses to get the word out. We have been working closely with industry on the expansion to leasing and we are consulting businesses on guidance to ensure that understanding of the new rules is as full as possible. The TIINs beloved of the shadow Minister, we now hear, make it clear that the OBR’s “Economic and fiscal outlook” sets out that the measure is not expected to have significant macroeconomic impacts, and for future investment the present value and cost of capital for businesses that claim the new first-year allowance remains broadly the same following these changes. For all those reasons, I maintain the view that new clause 2 should be rejected. Question put and agreed to. Clause 28 accordingly ordered to stand part of the Bill.”
“Alongside the 2025 Budget, in which the extension was announced, a policy costings document and a TIIN were published that set out the expected economic, business and other impacts of the changes, including impacts on incentivising businesses to purchase zero emission vehicles. Those documents are of course available online. The Government annually review the rates and thresholds of taxes and reliefs to ensure that they are appropriate and reflect the current state of the economy. For that reason, new clause 3 is unnecessary. I commend clause 30 to the Committee, and ask that new clause 3 be rejected.”
“Clause 30 will extend the 100% first-year allowance for qualifying expenditure on zero emission cars and plant or machinery for electric vehicle charge points by a further year to April 2027. More specifically, it will extend the availability of these capital allowances to 31 March 2027 for CT purposes and 5 April 2027 for income tax purposes, ensuring that investments in zero emission cars and charge point infrastructure continue to receive the most generous capital allowance treatment. New clause 3 would require the Chancellor to review and report on the impact of the expiry in 2027 of the 100% first-year allowances made under clause 30, including the case for ongoing capital allowance support for zero emission cars and electric vehicle charging points.”
“Member for Maidenhead that we might go beyond one year, we need to balance support for the industry with the impact on the public finances. In our debate on clause 30, we have had “stop-start”, “accelerate”, “full throttle” and “red light”. I now encourage the Committee to greenlight the clause. Question put and agreed to. Clause 30 accordingly ordered to stand part of the Bill.”
“On new clause 3, I think I have been as full as I can. The Government annually review the rates and thresholds of taxes and reliefs to ensure that they are appropriate and reflect the current state of the economy. We therefore do not need the review that is suggested in new clause 3. On the broader points made by the shadow Minister, the hon. Member for North West Norfolk, we are, as I say, fully committed to supporting our automotive sector. On the suggestion that we might look further ahead, the Chancellor makes decisions on tax policy at fiscal events in the context of the public finances. My hon. Friend the Member for Banbury is right that support for infrastructure in this area is critical; indeed, that is the wider policy of the Government. On the suggestion from the hon.”
“They will do so by preventing some incorrect amounts from occurring and by setting out how to resolve others when they arise. Noting that clause 32 will close a loophole, I commend clauses 31 to 33 to the Committee.”
“Clause 31 will make changes to clarify the tax treatment of payments made by companies in return for receiving expenditure credits. The changes made by the clause will set out a treatment for companies to follow. Payments made in return for credit must be ignored for corporation tax purposes, both by the surrendering company and by the recipient company. Clauses 32 and 33 will introduce technical amendments to the legislation on video games expenditure credit and audiovisual expenditure credit. The changes made by clause 32 will add a new transitional rule to modify the video games expenditure credit calculation so that it accounts for both European and UK expenditure. The changes made by clause 33 will prevent incorrect amounts from having an impact on the intended generosity of special credit.”
“This will affect only games that are already in development and need to switch reliefs. There are no figures available to show the impact on companies; it is normally in the tax line, so it is not treated as taxable by most companies. I think that answers all of his questions. Question put and agreed to. Clause 31 accordingly ordered to stand part of the Bill. Clauses 32 and 33 ordered to stand part of the Bill. Clause 34 R&D undertaken abroad: Chapter 2 relief only Question proposed, That the clause stand part of the Bill.”
“I wholeheartedly agree with my hon. Friend the Member for Watford about the impact of these measures. In relation to clause 31, if only the shadow Minister, the hon. Member for North West Norfolk, had the TIIN to hand; if he did, he might have been aware that we estimate that the payments for the surrender of expenditure credits will have an impact on roughly 12,000 claimants of R&D expenditure credit, audiovisual expenditure credit and video games expenditure credit. The shadow Minister asked about the impact on video games companies: I think it is fair to say that if a company has a game that switches from the video games tax relief to the video games expenditure credit, it simply needs to make sure that it uses the modified version of step 2 when calculating how much credit it is entitled to.”
“Clause 34 makes a minor legislative amendment to the R&D tax relief rules to put beyond doubt that the overseas restrictions apply to R&D expenditure credit claimants with a registered office in Northern Ireland. The Government are making this amendment to provide clarity to businesses and ensure that the legislation aligns with the original policy intent of the Finance Act 2025. I commend clause 34 to the Committee.”
“Clause 35 Restriction of relief on disposals to employee-ownership trusts Question proposed, That the clause stand part of the Bill.”
“I thank the shadow Minister for his question. The Government are committed to supporting R&D investment across the UK through R&D tax reliefs; they of course play a vital role in supporting the mission to boost economic growth, which he will know is this Government’s No. 1 priority. The legislation clarifies that the rules are the same for all R&D expenditure credit companies across the UK. The overseas restriction was introduced in regulations in 2024 before being included in the Finance Act 2025. It was always intended to apply to R&D expenditure credit claimants across the UK, so the change is purely to clarify the Finance Act 2025 to put that position beyond all doubt. Question put and agreed to. Clause 34 accordingly ordered to stand part of the Bill.”
“The changes made by clause 35 will restrict the amount of CGT relief available to company owners who dispose of shares to the trustees of an EOT. For disposals on or after 26 November 2025, half of the gain on disposal to the trustees of an EOT will be treated as the disposer’s chargeable gain for CGT purposes, and charged to tax according to the usual applicable rules. The remaining half of the gain will be not charged to tax at the time of disposal. Overall, this means that disposals to an EOT will benefit from a rate of tax that is broadly equivalent to half of the usual rate, which will still constitute an effective incentive to encourage company owners towards employee ownership.”
“Clause 35 reduces the amount of capital gains tax relief available on disposal of company shares to the trustees of an employee ownership trust. The Government are committed to building on the success of the existing scheme so that the UK remains a leader in the field of employee ownership. However, the Government have to consider the public finances and the important issue of fairness in our tax system. The current regime allows business owners to dispose of valuable shareholdings for significant capital gains without paying any tax at all. The cost of the CGT relief alone reached £600 million in 2021-2022, and forecasts suggest that it could rise to more than 20 times the original costing to £2 billion by 2028-29, if action is not taken.”
“The Government provide a wide range of loan support for SMEs through the British Business Bank. This includes the start up loans programme and the growth guarantee scheme, the latter of which recently supported over 4,000 businesses and over 65,000 jobs right across the country.”
“My hon. Friend is a tireless champion of businesses in Bassetlaw, and I wish her a happy birthday for yesterday. In the recent spending review, the Government extended the growth guarantee scheme, enabling £5 billion-worth of loans over the next four years. This will support businesses like the one she mentioned, and I would be more than happy to meet her to talk about how her constituent might access that support.”
“The hon. Member may well know that, at the spending review, we increased the financial capacity of the British Business Bank to £25.6 billion. There are a number of ways in which the British Business Bank will support companies like the one she referred to.”