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- Original (As enacted)
There are currently no known outstanding effects for the Finance Act 2025.
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Part 1 Income tax, capital gains tax and corporate taxes
58.EBTs: prohibition on applying property for benefit of participators etc
59.EBTs: restriction on proportion of beneficiaries who may be participators etc
60.EBTs: shares entering trust to have been held for two years
61.Agricultural property relief: environmental management agreements
62.National Savings Bank: statements from HMRC no longer to be required
66.Rates of vehicle excise duty for light passenger or light goods vehicles etc
67.Rates of vehicle excise duty for rigid goods vehicles without trailers etc
68.Rates of vehicle excise duty for rigid goods vehicles with trailers
69.Vehicle excise duty for vehicles with exceptional loads etc
70.Rate of vehicle excise duty for haulage vehicles other than showman’s vehicles
Part 4 Miscellaneous and final
Schedules
Sections 7 to 10 : transitional provision
Part 1 Transitional provision in consequence of section 7 and Schedule 1
Part 2 Anti-forestalling provisions: sections 7(3) and 10(2)
Part 3 Anti-forestalling provisions: sections 8(3) and (6) and 9(4) and (8)
11.Assets transferred on or after 6 April 2025 under unconditional contract made before 30 October 2024
12.Assets transferred on or after 6 April 2025 under unconditional contract made on or after 30 October 2024 but before 6 April 2025
13.Assets transferred on or after 6 April 2026 under unconditional contract made in tax year 2025-26
15.Business asset disposal relief: reorganisations of share capital before 30 October 2024
16.Business asset disposal relief: reorganisations of share capital on or after 30 October 2024 but before 6 April 2026
17.Business asset disposal relief: exchanges of securities etc before 30 October 2024
18.Business asset disposal relief: exchanges of securities etc on or after 30 October 2024 but before 6 April 2026
19.Investors’ relief: reorganisations of share capital before 30 October 2024
20.Investors’ relief: reorganisations of share capital on or after 30 October 2024 but before 6 April 2026
14.In section 169 (certain non tax resident entities to be...
15.In section 170 (adjustments for ultimate parent that is a...
16.(1) Section 178 (reallocation of tax expense) is amended as...
17.In section 240 (location of flow-through entities and permanent establishments),...
19.In sections 175 and 176, in the headings, for “covered...
20.(1) Section 176D (tax credits etc allocated under tax equity...
21.(1) Section 176E (flow-through tax benefits: proportional amortisation method) is...
22.(1) Section 176F (flow-through tax benefits: subtraction method) is amended...
23.After section 176F insert— Clawback of earlier qualifying flow-through tax...
24.In Schedule 15 (elections), in paragraph 2(1) (annual elections), omit...
26.No allocation of deferred tax assets and liabilities under blended CFC regimes
27.Cross-border allocation of current tax under cross-crediting regimes
31.Existing deferred tax assets and liabilities arising under blended CFC regimes
32.Substance based income exclusion: permanent establishments and flow-through entities
33.For section 198 (eligible payroll costs and eligible tangible asset...
34.In section 196 (eligible payroll costs), after subsection (6) insert—...
35.In section 197 (eligible tangible asset amount), after subsection (9)...
38.(1) Section 206 (additional top-up amounts where recalculations required) is...
40.(1) Section 227 (application of Part to joint venture groups)...
41.(1) Section 266 (qualifying entities) is amended as follows.
43.(1) Section 272 (determining top-up amounts of entity that is...
48.Substance based income exclusion: removal of provision for election
54.In section 148A (transferable tax credits), in subsection (5)(a)—
55.In section 170 (adjustments for ultimate parent that is a...
56.In section 171 (ultimate parent subject to qualifying dividend regime)—...
57.In section 176B (value of non-marketable transferable tax credits: originator),...
58.In section 176C (value of non-marketable transferable tax credits: purchaser)—...
59.In section 176D (tax credits etc allocated under tax equity...
60.In section 211 (transfer of assets or liabilities to a...
61.In section 212 (meaning of “qualifying reorganisation”), in subsection (4),...
62.In section 215 (undistributed income amount), in subsection (2)(c) omit...
63.In section 216 (election where assets and liabilities adjusted to...
64.In section 217 (post filing adjustments of covered taxes), after...
67.In section 222 (investment entity effective tax rate), in Step...
68.In section 242 (ownership interests and controlling interests), in subsection...
69.In section 255 (Pillar Two rules), in subsection (6), for...
70.In Schedule 14 (administration of multinational top-up tax)—
71.In Schedule 16A (multinational top-up tax: safe harbours), in paragraph...
Relief on foreign employment income: consequential and transitional provision
Income tax and capital gains tax: remittance basis and domicile
Part 2 Removal of domicile (primary legislation)
7.Removal of exemption for persons not domiciled in United Kingdom
9.Residence of personal representatives: domicile of deceased no longer relevant
10.In section 62 of TCGA 1992 (residence of personal representatives),...
11.Residence of trustees: domicile of settlor no longer relevant
12.(1) Section 69 of TCGA 1992 (trustees of settlements) is...
13.(1) In the Money Laundering, Terrorist Financing and Transfer of...
14.Application of Income Tax Acts in relation to deemed employment
16.In section 7 of F(No.2)A 2005 (social security pension lump...
18.In ITA 2007 omit section 835B (domicile for income tax...
25.Reliefs in respect of income from investments etc. of certain pension schemes
Temporary repatriation facility
Part 2 Exemptions etc for designated qualifying overseas capital
Trusts: connected amendments, transitional provision etc
1.Chapter 5 of Part 5 of ITTOIA 2005 (settlements: amounts...
3.In section 622 (person liable), for “sections 643A and 643I...
4.In section 624 (income where settlor retains an interest), in...
5.Omit sections 628A to 628C (protected foreign-source income and transitional...
6.In section 629 (income paid to relevant children of settlor),...
7.Omit section 630A (exception to section 629 for protected foreign-source...
8.In section 635 (capital sums charge: amount of available income)—...
9.In section 636 (capital sums charge: calculation of undistributed income)—...
10.In section 637 (qualifications to section 636), in subsections (5)...
11.For the italic heading before section 643A, substitute— Transitional provision...
12.Before section 643A insert— “Protected foreign-source income” and “transitional trust...
13.For section 643A substitute— Benefits paid out of protected foreign-source...
14.(1) Section 643B (meaning of “untaxed benefits total” in section...
15.For section 643C substitute— Meaning of “available protected income” in...
16.(1) Section 643E (reimbursement of tax paid by settlor) is...
17.After section 643E insert— Onward gifts from non-residents or qualifying...
18.(1) Section 643F (income attributed by section 643A to user...
19.(1) Section 643G (section 643F(4): benefits and income “relating” to...
20.In section 643H (meaning of close member of settlor’s family),...
22.(1) Section 643N (person liable under section 643J or 643L...
23.(1) Section 645 (property or income originating from settlor) is...
24.(1) Section 646 (adjustments between settlor and trustees etc) is...
25.(1) Section 648 (income arising under a settlement) is amended...
Part 2 Transfer of assets abroad
29.In section 721 (individuals with power to enjoy income as...
30.Omit sections 721A and 721B (meaning of “protected foreign-source income”...
32.(1) Section 726 (remittance basis etc) is amended as follows....
34.In section 728 (individuals receiving capital sums as a result...
35.Omit section 729A (meaning of “protected foreign-source income”).
37.(1) Section 730 (remittance basis etc) is amended as follows....
39.(1) Section 732 (deemed income where benefit received) is amended...
40.(1) Section 733 (income charged under section 731) is amended...
41.Omit sections 733A to 733E and 734A (old provision about...
42.(1) Section 735 (remittance basis etc) is amended as follows....
44.After section 735A insert— Transitional provision about protected foreign-source income...
45.(1) Section 735B (settlor charge: remittance-basis users) is amended as...
46.(1) Section 735C (old onward gifts provisions: remittance-basis users) is...
47.In section 736 (exemptions: introduction)— (a) in subsection (1), for...
48.Omit section 742A (post-5 April 2012 transactions: exemption for genuine...
49.In section 747 (amounts corresponding to accrued income profits and...
50.In section 751 (tribunal’s jurisdiction on appeals), omit paragraph (da)....
Part 3 Settlements (chargeable gains)
52.In section 1A (territorial scope), in subsection (2)(e), omit “87K,...
53.In section 1E (losses deductible only when within scope of...
54.In section 62 (death: general provisions), in subsection (2A), omit...
55.(1) Section 86 (attribution of gains to settlors with interest...
56.In section 86A (attribution of gains to settlor where temporarily...
57.In section 87 (non-UK resident settlements: attribution of gains to...
58.(1) Section 87B (section 87: remittance basis) is amended as...
59.In section 87D (sections 87 and 87A: capital payments to...
60.(1) Section 87G (settlor liable if capital payment received by...
61.In section 87H (meaning of “close member of the settlor’s...
62.For sections 87I to 87M (old onward gifting provisions) substitute—...
63.In section 91 (increase in tax payable under section 87...
64.In section 97 (supplementary provisions)— (a) in subsection (1)(a)(ii), for...
65.In section 279A (deferred unascertainable consideration: election for treatment of...
66.In section 279C (effect of election under section 279A), in...
67.In Schedule 1 (UK resident individuals not domiciled in UK),...
68.(1) Schedule 4C (transfers of value: attribution of gains to...
69.(1) Schedule 5 (attribution of gains to settlors with interest...
Part 1 Amendments to IHTA 1984 and related legislation
2.In section 5 (meaning of estate), for subsection (1B) substitute—...
4.In section 8D(9), omit the definitions of “tax year” and...
6.In section 18 (transfers between spouses or civil partners), in...
8.(1) Section 53 (exceptions from charge under section 52) is...
9.(1) Section 54 (exceptions from charge on death) is amended...
10.(1) Section 64 (charge at ten-year anniversary) is amended as...
11.(1) Section 65 (exit charges etc) is amended as follows....
12.(1) Section 74A (arrangements involving acquisition of interest in settled...
14.In section 80 (initial interest of settlor or spouse), in...
15.In section 81 (property moving between settlements), in subsection (1)—...
16.For section 81B substitute— Excluded property: property to which section...
17.Omit sections 82 and 82A (excluded property: property to which...
18.In section 94 (close companies: charge on participators), in subsection...
19.In section 136 (transfers within three years before death: transactions...
20.In section 155 (visiting forces etc), in subsections (2) and...
21.(1) Section 157 (non-residents’ bank accounts) is amended as follows....
22.In section 218 (non-resident trustees), in subsection (1)(a), for “domiciled...
23.Omit section 267 (persons treated as domiciled in United Kingdom)....
24.(1) Section 267ZA (election to be treated as domiciled in...
25.In section 267ZB (section 267ZA: further provision about election) (as...
26.Omit sections 267ZA and 267ZB (election to be treated as...
27.Before section 267A insert— Election to be treated as a...
28.(1) Section 272 (general interpretation) is amended as follows.
29.(1) Schedule A1 (non-excluded overseas property) is amended as follows....
30.In Schedule 4 (maintenance funds for historic buildings etc), in...
33.In paragraph 11 (exemptions from charge), in sub-paragraph (5), after...
34.In the italic heading before paragraph 12, for “resident or...
37.Inheritance Tax (Delivery of Accounts) (Excepted Estates) Regulations 2004 (S.I. 2004/2543)
38.In regulation 2 (interpretation)— (a) the existing text becomes paragraph...
39.(1) Regulation 4 (excepted estates) is amended as follows.
40.In regulation 5 (spouse, civil partner and charity transfers), in...
41.In regulation 5A (IHT threshold), in paragraph (4)(a), for “died...
42.In regulation 6 (production of information), in the heading, for...
43.(1) Regulation 6A (production of information) is amended as follows....
44.Inheritance Tax (Delivery of Accounts) (Excepted Settlements) Regulations 2008 (S.I. 2008/606)
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