Legislation to implement the previously announced changes to the DOTAS regime will be included in the first (pre-general election) Finance Bill of 2015 due to be published on 24 March 2015 (see Legal update, Finance Bill 2015 to be published on 24 March.

The changes include:

Regulations will also be published to make changes to the hallmarks including the financial product, standardised tax products, loss schemes and inheritance tax hallmarks. The inheritance tax hallmark will include schemes seeking to avoid IHT during a person's lifetime and after death.

These changes were announced in the 2014 Autumn Statement (see Legal update, 2014 Autumn Statement: business tax implications: Promoters and users of tax avoidance schemes) and draft legislation published for consultation on 10 December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Strengthening the DOTAS regime). To track the progress of these measures to implementation see Tax legislation tracker: compliance, disputes and investigations: Disclosure of tax avoidance schemes: publishing scheme and promoter details and Strengthening hallmarks and penalties

(See HM Treasury: March Budget 2015, paragraph 2.207.)

Legislation to implement two previously announced changes to the Promoters of Tax Avoidance Schemes (POTAS) regime will be included in the first (pre-general election) Finance Bill of 2015. These changes are to:

These measures were announced in the 2014 Autumn Statement (see Legal update, 2014 Autumn Statement: business tax implications: Promoters and users of tax avoidance schemes) and a tax information and impact assessment was published in December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Changes to the high risk promoters regime).

In addition, the government confirmed that legislation will be introduced "in due course" to widen the scope of the POTAS regime to bring promoters into the regime if a significant proportion of their notified schemes fail. HMRC consulted on these proposals in January 2015 (see Legal update, Consultation on sanctions for serial tax avoiders and GAAR-specific penalties).

For information about the POTAS regime, see Practice note, Tax avoidance schemes: high risk promoters: conduct and monitoring notices and to track the progress of these measures to implementation, see Tax legislation tracker: compliance, disputes and investigations: High-risk promoters: amendments.

(See HM Treasury: March Budget 2015, paragraphs 2.203 and 2.204 and Overview, paragraph 2.32.)

The government confirmed that legislation will be introduced in a future Finance Bill to impose further sanctions on serial tax avoiders. The additional sanctions will include increased financial penalties for inaccuracies in returns (where returns are inaccurate because of failed avoidance schemes), increased reporting obligations, "naming and shaming" and restricting access to tax reliefs.

HMRC consulted on these proposals in January 2015 (see Legal update, Consultation on sanctions for serial tax avoiders and GAAR-specific penalties). A response document has yet to be published.

To track the progress of this measure to implementation, see Tax legislation tracker: compliance, disputes and investigations: Deterring serial avoiders

(See HM Treasury: March Budget 2015, paragraph 1.243 and Overview, paragraph 2.32.)

Legislation will be introduced in a future Finance Bill to impose a tax-geared GAAR-specific penalty. HMRC consulted on whether such a penalty would have a useful deterrent effect in January 2015 (see Legal update, Consultation on sanctions for serial tax avoiders and GAAR-specific penalties). HMRC has yet to publish a response document or draft legislation. For details of the GAAR, see Practice note, General anti-abuse rule (GAAR) and to track the progress of this measure to implementation, see Tax legislation tracker: miscellaneous: GAAR-related penalties.

(See HM Treasury: March Budget 2015, paragraph 1.244 and Overview, paragraph 2.33.)

The Chancellor confirmed that HMRC is to issue 21,000 more accelerated payment notices than previously announced.

For information about accelerated payment notices, see Practice note, Tax avoidance schemes: follower and accelerated payment notices.

(See HM Treasury: March Budget 2015, paragraphs 1.245 and 2.206 and HM Treasury: Chancellor George Osborne's March Budget 2015 speech.)

On 19 March, the government will publish comprehensive plans for new criminal offences for tax evasion and new penalties for professionals who assist tax evaders. No further details are available but this appears to be a response to the recent HSBC controversy. In addition, the pre-election Finance Bill will include the enhanced civil penalties for offshore tax evasion confirmed in the 2014 Autumn Statement (see Tax legislation tracker: compliance, disputes and investigations: Strengthening civil sanctions for offshore evasion).

(See HM Treasury: Chancellor George Osborne's March Budget 2015 speech.)

The government will introduce legislation charging corporation tax for the financial year commencing on 1 April 2016 and setting the rate at 20%. The rate is unchanged from 2015 (for details of corporation tax rates for previous years, see Practice note, Tax rates and limits: Corporation tax).

The measure will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraph 2.136 and Overview, paragraph 1.12.)

The government announced that the draft diverted profits tax (DPT) legislation will be amended to:

DPT will apply from 1 April 2015. The new tax was introduced in the 2014 Autumn Statement and draft legislation for inclusion in the Finance Bill 2015 was published on 10 December 2014. DPT is designed to counteract multinational enterprises entering into arrangements to divert their profits from the UK and reduce their UK tax liability. Broadly, DPT will be charged at a rate of 25% on diverted taxable profits and may arise in two circumstances:

For a detailed discussion of DPT, see Practice note, Diverted profits tax.

For background to this measure, see Tax legislation tracker: corporate: Diverted profits tax.

The proposed amended legislation, will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraph 2.133 and Overview, paragraph 1.46.)

The Finance Bill 2015 will contain legislation preventing companies from using arrangements that convert carried-forward reliefs into more flexible sideways reliefs. If a company enters into such arrangements, it will not be able to use these carried-forward reliefs against the profit arising from the arrangement. However, any new deductible amount that the arrangements generate will be available for use against profits from the arrangement as normal.

This measure will apply to arrangements entered into at any time but will have effect for accounting periods beginning on or after 18 March 2015. Profits of an accounting period straddling that date will be split (on a time or otherwise just and reasonable basis) between the usual notional periods, with the measure applying to the period commencing on 18 March 2015.

The anti-avoidance rule applying to arrangements involving banking companies in draft section 269M of Part 7A of the Corporation Tax Act 2010 (CTA 2010) (see Legal update, 2014 Autumn Statement: business tax implications: Restricting carried forward reliefs for the banking sector) takes precedence over this measure. (It appears that draft section 269M will become section 269CK of that Act once it is enacted.)

The measure, which inserts a new Part 14B into CTA 2010, will apply if the following conditions are satisfied:

The relevant carried-forward reliefs are:

For an explanation of sideways relief, see Practice note, Corporation tax: general principles: Trading losses against total profits.

HMRC has published a technical note containing, among other things, examples of when the measure will and will not apply.

(See TIIN, Corporation tax: loss refresh prevention (including draft legislation) and HMRC: Corporation Tax: anti-avoidance rule to prevent loss refreshing.)

The government will make an announcement in the 2015 Autumn Statement about the amount of the capital allowances annual investment allowance (AIA) from 1 January 2016. The AIA is a 100% allowance for qualifying expenditure up to the allowance. It is currently set at £500,000 and is scheduled to reduce to £25,000 from 1 January 2016. The Chancellor is inclined to set it at a "much more generous rate".

For background, see Practice note, Tax rates and limits: Annual investment allowances.

(See HM Treasury: Chancellor George Osborne's March Budget 2015 speech.)

As announced in the 2014 Autumn Statement, from 1 January 2015, business contributions (which include cash and services) to flood and coastal erosion risk management (FCERM) projects will be fully deductible for corporation tax and income tax purposes. For background to this measure, see Legal update, 2014 Autumn Statement: business tax implications: Tax relief for contributions to flood defence projects.

However, the draft legislation, which was published on 10 December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Tax relief for contributions to flood defence), will be amended to expand the exceptions to a "disqualifying benefit", the receipt of which will result in a deduction for the contribution being denied.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See Overview, paragraph 1.9.)

The government will publish a roadmap in 2015 setting out proposed policy and administration changes to replace annual tax returns for individuals and small businesses with digital tax accounts. The government will also consult, in the summer of 2015, on a new payment process to allow income tax and national insurance contributions to be collected outside the PAYE and self assessment tax return system.

In his Budget speech, George Osborne announced that information to allow HMRC to assess most individuals' tax liability will be automatically uploaded into the new digital tax accounts. Only a minority of individuals with more complicated tax affairs will need to provide additional information to manage their accounts online.

This measure is intended to be implemented over the course of the next Parliament and will not be included in the pre-election Finance Bill.

(See HMRC: Making Tax Easier, HM Treasury: March Budget 2015, paragraph 1.108-1.109 and 2.187-2.188, Overview, paragraph 2.26 and HM Treasury, Chancellor George Osborne's March Budget 2015 speech.)

HMRC is considering the responses to a consultation that was held between 18 December 2014 and 12 March 2015 on a proposed power to enable HMRC to close one or more aspects of a tax enquiry while leaving other aspects open.

For background to this measure, see Legal update, Tax enquiries: HMRC consultation on individual aspect closure notices.

(See Overview, paragraph 2.31.)

HM Treasury will introduce regulations to impose due diligence and reporting obligations for UK financial institutions. The regulations will require financial institutions to identify UK tax resident account holders and to collect and report information on them. The changes ensure that the UK complies with its obligations under the EU Revised Directive on Administrative Cooperation (Council Directive 2014/107/EU) (DAC) to improve international tax compliance and the UK’s obligations under Competent Authority Agreements with non-EU jurisdictions for the Common Reporting Standard (CRS).

In addition, the regulations will:

Tax information exchange agreements (TIEA) allow the signatory governments to enforce their domestic tax laws by exchanging, on request, information relevant to a tax matter covered by the TIEA. The UK has signed a large number of TIEAs in recent years as a result of an Organisation for Economic Co-operation and Development (OECD) initiative to improve tax transparency by tax havens, see Practice note, Double taxation treaties and agreements (income, capital gains and corporation tax).

Draft legislation has yet to be published, but the regulations will have effect on and after 1 January 2016 in relation to the DAC and the CRS Competent Authority Agreements, and 21 days from the date these regulations are laid in relation to the Foreign Account Tax Compliance Act agreement. Shortly after the Budget, the regulations will be laid and a consultation response document will be published.

(See TIIN, Tax administration: regulations to implement the UK's automatic exchange of information agreements, HM Treasury: March Budget 2015, paragraph 2.196 and Overview, paragraph 1.44.)

The government will be empowered to legislate to require financial intermediaries and tax advisers to notify their UK resident customers with UK or overseas accounts of the full impact of the Common Reporting Standard (CRS), the opportunities to disclose and the penalties they could face for non-disclosure. For details of the CRS disclosure facility, see Early closure of Liechtenstein and Crown Dependency disclosure facilities. For more information about the CRS, see Tax legislation tracker: compliance, disputes and investigations: Implementing obligations under competent authority agreements and common reporting standards.

This measure will not be included in Finance Bill 2015, which is due to be published on 24 March 2015. The government intends to include it in future (presumably primary) legislation.

The government will also invest £4 million in data analytics resources to maximise the yield from CRS data.

(See HM Treasury: March Budget 2015, paragraphs 2.200 and 2.201 and Overview, paragraph 2.28.)

The Liechtenstein Disclosure Facility (LDF) and similar facilities for the Crown Dependencies (Jersey, Guernsey and the Isle of Man) will all close at the end of 2015, instead of April 2016 and September 2016 respectively. They will be replaced by a tougher disclosure facility with increased penalties and no immunity from criminal prosecution. The new facility will be introduced between 2016 and mid 2017 before the introduction of the OECD common reporting standard (CRS) (see Common Reporting Standard: intermediaries' duty to provide information).

The LDF agreed by the UK and Liechtenstein on 11 August 2009 is set out in a memorandum of understanding and supplemented by four joint declarations. The LDF enables taxpayers to declare previously undisclosed assets to HMRC, allowing qualifying taxpayers to regularise their tax affairs on favourable terms. For further information on the LDF see Practice note, UK/Switzerland tax co-operation agreement and Liechtenstein Disclosure Facility: comparison tables.

For information about the Crown Dependency facilities and the CRS, see Private client tax legislation tracker 2014-15: FATCA-style agreements with other jurisdictions.

(See HM Treasury: March Budget 2015, paragraphs 1.242, 2.198 and 2.199 and Overview, paragraphs 2.29 and 2.30.)

The government has confirmed its intention to introduce legislation to allow HMRC to directly recover tax debts from the bank and building society accounts of tax debtors.

Direct recovery of debts was first announced in May 2014 and draft legislation was published on 10 December 2014 (see Legal update, Direct recovery of debts: draft legislation). For further background, see Tax legislation tracker: compliance, disputes and investigations: Direct recovery of tax debts.

This measure will not be included in the first (pre-general election) Finance Bill of 2015 due to be published on 24 March 2015. Depending on the outcome of the general election on 7 May, it may be included in a future Finance Bill.

(See Overview, paragraph 2.34.)

As well as highlighting the defined contribution (DC) pension flexibility reforms coming into effect on 6 April 2015, the Chancellor made two main pensions-related announcements:

A call for evidence published alongside the Budget seeks views on how to develop a secondary annuities market. Among the questions for consultation are how annuity providers can resolve operational issues such as when to cease making income payments, and what form of consumer protection measures will be required. In that context, the government suggests the scope of the Pension Wise guidance service could be extended or annuity providers could be required to check annuity holders have received independent advice before assigning their annuity payments, mirroring the new system for DB-to-DC transfers. Consultation on the call for evidence runs until 18 June 2015.

Legislation enacting both the lifetime allowance and annuity assignment measures will be contained in a future Finance Bill.

For more detail, see Legal update, March 2015 Budget: key pensions announcements.

Legislation to implement an exemption for non-taxable expenses paid or reimbursed to an employee and to abolish the current dispensation regime will be in the pre-election Finance Bill. The measures will take effect from 6 April 2016.

As previously announced, the exemption will not be available if the expense is provided as part of a salary sacrifice arrangement. The exemption will also be unavailable if used in conjunction with other arrangements that seek to replace salary with expenses. (This further restriction was announced in the March 2015 Budget.)

The exemption was announced in the 2014 Autumn Statement (see Legal update, 2014 Autumn Statement: business tax implications: Employee benefits and expenses: OTS recommendations to be implemented) and draft legislation was published for consultation on 10 December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Employee benefits and expenses: exemption for paid or reimbursed expenses. To track the progress of the measure to implementation, see Tax legislation tracker: employment: Review of employee benefits and expenses.

(See HM Treasury: March Budget 2015, paragraph 2.190 and Overview, paragraph 1.5.)

Legislation to implement an exemption for trivial benefits in kind from 6 April 2015 will be included in the first (pre-general election) Finance Bill of 2015. The exemption will cover benefits in kind costing the employer less than £50 per employee provided the benefit is not provided as part of a salary sacrifice arrangement. The exemption will also be subject to an annual £300 cap that will apply to office holders of close companies and employees who are family members of those office holders. (This annual cap was announced in the March 2015 Budget.) An exemption from NICs will be introduced separately, which will also apply from 6 April 2015.

The exemption was announced in the 2014 Budget, confirmed in the 2014 Autumn Statement and draft legislation was published for consultation on 10 December 2014. For background and to track the progress of the measure to implementation, see Tax legislation tracker: employment: Review of employee benefits and expenses.

(See Notes on Finance Bill 2015 Resolutions, resolution 9, HM Treasury: March Budget 2015, paragraph 2.190 and Overview, paragraph 1.3.)

Legislation empowering HMRC to make regulations for the voluntary collection of income tax on certain benefits through the payroll from 6 April 2016 will be included in the first (pre-general election) Finance Bill of 2015. We are expecting the amending regulations to be published for consultation during the course of 2015.

Draft empowering legislation was published for consultation on 10 December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Employee benefits and expenses: voluntary payrolling of benefits). To track the progress of the measure to implementation, see Tax legislation tracker: employment: Review of employee benefits and expenses.

(See Notes on Finance Bill 2015 Resolutions, resolution 10 and HM Treasury: March Budget 2015, paragraph 2.190.)

Legislation to abolish the tax exemption for certain directors and employees in lower-paid employment from 6 April 2016 will be included in the first (pre-general election) Finance Bill of 2015. The exemption will be replaced with a new exemption for certain carers and for ministers of religion.

The abolition of the £8,500 threshold was announced in the 2014 Autumn Statement (see Legal update, 2014 Autumn Statement: business tax implications: Employee benefits and expenses: OTS recommendations to be implemented) and draft legislation was published for consultation on 10 December 2014 (see Legal update, Draft Finance Bill 2015 legislation: key business tax measures: Abolition of £8,500 "higher paid" threshold and new benefits exemptions for carers and ministers. To track the progress of the measure to implementation, see Tax legislation tracker: employment: Review of employee benefits and expenses.

(See HM Treasury: March Budget 2015, paragraph 2.190.)

The government will consult on restricting travel and subsistence reliefs for workers engaged through an employment intermediary and under the supervision, direction and control of the end-user. Any legislative changes will take effect from 6 April 2016 and will be legislated for in a future Finance Bill. For an overview of those reliefs, see Practice note, Taxation of employees: benefits and expenses: Travelling expenses and Accommodation and meals (subsistence).

This announcement follows the government's publication, after the 2014 Autumn Statement, of a discussion paper on the use of umbrella companies and other employment intermediaries to change a series of permanent workplaces (for which there is no tax relief) into temporary workplaces (for which relief is due). For more detail, see Tax legislation tracker: employment: Employment intermediaries and travel costs of temporary workers.

The government has also announced that the Department of Business, Innovation and Skills will consult later this year on proposals to require employment intermediaries to provide workers with greater transparency on how they are employed and what they are paid. This follows concerns raised that individuals do not understand how these arrangement affect their take-home pay.

(See HM Treasury: March Budget 2015, paragraphs 1.250, 1.251 and 2.79, and Overview, paragraph 2.37.)

As part of the March 2015 Budget, the government stated that it welcomed the final report of the OTS on employment status, which was published on 3 March 2015, and that it would respond to the recommendations set out in that report in the next parliament.

For background, including the details of the report of the OTS and its recommendations, see Tax legislation tracker: employment: Review of employment status.

(See HM Treasury: March Budget 2015, paragraph 2.189.)

The government has confirmed that the company car tax measures announced in the 2014 Budget (see Legal update, 2014 Budget: key business tax announcements: Cars, vans and related fuel benefits) will be included in the (pre-election) Finance Bill 2015. For 2017-18 and 2018-19, the appropriate percentage of list price subject to tax will increase by 2 percentage points for cars emitting more than 75 gCO2/km, to a maximum of 37%. In 2017-18 there will be a 4 percentage point differential between the 0-50 and 51-75 gCO2/km bands and between the 51-75 and 76-94 gCO2/km bands. In 2018-19, the differential will reduce to 3 percentage points.

In a future (post-election) Finance Bill, for 2019-20, the appropriate percentage of list price subject to tax will increase by 3 percentage points for cars emitting more than 75 gCO2/km, to a maximum of 37%. There will be a 3 percentage point differential between the 0-50 and 51-75 gCO2/km bands and between the 51- 75 and 76-94 gCO2/km bands.

The government will review incentives for ultra low emission vehicles in the 2016 Budget.

The government has confirmed that the (pre-election) Finance Bill 2015 will increase the current van benefit charge (£nil) for zero emission vans from 2015-16. The charge will be 20% of the value of the van benefit charge for vans emitting CO2 in 2015-16, 40% in 2016-17, 60% in 2017-18, 80% in 2018-19 and 90% in 2019-20. From 2020-21, there will be a single van benefit charge applying to all vans.

Secondary legislation will be introduced later this year to increase the van benefit charge in line with inflation with effect from 6 April 2016.

Secondary legislation will be introduced to increase the fuel benefit charge multipliers for both company cars and vans in line with inflation with effect from 6 April 2016.

(See HM Treasury: March Budget 2015, paragraphs 1.120 and 2.160-2.164 and Overview, paragraphs 1.2 and 2.2-2.5.)

The most significant development is the announcement that the capital gains tax entrepreneurs' relief (ER) qualification rules are amended for disposals on or after 18 March 2015. This change is most likely intended to target "manco" structures under which executives would be directors of, and each hold 5% shareholdings in, a specially-formed company which in turn held growth shares representing 10% of the ordinary share capital of a trading company (taking advantage of the definition of joint venture in the ER legislation). This allowed the executives to qualify for ER, despite each of their shareholdings representing only 0.5% of the trading company’s ordinary share capital.

For more detail, see Legal update, March 2015 Budget: share schemes and incentives implications and Entrepreneurs' relief denied for shares in companies without a trade of their own.

The energy-saving and water efficient enhanced capital allowance (ECA) schemes will be updated to:

Subject to state aid approval (and depending on the outcome of the general election on 7 May), this change will come into effect by Treasury Order in summer 2015. Businesses planning to invest in these technologies might want to consider delaying or accelerating investment to benefit from ECAs.

Under the ECA schemes, a 100% allowance is available to businesses investing in qualifying plant and machinery. For more information on energy-saving and water efficient ECAs, see Practice note, Enhanced capital allowances (ECAs) for investment in environmental technologies.

(See Overview, paragraph 2.14.)

For all environment announcements, see Legal update, March 2015 Budget: key environmental announcements.

As part of the March 2015 Budget, the government confirmed that it intends to proceed with its reform of the loan relationships and derivatives rules (as to which, see Practice notes, Loan relationships and Derivatives: tax).

The proposed changes are wide-ranging, including having sole regard to profit and loss accounts (and not other accounts), new relief for corporate rescues and a new regime anti-avoidance rule. The legislation to effect these changes was previously published in draft in two stages:

For further background to this reform, see Tax legislation tracker: finance: Reform of loan relationship and derivative contract rules.

The government stated as part of the March 2015 Budget that no (presumably, substantive) changes from the draft legislation were proposed.

Most of these measures will not be included in the first (pre-general election) Finance Bill of 2015, due to be published on 24 March 2015 (see Legal update, Finance Bill 2015 to be published on 24 March). Depending on the outcome of the general election on 7 May 2015, they may be included in a future Finance Bill. However, the proposed changes to the late paid interest rules are to be included in the first Finance Bill 2015.

One surprising omission from the legislation to be included in the first Finance Bill 2015 is the relief for corporate rescues, which was previously stated to apply to releases, modifications or replacements from 1 January 2015 (see Legal update, Draft Finance Bill 2015 changes to loan relationships and derivative contracts rules: Corporate rescues). Taxpayers will hope that the deferral of enactment of this measure will not lead to the deferral of the start date as this extension would prove helpful to companies already in financial distress. However, it may be that the deferral of most of the proposed legislation will lead to the start date of various proposed anti-avoidance rules (notably, the regime anti-avoidance rule, as to which, see Practice note, Loan relationships: Regime anti-avoidance rule), which were previously stated to have effect, broadly, for arrangements entered into from 1 April 2015, being pushed back, which would be more warmly received by taxpayers.

(See HM Treasury: March Budget 2015, paragraphs 2.137 and 2.193 and Overview, page 20.)

As announced as part of the 2014 Autumn Statement, legislation is to be introduced to provide a new relief allowing individuals lending through peer-to-peer (P2P) platforms to offset any losses from loans that go bad against other P2P interest received. This measure is to be effective from April 2016 and, through self-assessment, is to allow individuals to claim relief for losses incurred from April 2015.

As part of the March 2015 Budget, the government stated that a technical note on this measure was to be published "shortly after" that Budget.

For background to this measure, see Tax legislation tracker: finance: Peer-to-peer lending.

This measure will not be included in the first (pre-general election) Finance Bill of 2015. Depending on the outcome of the general election on 7 May 2015, it may be included in a future Finance Bill, with draft legislation currently planned to be published in 2015.

(See HM Treasury: March Budget 2015, paragraph 2.89 and Overview, paragraph 2.7.)

As announced as part of the 2014 Autumn Statement, interest on qualifying private placements (a form of long-term, non-bank, unlisted debt) is to be exempt from withholding of income tax to help unlock new finance for businesses and infrastructure projects. As part of the March 2015 Budget, it was announced that the primary legislation enabling this change (published in draft on 10 December 2014) will be amended to remove a condition relating to the minimum term of the security.

For background to this measure, see Tax legislation tracker: finance: Withholding exemption for private placements.

This measure will be included in the first (pre-general election) Finance Bill of 2015, due to be published on 24 March 2015 (see Legal update, Finance Bill 2015 to be published on 24 March). That primary legislation, containing the power to make regulations, will have effect from Royal Assent to the Finance Bill 2015, and the regulations are to be laid later in 2015.

(See HM Treasury: March Budget 2015, paragraph 2.130 and Overview, paragraph 1.6.)

The rates of the bank levy are to increase from 0.156% to 0.21% (for short-term liabilities) and from to 0.078% to 0.105% (for long-term equity and liabilities) from 1 April 2015. Although not stated explicitly, it may be expected that, if a chargeable period straddles 1 April 2015, the new rate(s) will apply (only) to proportions of such periods falling on or after that date (as this is the usual approach to bank levy rate increases), although this will only be certain when the draft legislation is published.

For a discussion of the bank levy, see Practice note, Bank levy.

It appears that this measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Bank levy: rate change.)

The Finance Bill 2015 will introduce a modified measure restricting to 50% the proportion of banks' and building societies' taxable profit that can be offset by carried-forward trading losses, non-trading loan relationship deficits and management expenses.

Following consultation on the draft legislation published as part of the 2014 Autumn Statement (as to which, see Legal update, 2014 Autumn Statement: business tax implications: Restricting carried forward reliefs for the banking sector), the amendment consists of an allowance of £25 million for groups headed by a building society. This is intended to reduce for building societies only the carried-forward reliefs that are subject to the restriction.

The restriction will apply from 1 April 2015 (with the usual straddle period rules) but only to reliefs accruing before that date.

(See HM Treasury: March Budget 2015, paragraph 2.138 and Overview, paragraph 1.14.)

The government is to bar compensation payments made by banks from being deductible for corporation tax purposes. The detail is sketchy. The Budget 2015 document refers to "compensation associated with widespread misconduct in the sector" and the policy costings document refers to "costs in respect of compensation to customers in relation to the provision of financial services" (in particular, noting "payment protection insurance mis-selling").

Legislation will be introduced in a future Finance Bill and not in the first (pre-general election) Finance Bill 2015.

(See HM Treasury: March Budget 2015, paragraph 1.248, Overview, paragraph 2.15 and HM Government: Budget 2015: policy costings, page 26 and paragraph B.7.)

The government confirmed that legislation will be introduced providing that guaranteed fee income of investment managers arising on or after 6 April 2015 will be subject to income tax.

The measure was initially announced in the 2014 Autumn Statement and was included in draft legislation for inclusion in the Finance Bill 2015. Following consultation, the legislation will be amended to:

The measure aims to prevent managers converting trading income into capital receipts and is in response to private equity fund managers increasingly using structures in which annual fees are paid as priority partnership shares to avoid income tax. Sums received for investment management services provided to collective investment schemes through arrangements involving any number of partnerships will be caught unless they represent "carried interest" or constitute a return on capital invested by the individual. For more information, see Practice note, Carried interest: tax: Anti-avoidance: disguised management fees.

For background to this measure, see Tax legislation tracker: investment structures: Disguised fee income of investment managers.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See Overview, paragraph 1.4.)

It was announced as part of the March 2015 Budget that film tax relief is to be increased, removing the distinction between limited budget films (with core expenditure of £20 million or less) and bigger budget films for these purposes, subject to state aid approval.

At present, limited budget films are eligible for an enhanced deduction for 100% of their qualifying expenditure whereas this figure is 80% for bigger budget films (see Practice note, Film tax relief: Enhanced tax deduction). Under the proposed changes, the figure will be 100% for all films. In addition, under the current rules, the payable tax credit is 25% on the first £20 million of losses surrendered and 20% thereafter (see Practice note, Film tax relief: Payable tax credit). Under the proposed changes, this will be increased to 25% in all cases.

These changes will have effect from 1 April 2015 or, if later, the date of state aid approval.

For a discussion of film tax relief generally, see Practice note, Film tax relief.

It appears that this measure is expected to be included in the first (pre-general election) Finance Bill of 2015, due to be published on 24 March 2015 (see Legal update, Finance Bill 2015 to be published on 24 March).

(See TIIN, Corporation tax: increasing the rate of film tax relief and Overview, paragraph 1.17.)

As part of the March 2015 Budget, it was announced that, as suggested as part of the 2014 Autumn Statement, the rules providing tax relief for high-end television (broadly, dramas and documentaries) and animation will be expanded and modernised. Under the changes, subject to state aid clearance, the minimum UK expenditure requirement will be reduced from 25% to 10% and the cultural test will be modernised to reflect similar changes made to the film tax relief cultural test (as to which, see Legal update, Revised cultural test for film tax relief: final regulation made). The reduction in the UK expenditure requirement is to have effect for qualifying expenditure incurred on or after 1 April 2015 (subject to state aid clearance); the effective date of the cultural test modernisation also appears to be 1 April 2015.

For background to this measure, see Tax legislation tracker: intellectual property: Amendments to high-end television relief.

It appears that this measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Corporation tax: high-end television tax relief and Overview, paragraph 1.15.)

As announced as part of the 2014 Autumn Statement, the government will introduce a new corporation tax relief for making children's television programmes with effect from 1 April 2015.

The relief will be at a rate of 25% on qualifying production expenditure. As part of the March 2015 Budget, it was announced that the legislation (published in draft on 10 December 2014) is to be amended to include children's programmes that are game shows or competitions.

For background to this measure, see Tax legislation tracker: intellectual property: Children's television relief.

It appears that this measure will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraphs 1.112 and 2.124 and Overview, paragraph 1.16.)

As part of the March 2015 Budget, the government confirmed that it intends to introduce a new corporation tax relief for orchestras. This relief is to be available to eligible companies from April 2016 at a rate of 25% on qualifying expenditure. A summary of responses to the government's consultation is due for publication "shortly".

For background to this measure, see Tax legislation tracker: intellectual property: Orchestra relief.

This measure is not to be included in the first (pre-general election) Finance Bill of 2015. Depending on the outcome of the general election on 7 May 2015, it may be included in a future Finance Bill.

(See HM Treasury: March Budget 2015, paragraphs 1.112 and 2.121, Overview, paragraph 2.16 and HM Government: March Budget 2015: policy costings, page 19.)

As announced as part of the 2014 Autumn Statement, the research and development (R&D) rules are to be amended so that the costs of materials incorporated in products that are sold will be excluded from qualifying expenditure attracting R&D credits from 1 April 2015. As part of the March 2015 Budget, it was announced that the legislation (which was published in draft on 10 December 2014) will be amended to clarify that the restriction will not apply if the product is transferred as waste or is transferred without any consideration being received. The government also confirmed that the rate of the above the line credit will increase from 10% to 11% and the rate for the SME scheme will increase from 225% to 230%, both with effect from 1 April 2015.

For background to these measures, see Tax legislation tracker: intellectual property: Restriction of R&D qualifying expenditure and Tax legislation tracker: intellectual property: Increase in R&D tax credits.

It appears that these measures will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraphs 2.126 and 2.127 and Overview, paragraph 1.18.)

The government will introduce a package of measures designed to facilitate claims for research and development (R&D) tax credits by small businesses. The package includes:

The announcement follows a consultation that was announced in the 2014 Autumn Statement and took place between 16 January and 27 February 2015. For background on the measure, see Legal update, Consultation launched on R&D credits for SMEs and for background on R&D credits generally, see Practice note, R&D tax reliefs: practical aspects.

HMRC will publish a roadmap during the summer of 2015 setting out further improvements (assumed to be in addition to the specific measures described above) to the scheme to encourage claims by small businesses.

(See HM Treasury: March Budget 2015, paragraphs 1.119 and 2.128.)

The supplementary charge will be reduced to 20% (from 32%). The reduced rate will apply from 1 January 2015 and transitional rules for accounting periods beginning before this date will apply. The reduction is aimed at encouraging additional investment, driving higher production and ensuring that the UK continental shelf remains competitive. It is likely to be welcomed by the industry in the face of falling oil and gas prices.

The supplementary charge is assessable on a company's ring fence profits (the company's profits from its UK oil extraction business) that are calculated without deducting any costs of debt finance (see Practice note, Oil and gas taxation: Ring fence rules and Supplementary charge). Today's statement supersedes 2014 Autumn Statement announcement that the rate would go down to 30% (see Tax legislation tracker: property, energy and environment: Reduction in supplementary charge).

It is expected that this measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Corporation tax: oil and gas companies: investment allowance and reduction in supplementary charge, HM Treasury: March Budget 2015, paragraphs 1.129 and 2.142, Overview, paragraph 1.21 and HM Government: March Budget 2015: policy costings, page 23.)

A new basin-wide investment allowance will be introduced for oil and gas companies operating a ring fence trade in the UK or UK continental shelf. It will be available for investment expenditure incurred on or after 1 April 2015 on projects in new and existing fields. The allowance will operate by removing an amount equal to 62.5% of the investment expenditure from the company's adjusted ring fence profits that are subject to the supplementary charge. This, along with other oil and gas measures announced (see Supplementary charge to be reduced to 20% from 1 January 2015) will hopefully provide a much needed boost for the industry.

Existing field allowances will be abolished so that they are not available after 30 April 2015. Transitional arrangements will apply for fields that currently receive a field allowance.

A response to HM Treasury's consultation on this measure is expected to be published shortly.

For background to this measure, see Tax legislation tracker: property, energy and environment: Review of oil and gas regime.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Corporation tax: oil and gas companies: investment allowance and reduction in supplementary charge, HM Treasury: March Budget 2015, paragraphs 1.129 and 2.141, Overview, paragraph 1.19 and HM Government: March Budget 2015: policy costings, page 23.)

The government announced that the legislation introducing the new high pressure, high temperature cluster area allowance will be amended to include a power to make secondary legislation extending the definition of qualifying expenditure qualifying for the allowance. A restriction on expenditure incurred on the acquisition of a licence interest will also be introduced.

The new allowance was announced in the 2014 Autumn Statement and included in draft legislation for inclusion in the Finance Bill 2015. It will operate by exempting a portion of a company's profits from the supplementary charge. The amount of adjusted ring fence profits subject to the supplementary charge will be reduced by 62.5% of capital expenditure incurred in designated cluster areas on or after 3 December 2014 (see Practice note, Oil and gas taxation: Field allowances).

For background to this measure, see Tax legislation tracker: property, energy and environment: Ultra high pressure/high temperature cluster allowance.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraph 2.140 and Overview, paragraph 1.20.)

The rate of petroleum revenue tax will fall to 35% (from 50%) with effect for chargeable periods ending after 31 December 2015. This measure forms part of a package announced to assist a recovery of the UK's oil and gas industry.

Petroleum revenue tax is, broadly, chargeable on profits arising to licensees of taxable fields from oil and gas production (see Practice note, Oil and gas taxation: Petroleum revenue tax).

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Corporation tax: oil and gas companies: investment allowance and reduction in supplementary charge, HM Treasury: March Budget 2015, paragraph 1.129 and 2.143, Overview, paragraph 1.22 and HM Government: March Budget 2015: policy costings, page 23.)

With effect from 18 March 2015, individuals wishing to claim entrepreneurs' relief on the gain arising on the disposal of a personally owned asset that has been used in their business or personal company must, at the same time, make a significant disposal of their share in the business or shareholding in the company. Until now, any disposal out of a material holding was sufficient to trigger the entitlement to claim relief on disposal of the associated asset and thus pay CGT at a rate of 10%.

To prevent minor or short term reductions in partnership share or shareholding that might be undertaken simply in order to qualify for relief on the sale of a personal asset, section 169K of TCGA 1992 is to be amended to require a disposal of an interest representing at least 5% of the assets of a partnership or 5% of the ordinary shares or securities of a personal trading company, with the condition that there are no arrangements to reacquire an increased share in the partnership or additional shares in the company. The relief is intended to benefit individuals who are permanently withdrawing from a business.

For more information on entrepreneurs' relief, see Practice note, Entrepreneurs' relief.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN, Capital gains tax: restricting entrepreneurs’ relief on associated disposals (including draft legislation), HM Treasury: March Budget 2015, paragraphs 1.252 and 2.96 and Overview, paragraph 1.38.)

The Chancellor has announced that, for the purposes of entrepreneurs' relief (ER), with effect from 18 March 2015, a company will not qualify as a trading company simply by virtue of its participation in a joint venture (JV) or partnership. ER operates to reduce to a rate of 10%, for the first £10 million of gains, the capital gains tax chargeable on the disposal of shares in a qualifying personal trading company of which the seller is an employee or officer.

Draft legislation released as part of the March 2015 Budget documentation amends the definition of "trading company" and "trading group". A company that does not carry on a trade of its own will no longer, for the purposes of ER be able to treat its share of the trade of a partnership or JV of which it is a member as constituting a trading activity. This change has been introduced to prevent the use of structures which contrive for individuals to be directors of a company in which they each own 5% of the shares and for that company, which has no trade of its own, to own 10% of the shares of the trading company. This was seen as an abuse of a relief that was intended to benefit the owners of a business. For background, see Employee incentives.

For more information on entrepreneurs' relief, see Practice note, Entrepreneurs' relief.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See TIIN: Capital gains tax: entrepreneurs’ relief, joint ventures and partnerships (including draft legislation) and Overview, paragraph 1.39.)

The Chancellor confirmed that, as announced in the 2014 Autumn Statement, sole traders and partners who transfer their business to a related close company on or after 3 December 2014 will be not be entitled to claim ER on the value of the goodwill. However, as a result of the consultation on the draft legislation, the restriction will not apply to partners who dispose of their partnership share to a company but do not acquire shares in that company or in any associated company.

For more information on the incorporation of a business, see Practice note, Incorporating a partnership: tax issues.

For background to this measure, see Tax legislation tracker: owner-managed business: Denial of entrepreneurs' relief on goodwill transferred to related company.

This measure will be included in the first (pre-general election) Finance Bill of 2015.

(See HM Treasury: March Budget 2015, paragraph 2.98 and Overview, paragraph 1.41.)

The Chancellor announced in the March 2015 Budget that the government will review the ER treatment of academics who dispose of shares in spin out companies that exploit intellectual property to which they have contributed.

To qualify for ER, an individual needs to hold at least 5% of the shares in a trading company and to be an employee or officer of that company in the 12 months ending on the date of sale. For academics, these requirements are difficult to meet both because of their academic commitments and because the funding required to develop the product is likely to mean that they are left with less than 5% of the shares in the spin out company.

This measure will not be included in the first (pre-general election) Finance Bill of 2015. Depending on the outcome of the general election on 7 May, it may be included in a later Finance Bill in 2015 or 2016.

(See HM Treasury: March Budget 2015, paragraph 2.97 and Overview, paragraph 2.22..)

The government intends to abolish Class 2 NICs in the next parliament and reform Class 4 NICs to introduce a new contributory benefit test. The government will consult on the detail and timing of these reforms later in 2015.

Class 2 NICs are payable by self-employed persons at a flat weekly rate (£2.75 for this year and from 6 April 2015), with an exception for earnings under a certain limit (£5,885 for this year and from 6 April 2015). Class 4 NICs are payable by self-employed persons whose profits exceed the lower profits limit (currently £7,956 per year and, from 6 April 2015, £8,060 per year). They are payable at 9% on profits between the lower profits limit and the upper profits limit (currently £41,865 per year and, from 6 April 2015, £42,385 per year) at 2% on profits above the upper profits limit. (See Legal update, NICs rates and thresholds from 6 April 2015: regulations made.)

These changes are stated to be part of the government's Making Tax Easier programme. However, given their focus on the self-employed, the government appears to be trying to make it easier for taxpayers to establish their own businesses.

(See HM Treasury: March Budget 2015, paragraphs 1.109 and 2.74, and Overview, paragraph 2.36.)

The Chancellor confirmed that legislation is to be introduced in the first (pre-general election) Finance Bill of 2015 to exclude companies that benefit "substantially" from any subsidy for the generation of renewable energy from qualifying for relief under the venture capital schemes unless the company is a qualifying community energy organisation. The restriction was announced in the 2014 Autumn Statement (see Legal update, 2014 Autumn Statement: business tax implications: Venture capital schemes restrictions and process) and draft Finance Bill clauses published on 10 December 2014 (see Legal updates, Draft Finance Bill 2015 legislation: key business tax measures: Venture capital schemes restrictions and Finance Bill 2015: enlarging the social investment tax relief (SITR) scheme). It is confirmed that, following consultation on the draft clauses, the legislation has been revised to ensure that the exclusion extends to equivalent foreign subsidies. The restrictions will take effect for shares issued on or after 6 April 2015 (for EIS and SEIS purposes) and for holdings issued on or after 6 April 2015 (for VCT purposes). It is also confirmed that the Social Investment Tax Relief scheme is to be expanded (subject to obtaining state aid clearance). From the date of expansion, qualifying community energy companies will become eligible for SITR and, subject to a six month transitional period, will cease to qualify under the venture capital schemes.

To track the progress of these measures to implementation, see Tax legislation tracker: owner-managed business: Venture capital schemes: restrictions and processes.

It was also announced that, subject to obtaining state aid approval (and with effect from that date), the government intends to amend the venture capital schemes to:

It is clear that many of these measures arise from the summer 2014 consultation that sought evidence on the venture capital schemes' compliance with revised state aid rules (as to which, see Legal update, Venture capital schemes consultation). HM Treasury and HMRC have yet to publish a summary of responses to that consultation, which also sought views on anti-dilution clauses and on whether companies should be permitted to access short-term funding through convertible loans. Draft legislation to implement the announced changes has also not been published.

Finally, the government also intends to remove the requirement that a company that has issued shares under SEIS must spend at least 70% of the money raised before raising EIS and VCT funds. This change is to take effect from 6 April 2015. The government has also announced the launch of a new industry forum on the operation and use of the venture capital schemes.

For information about the venture capital schemes, see Practice notes, Venture Capital Trusts, Enterprise Investment Scheme and Seed Enterprise Investment Scheme. For information about SITR, see Practice note, Social investment tax relief (SITR).

(See Overview, paragraphs 1.7 and 1.8, Notes on Finance Bill 2015 Resolutions, resolutions 21 and 22 and HM Treasury, March Budget 2015, paragraphs 1.200, 1.201, 2.75, 2.76 and 2.77.)

The government intends to consider or take forward over 70% of recommendations included in the Office of Tax Simplification's (OTS) final report on partnership taxation.

The government asked the OTS to carry out a review of partnership taxation as part of the 2013 Budget. The OTS published an interim report on 22 January 2014, an update on its review on 25 July 2014 and its final report on 19 January 2015. The final report included recommendations that HMRC clarify its guidance and improve its administrative procedures relating to partnerships.

For background to this measure, see Tax legislation tracker: miscellaneous: Review of partnership taxation.

(See HM Treasury: March Budget 2015, paragraph 2.194.)

The government confirmed that it will amend the simplified regime for deducting expenses of using a home for business purposes (as to which, see Practice note, Income tax: calculation of income profits: Use of home for business purposes) to ensure that partnerships can fully access the regime and to cater for business premises that are also a home. It appears that the government intends to make no changes to the draft legislation effecting this measure that was published on 10 December 2014.

For background to this measure, including the draft legislation, see Tax legislation tracker: miscellaneous: Home use by partners: fixed rate deductions.

This measure will not be included in the first (pre-general election) Finance Bill of 2015. Depending on the outcome of the general election on 7 May 2015, it may be included in a future Finance Bill.

(See HM Treasury: March Budget 2015, paragraph 2.191 and Overview, page 20.)

The personal allowance will rise from its previously announced level of £10,600 (for those born after 5 April 1938) or £10,660 (for those born before 6 April 1938) for 2015-16 to £10,800 for 2016-17 and £11,000 for 2017-18. The rates for 2016-17 and 2017-18 will apply to all taxpayers, regardless of their date of birth. At the same time, the basic rate limit will be increased from £31,875 to £31,900 for 2016-17 and £32,300 for 2017-18.

The higher rate threshold will be £42,385 (2015-16), £42,700 (2016-17) and £43,300 (2017-18). The basic, higher and additional rates of income tax will not change for 2015-16. The NICs upper earnings and upper profits limits will increase in line with the higher rate threshold.

The Chancellor described these measures as a "down-payment on our commitment to raise the personal allowance to £12,500 and the higher rate threshold to £50,000".

As announced in the 2014 Autumn Statement, the blind person's allowance, the married couple's allowance and the income limit will increase by amounts equivalent to the retail prices index.

For details of previous income tax rates and allowances, see Practice note, Tax rates and limits: Income tax.

These measures will be included in the first (pre-general election) Finance Bill of 2015.

(See Overview, paragraph 1.1, TIIN, Income tax: personal allowance and basic rate limit for 2016-17 and 2017-18, HM Treasury: March Budget 2015, paragraphs 2.66, 2.67 and 2.70 and HM Treasury: Chancellor George Osborne's March Budget 2015 speech.)

The government will introduce a personal savings allowance (PSA) from 6 April 2016. For basic rate taxpayers, the first £1,000 of savings income will be free of tax and for higher rate taxpayers, the first £500. There will be no allowance for additional rate taxpayers. The PSA will be in addition to ISA allowances.

The government will discuss implementation issues with the savings and investment industry and other interested groups. Financial institutions will stop deducting 20% in income tax from interest on non-ISA savings from April 2016. HMRC will introduce automated coding out of savings income that remains taxable through the PAYE system from 2017-18, with pilots starting in autumn 2015.

For more information about income tax rates and allowances, see Practice note, Tax data: income tax: Individuals: rates and allowances.

This measure will not be included in the pre-election Finance Bill. Depending on the outcome of the general election on 7 May, it may be included in a future Finance Bill.

(See HM Treasury: Abolishing tax on savings for 95% of savers, HM Treasury: March Budget 2015, paragraph 2.84 and Overview, paragraph 2.1.)

As announced in Autumn Statement 2014, the annual charge paid by some non-UK domiciled but UK resident individuals who use the remittance basis of taxation will increase from April 2015. The charge for those who have been UK resident for at least seven out of the nine tax years before the relevant tax year will remain at £30,000. The charge for those who have been UK resident for at least 12 out of the previous 14 tax years will increase from £50,000 to £60,000. There will be a new charge of £90,000 for those who have been UK resident for at least 17 out of the previous 20 tax years.

For more information about the current rules, see Practice notes, Remittance basis: what individuals need to know: overview and Remittance basis: remittance basis charge.

For more information about the announcements on the changes in Autumn Statement 2014 and the government's consultation on making an election to use the remittance basis apply for a minimum of three years see 2014 Autumn statement: private client implications: Remittance basis charges to increase.

This measure will be included in the pre-election Finance Bill.

(See HM Treasury: March Budget 2015, paragraph 2.73 and Overview, page 12.)

Regulations will be introduced to:

In addition, the government will introduce a new Help to Buy ISA. The scheme will work by providing a government bonus to each person who has saved into a Help to Buy ISA at the point they use their savings to purchase their first home. For every £200 a first time buyer saves, the government will provide a £50 bonus up to a maximum of £12,000 of savings. The government intends the scheme to be available from Autumn 2015.

These measures will not be included in the pre-election Finance Bill.

(See HM Treasury: Help to Buy: ISA: scheme outline, Help to Buy: ISA - factsheet and HM Treasury: March Budget 2015, paragraphs 1.24, 1.228, 2.80, 2.83 and 2.85, Overview, paragraphs 2.10 and 2.11 and HM Government: March Budget 2015: policy costings, pages 10 -12, appendices B1 and B8.)

The government has announced that it will amend the exemption from capital gains tax (CGT) in section 45 of the Taxation of Chargeable Gains Act 1992 that applies on the disposal of a wasting asset, to require that the asset has been used in the business of the person disposing of it.

The announcement is a direct response to HMRC v The Executors of Lord Howard of Henderskelfe (deceased) [2014] EWCA Civ 278, in which the Court of Appeal held that a painting owned by an individual's estate but used by a company operating a tourist attraction was plant, notwithstanding that the owner differed from the business operator, and was therefore, a wasting asset, the chargeable gain on the disposal of which was exempt from CGT.

For further detail on the decision, see Legal update, Painting held to be wasting asset (Court of Appeal) and for further background on the wasting assets exemption from CGT, see Practice note, Tax on chargeable gains: general principles: Exemptions from tax on chargeable gains: Wasting assets: exemption.

This measure will be included in the first (pre-general election) Finance Bill of 2015 and will take effect for chargeable gains accruing on or after 1 April 2015 for corporation tax purposes or 6 April 2015 for CGT purposes.

(See TIIN, Capital gains tax: exemption for certain wasting assets, HM Treasury: March Budget 2015, paragraph 2.103 and Overview, paragraph 1.40.)

In the 2014 Autumn Statement, the government announced that it would introduce a stand-alone Social Venture Capital Trust scheme to enable retail investors to make indirect investments in social enterprises via a separate legal entity, similar to and based on the Venture Capital Trust (VCT) scheme. Specific design features of the new scheme were then announced, see Legal update, Finance Bill 2015: enlarging the social investment tax relief (SITR) scheme: New social Venture Capital Trust scheme.

The government has now announced the following further design features:

The legislation will not be in the pre-election Finance Bill. For further information about VCTs, see Practice note, Venture Capital Trusts.

(See HM Treasury: Budget 2015 announcements on Social Investment Tax Relief (18 March 2015) and March Budget 2015, paragraph 2.77 and Overview, paragraph 2.12.)

For all private client and charity announcements, see Legal update, March 2015 Budget: key private client tax announcements.

The government has confirmed that, from 6 April 2015, non-UK resident persons (including individuals, trustees, personal representatives and certain closely-held companies), will be subject to capital gains tax on disposals of UK residential property. Non-resident individuals will be subject to tax at the same rates as UK resident individuals (28% or 18% on gains above the annual exempt amount). Non-resident companies will be subject to tax at the same rates as UK companies (20%) and will have access to an indexation allowance.

The government consulted on these changes in 2014 and draft legislation was published on 10 December 2014. For further information on these proposed provisions, see Practice note, Capital gains tax: disposals of UK residential property by non-residents.

It appears this measure will be included in the pre-election Finance Bill.

(See HM Treasury: March Budget 2015, paragraph 2.100, Overview, page 13, and HMRC: Capital Gains Tax for non-UK residents: sales and disposals of UK residential property: Frequently Asked Questions (18 March 2015).)

The government has again confirmed its commitment to:

Currently, SDLT is payable if an existing property portfolio is used to seed a new PAIF (see Practice note, Property authorised investment funds: tax: SDLT). As co-ownership ACSs are transparent for income taxes, it is arguable that they are also transparent for SDLT purposes. Therefore, no SDLT should be payable on a transfer of properties to the ACS in return for units in the ACS but SDLT will be payable on the issue, transfer or redemption of units (see Practice note, Authorised contractual schemes: tax: Stamp duty land tax).

A consultation on these measures was launched on 18 July 2014 and the government confirmed its commitment to introducing the measures in the 2014 Autumn Statement, stating that legislation would be included in the Finance Bill 2016. For background to this measure, see Tax legislation tracker: property, energy and environment: PAIFs seeding SDLT relief.

This measure will not be included in the first (pre-general election) Finance Bill of 2015. Depending on the outcome of the general election on 7 May, it will be included in a later Finance Bill.

(See HM Treasury: March Budget 2015, paragraph 2.184, Overview, paragraph 2.23 and HM Government: March Budget 2015: policy costings, page 38.)

The government will extend the period over which self-employed farmers and market gardeners can average their profits for income tax purposes to five years (from two years). For information on averaging profits, see Practice note, Income tax: general principles.

Later this year, the government will consult on the detailed design and implementation of the extension. The change will come into effect from 6 April 2016 and be included in a future (post-election) Finance Bill.

(See HM Treasury: March Budget 2015, paragraphs 1.118 and 2.68 and Overview, paragraph 2.13.)

For all property announcements, see Legal update, March 2015 Budget: key property announcements and for construction announcements, see Legal update, March 2015 Budget: key construction announcements.

With effect from 1 April 2015, the VAT registration threshold will be increased to £82,000 (from £81,000) and the deregistration threshold will be increased to £80,000 (from £79,000). These changes will be effected by secondary legislation.

For information on VAT generally, see Practice note, Value added tax.

(See HM Treasury: March Budget 2015, paragraph 2.154 and Overview, paragraph 1.24.)

Partially exempt businesses will no longer be able to take into account supplies made by foreign branches in determining how much VAT on overhead costs can be deducted under the partial exemption rules. This will mainly affect financial institutions such as banks and insurance companies. Exempt financial services provided to non-EU customers are treated as taxable for input tax deduction purposes and, therefore, attributable input tax may be deducted. Currently, under the partial exemption rules, supplies made by foreign branches are taken into account in determining how much VAT on UK overhead costs used to support foreign branch activities may be deducted.

Regulations 101, 102 and 103 of the VAT Regulations 1995 (SI 1995/2518) will be amended to exclude foreign branch supplies from the standard and special methods (and restrict the use based calculation for foreign/specified supplies to UK supplies). These changes will take effect from 1 August 2015. However, if 31 July 2015 falls within a VAT longer accounting period for a business, it will not take effect until the first day of the next longer period.

For more information on partial exemption, see Practice note, Value added tax: Partial exemption.

This measure will be effected by secondary legislation.

(See HM Treasury: March Budget 2015, paragraphs 1.249 and 2.153, TIIN, VAT: deductions relating to foreign branches, Overview, paragraph 1.25 and draft Value Added Tax (Amendment) (No.) Regulations 2015 and Explanatory Memorandum.)