2014 Autumn Statement: private client implications | Practical Law
On 3 December 2014 the Chancellor of the Exchequer, George Osborne, delivered his Autumn Statement. This update summarises the most important private client announcements. (Free access.)
On 3 December 2014 the Chancellor of the Exchequer, George Osborne, delivered his Autumn Statement. This update summarises the most important private client announcements. (Free access.)
On 3 December 2014 the Chancellor, George Osborne, delivered his Autumn Statement responding to economic forecasts published by the Office for Budget Responsibility.
A major surprise for private client practitioners is the announcement that the government will not introduce a settlement nil rate band, although it will introduce measures to prevent the use of multiple trusts to avoid inheritance tax (IHT). Another unexpected measure is the abolition of the slab system of stamp duty land tax (SDLT) for residential properties. There are further burdens for non-domiciled individuals and those with enveloped properties, in the form of increases in remittance basis charges and the annual tax on enveloped dwellings (ATED). On the plus side, there are some small additions to IHT exemptions, ISA allowances for surviving spouses and pensions flexibility.
Autumn statements may have replaced pre-budget reports in 2010, but this one still feels like a mini-budget.
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2014 Autumn Statement
On 3 December 2014 the Chancellor, George Osborne, delivered his Autumn Statement responding to economic forecasts published by the Office for Budget Responsibility.
A major surprise for private client practitioners is the announcement that the government will not introduce a settlement nil rate band, although it will introduce measures to prevent the use of multiple trusts to avoid inheritance tax (IHT) (see Trusts). Despite three consultations, two sets of detailed proposals and anti-forestalling provisions proposed to have effect from 7 June 2014, practitioners cannot advise clients what to expect in the Finance Bill 2015. It is unclear whether draft legislation for these measures will be ready to publish on 10 December 2014 with other Finance Bill clauses.
Another unexpected measure is the abolition of the slab system of stamp duty land tax (SDLT) for residential properties. The new model is similar to the one proposed for Scotland, which some have described as a mansion tax, but the Chancellor was keen to emphasise that SDLT is only charged once, at the point of sale. The Chancellor pulled this out of his hat at the end of his speech and it is the most obvious pre-election measure.
There are further burdens for non-domiciled individuals and those with enveloped properties, in the form of increases in remittance basis charges and the annual tax on enveloped dwellings (ATED). Anti-avoidance measures include further civil deterrents for offshore tax evasion, with extension of the offshore penalties regime to IHT. On the plus side, there are some small additions to IHT exemptions, ISA allowances for surviving spouses and pensions flexibility.
There is very little in the Chancellor's announcements that will excite most charity practitioners. Apart from offering VAT refunds to hospices, search and rescue and air ambulance charities, he re-confirmed or extended previously announced Gift Aid developments.
On the other hand, those involved in social investment will welcome measures to significantly increase the amounts individuals can invest in eligible social enterprises and obtain tax relief under the social investment tax relief (SITR) scheme, together with additional proposals to enlarge the scheme. The current limits are seen as a major barrier to take up of SITR. However, increasing the limits is subject to obtaining EU state aid approval.
Autumn statements may have replaced pre-budget reports in 2010, but this one still feels like a mini-budget.
Draft legislation for the Finance Bill 2015 is to be published on 10 December 2014. To follow progress of the Bill as a whole and specific measures of interest to private client practitioners, see Private client tax legislation tracker 2014-15.
For information about tax rates and limits of interest to private client practitioners, including information about future rates announced in the Autumn Statement and elsewhere, see Practice note, Tax data for individuals and trustees.
Lifetime planning
Income tax: personal allowance and higher rate threshold to increase from April 2015
The Chancellor announced that the personal allowance for those born after 5 April 1948 will increase to £10,600 and the higher rate threshold will increase to £42,385 for 2015-16.
Income tax: blind person's allowance, married couple's allowance and income limit
As announced in the 2011 Budget, the blind person's allowance, married couple's allowance and the income limit will be increased in line with the retail prices index in 2015-16.
Income tax: restrictions on miscellaneous loss relief
Two changes to the miscellaneous loss relief rules will be introduced in the Finance Bill 2015 to counter avoidance of income tax involving losses from miscellaneous transactions. (Miscellaneous loss relief arises on a transaction if, assuming a profit had been made, it would have been chargeable to income tax under any of the provisions listed in section 1016 of the Income Tax Act 2007 (section 1016). For background, see Practice note, Income tax: use of losses: Other revenue losses.)
The first change, which applies to miscellaneous income or miscellaneous losses arising on or after 3 December 2014, denies loss relief if the loss or the income arises "directly or indirectly in consequence of, or otherwise in connection with" relevant tax avoidance arrangements. Relevant tax avoidance arrangements are arrangements to which the taxpayer is a party and a main purpose of which is to reduce a tax liability.
The second change, which applies from 6 April 2015, restricts loss relief to income of the same type. Currently, miscellaneous losses can be set against any income type falling within section 1016. Thus losses from intellectual property rights can be set against interest income. From 6 April 2015, the loss can only be set against income of the same type and any unrelieved loss must be carried forward and set against income of the same type in the next tax year.
Income tax: disguised fee income of investment managers to be subject to income tax
The government announced that it will introduce legislation to ensure that guaranteed fee income of investment managers will be subject to income tax.
The draft legislation, which will be included in the Finance Bill 2015 and will be effective from 6 April 2015, is in response to arrangements entered into by private equity firms involving partnerships or other transparent vehicles to convert trading income into capital receipts. Amounts that are genuinely linked to the performance of the fund (such as, carried interest returns or returns on genuine investments made by the individual fund managers) will not be caught by the new rules.
Income tax: B share schemes: abolition of capital treatment
The government intends to abolish the option for shareholders receiving cash under a B share scheme to elect for capital treatment. Instead, where a shareholder is offered the choice of receiving capital or income, the amount received will be taxed in the same way as a dividend.
B share schemes involve the creation and issue of an additional class of shares, with cash being returned to shareholders through one of several methods, the option chosen depending on whether shareholders wish to receive income or capital, or a combination of both. For further detail on B share schemes, see Practice note, B share schemes.
The government will introduce legislation in the Finance Bill 2015 to remove this perceived "unfair tax advantage", with effect from 6 April 2015.
The government will consult on introducing a withholding regime for income tax applicable to all peer-to-peer (P2P) lending platforms from April 2017. The government proposes that P2P platforms will withhold income tax at the rate of 20% from taxable (in other words, non-ISA) P2P returns. This will help many individuals to resolve their tax liability outside the self-assessment regime. For more detail on UK interest withholding, see Practice note, Withholding tax.
The government will also introduce a new relief to allow individuals lending through P2P platforms to offset any losses from loans that go bad against other P2P interest received. It will be effective from April 2016 and, through self-assessment, will allow individuals to claim relief for losses incurred from April 2015.
ISAs: transfer to spouses on death and subscription limit
When an individual who has an individual savings account (ISA) dies, their spouse or civil partner will receive an additional ISA allowance equal to the value of the deceased's ISAs. ISA status ends on the account holder's death. It appears that this will still be the case in relation to the deceased's own ISAs, but that the surviving spouse or civil partner will be able to use the additional allowance in relation to their own ISAs, regardless of whether they have inherited the funds in the deceased's ISAs. This measure will apply in relation to deaths on or after 3 December 2014, but the surviving spouse or civil partner's allowance will only be increased from 6 April 2015.
On 6 April 2015, the ISA subscription limit will increase to £15,240 and the junior ISA limit to £4,080. The current limits are £15,000 and £4,000 respectively. These rises are in line with the consumer prices index (CPI), which is the default basis for indexation unless the government decides to override it.
SDLT: revised structure, rates and thresholds for residential property
The government has published draft legislation that jettisons the current so-called "slab" system, under which SDLT is levied at a single rate on the chargeable consideration for a transaction (old rules), and replaces it with a "progressive" system, under which SDLT is charged at several rates according to the portion of the total consideration falling within each of several bands (new rules). This is aimed at correcting market distortions for properties with a value close to the existing borders separating SDLT rate increments.
The new rules will apply only to residential property transactions with an effective date on or after 4 December 2014, subject to transitional arrangements (see below). Non-residential, mixed property and enveloped dwellings (as to which, see Practice note, SDLT: 15% rate on enveloping high-value residential property) are unaffected by these changes.
For example, under the old rules, the SDLT charge on a residential property bought for £450,000 would be £13,500 (the entire consideration would be taxed at 3%). Under the new rules, the SDLT charge would be £12,500 (the first £125,000 would be taxed at 0%, the next £125,000 at 2% and the final £200,000 at 5%).
The effective rate of tax for properties with a chargeable consideration of £937,500 or less will be lower, or the same as, the effective rate of tax under the old rules. However, there will be an increase in the effective rate for most higher value properties. For example, a residential property bought for £1.25 million under the old rules would attract SDLT of £62,500 (effective rate 5%). Under the new rules, the charge would be £68,750 (effective rate of 5.5%).
Under transitional rules, buyers may elect to pay SDLT under the old rules in either of the following cases:
The transaction is effected under a contract entered into before 4 December 2014 unless:
the contract (or assignment of rights under the contract) is varied on or after 4 December 2014;
the transaction is consequent on the exercise of an option (right of pre-emption or similar right) on or after 4 December 2014; or
there has been an assignment, sub-sale or other transaction relating to the whole or part of the subject matter of the contract resulting in another person having the right to call for a conveyance of the subject matter.
If a person has the right to choose to account for SDLT under the old or new rules, this is done simply by including the amount of SDLT in box 14 of the land transaction return (calculated according to which rules have been selected). Pending the development of HMRC's IT systems, a stand-alone online calculator is available (see HMRC: Stamp Duty Land Tax calculator).
The draft legislation, which will be introduced into Parliament in December 2014, will be contained in the Stamp Duty Land Tax Bill. The draft Bill contains consequential amendments to existing SDLT provisions, including the linked transactions rules and multiple dwellings relief. We will publish a separate update on these measures soon.
ATED: increase for residential properties worth more than £2 million
The government announced that the rates of annual tax on enveloped dwellings (ATED) (as to which, see Practice note, Annual tax on enveloped dwellings (ATED)) for residential properties worth more than £2 million will be increased by 50% above inflation and that the ATED filing obligations and information requirements will be simplified.
The new rates, that will be included in the Finance Bill 2015 and will apply for the chargeable period 1 April 2015 to 31 March 2016, are:
£23,350 for properties with a taxable value of over £2 million up to £5 million.
£54,450 for properties with a taxable value of over £5 million up to £10 million.
£109,050 for properties with a taxable value of over £10 million up to £20 million.
£218,200 for properties with a taxable value of over £20 million.
The announcement refers to properties owned through a company and does not mention properties owned by other non-natural persons. However, we do not expect that the draft legislation will amend the scope of the ATED charge.
CGT: entrepreneurs' relief extended to gains deferred into EIS or SITR
With effect from 3 December 2014, individuals and trustees who are eligible for entrepreneurs' relief will no longer have to forego this entitlement if they defer their gain into investments that qualify for Enterprise Investment Scheme (EIS) or Social Investment Tax Relief (SITR). Gains reinvested before this date suffer tax at the full capital gains tax rate (18% or 28%) when they come back into charge on disposal of the EIS or SITR investment. Gains deferred on or after 3 December 2014 will be eligible for entrepreneurs' relief when they come back into charge, reducing the tax rate to 10%.
This change, which restores the treatment of the deferred gain to the position that existed before 6 April 2008 under the taper relief regime, will be greatly welcomed as it removes a disincentive to invest in EIS and SITR.
CGT: no entrepreneurs' relief on goodwill transferred to related company
It was announced in the 2014 Autumn Statement that individuals, partners and trustees who transfer a business to a related close company will no longer be able to claim entrepreneurs' relief on the value of reputation and customer relationships (goodwill). This measure will apply to disposals of goodwill to related close companies on or after 3 December 2014.
The change has been introduced to stop the perceived abuse of entrepreneurs' relief on incorporation of a business, particularly where the previous owners of the business sell it to the company and leave the consideration outstanding as a credit to the director's loan account with the new company. By claiming entrepreneurs' relief, the seller could pay tax at the rate of 10% on the value of the goodwill and make future withdrawals from the loan account free of tax. The draft legislation, released alongside the Autumn Statement, inserts a new section 169LA in the Taxation of Chargeable Gains Act 1992 (TCGA 1992) denying entrepreneurs' relief on such a transfer. It includes provisions aimed at catching any avoidance arrangements put in place to circumvent the new exclusion.
The knock-on effect from this amendment will be that, for a business that is incorporated in exchange for shares, an election disapplying section 162 TCGA 1992 (incorporation relief) is unlikely to be beneficial. Therefore, if the business owners envisage a sale to a third party within 12 months of incorporation, they should consider their options very carefully. See Practice notes, Entrepreneurs' relief and Incorporating a partnership: tax issues.
The government is to provide an online calculator that will allow taxpayers to calculate their chargeable gains for capital gains tax (CGT) purposes. Taxpayers will also be given the opportunity to pay any CGT liability ahead of the self assessment due date. Although it is unclear why a taxpayer would choose to do this, the policy costing anticipates that a number of taxpayers will indeed take up this option. This facility will be available from October 2016.
There were no new major pensions-related announcements. The Chancellor confirmed that the pensions flexibility measures unveiled at the 2014 Budget for those with defined contribution pension savings would come into effect in April 2015. As has been widely predicted, changes to the treatment of death benefits announced in September 2014 will be extended to include joint life and guaranteed period annuities. These measures are being implemented in the Taxation of Pensions Bill 2014-15.
Alongside this change, the tax rules will be updated to allow a joint life annuity to be paid to any beneficiary of a deceased policyholder, rather than only to a dependant. This measure will be introduced in the Finance Bill 2015.
The government also announced that it had decided not to extend the availability of pensions tax relief to those above age 75.
Legislation will be introduced in the Finance Bill 2015 to prevent companies that benefit "substantially" from subsidies for the generation of renewable energy from qualifying for relief under the venture capital schemes (as to which, see Practice notes, Venture Capital Trusts, Enterprise Investment Scheme and Seed Enterprise Investment Scheme). The legislation will take effect from 6 April 2015. This follows Finance Act 2014 legislation that excludes companies from the venture capital schemes if they benefit from Department of Energy and Climate Change renewable obligations certificates or renewable heat incentive subsidies. It was also confirmed that, in the future, qualifying organisations undertaking community energy generation, will be eligible for relief under the social investment tax relief scheme. At that point, such organisations will cease to be eligible for relief under the venture capital schemes.
The government also announced that a new online process for the venture capital schemes will be available in 2016.
Close company loans to participators rules to remain unchanged
Following a review of the tax charge imposed by section 455 of the Corporation Tax Act 2010 on loans from close companies to individuals, trusts and partnerships that are participators, the government has decided to make no changes to its structure or operation.
The government initially consulted on reforms to the close company loans tax regime on 9 July 2013 but watered down its original proposals in a consultation response published on 10 December 2013. The proposals for minor change that remained involved excluding commercial transactions where no avoidance motive exists, imposing a higher tax rate for loans made to additional rate taxpayers and the introduction of a non-statutory form clarifying the information required for a repayment of tax paid under the regime.
The prevailing view amongst practitioners has always been that, as close company loans are rarely used to avoid tax, the regime should either remain as it is or be completely abolished. Therefore, this announcement does not come as a surprise.
IHT: exemption for emergency service personnel and humanitarian aid workers
The existing inheritance tax (IHT) exemption for members of the armed forces who die or whose death is caused or hastened by injury while on active service will be extended to emergency service personnel and humanitarian aid workers responding to emergencies. The extension will have effect for deaths on or after 19 March 2014.
The government consulted on extending the existing IHT exemption to emergency service personnel during the summer of 2014. The Chancellor's announcement confirms the proposal and extends it to humanitarian aid workers.
The existing inheritance tax (IHT) exemption for medals and other decorations for valour or gallantry will be extended to all medals and decorations awarded to the armed services or emergency service personnel, and awards made by the Crown for achievements and service in public life. The measure will have effect from 3 December 2014.
The government has dropped plans to introduce a single settlement nil rate band to be shared between all trusts set up by a settlor in lifetime or on death. The government included the original proposal in its plans to change the inheritance tax rules for relevant property trusts in a consultation published on 6 June 2014. It will still introduce measures to prevent the use of multiple trusts to avoid inheritance tax and to simplify the inheritance tax rules for relevant property trusts in Finance Bill 2015.
The settlement nil rate band proposal was heavily criticised as an overly complex, and unfairly retrospective solution to inheritance tax avoidance. However, it is something of a surprise that it has been shelved. Professional bodies have pointed out that widening the related settlements rules in section 62 of the Inheritance Tax Act 1984 would deter taxpayers from using multiple trusts. This may be the form that the new measure takes.
The annual charge paid by some non-UK domiciled but UK resident individuals who use the remittance basis of taxation is to 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 £60,0000. 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.
The government will also consult on making an election to use the remittance basis apply for a minimum of three years, so as to prevent taxpayers from arranging their affairs so as to only pay the charge occasionally. Eligible taxpayers can currently make an election for a specific tax year. If introduced, this measure would also make it more difficult for taxpayers to assess whether it would be beneficial to claim the remittance basis for any given period.
The tone of both the announcement in the Autumn Statement and the earlier consultation document suggests that the government is in favour of applying the restriction. However it has been recognised that a change would not be straightforward for employers or individuals and that further consideration is required.
The Chancellor confirmed that the offshore penalties regime will be extended to include inheritance tax, and to apply to domestic offences where the proceeds of the offence are kept offshore. The government will also update its territory classification system to reflect the adoption of the new global standard for the automatic exchange of tax information. These measures will take effect from April 2016. Additionally, the government intends to introduce a new aggravated penalty of up to 50% of the unpaid tax for moving funds hidden offshore, to take effect from Royal Assent to the Finance Bill 2015. The government's original proposal to introduce a new criminal offence of failing to declare taxable offshore income and gains appears to have been dropped. HMRC will also review its existing framework for offering information on offshore tax evaders, particularly those who remain outside international efforts to achieve tax transparency.
Social investment tax relief (SITR) has been in place since 6 April 2014, to encourage direct investment by individuals in social enterprises.
To ensure that the SITR scheme falls within the European Commission's de minimis threshold for state aid, the maximum amount that an investor can currently invest in an eligible social enterprise is EUR 344,827 (about £275,000) in any three year period. This limit is considered to be too low to have a transformative effect on the social investment market. So, in the summer, HM Treasury consulted on its proposals to enlarge the scheme (see Legal update, Consultation on enlarging social investment tax relief scheme).
The government has announced that it will:
Seek EU approval to:
increase the annual limit on the amount that can be invested in an individual organisation for SITR to £5 million, subject to an overall total increased to £15 million per organisation; and
These changes will come into effect on or after 6 April 2015, subject to state aid clearance.
Allow gains that are eligible for Entrepreneurs’ Relief (ER) and deferred into investment under the SITR scheme to benefit from ER when the gain is realised, so as to encourage successful entrepreneurs to invest in these companies.
From the date that the SITR scheme is expanded, allow all community energy generation undertaken by a qualifying social enterprise to be eligible (presumably, as a qualifying trade) for SITR (it will then cease to be eligible for tax relief under EIS, the Seed Enterprise Investment Scheme (SEIS) and the Venture Capital Trust (VCT)).
Make special purpose vehicles for subcontracted and spot-purchase social impact bonds eligible for SITR through secondary legislation in autumn 2015.
Charity donor benefits and Gift Aid on membership and entrance fees
The government will continue the charity donor benefits review it launched at Budget 2014 and extend it to consider the rules for claiming Gift Aid on membership and entrance fees (see 2014 Budget: key private client tax announcements: Charity donor benefits). It will also work with the charity sector to update and clarify its guidance. It will provide a progress update in the 2015 Budget.
The government has confirmed, as announced in the 2014 Budget, that legislation will be introduced in the Finance Bill 2015 to establish a framework to allow non-charity intermediaries (such as text donation operators or websites) to take a greater role in operating Gift Aid (see 2014 Budget: key private client tax announcements: Gift Aid on digital giving). The aim is to make it easier to claim Gift Aid on digital giving.
VAT refunds for hospices, search and rescue and air ambulance charities
A measure will be introduced in the Finance Bill 2015 to enable UK search and rescue charities and air ambulance charities to be eligible for refunds on VAT incurred on the purchase of goods and services used for their non-business activities. The measure will be effective from 1 April 2015.
The government has also announced that it will refund the VAT that hospice charities incur. However, no details have been published as to how and when this will be effective.
These new VAT refunds will bring the affected organisations in line with rebates received by emergency services and NHS bodies. The announcement will be welcomed in the sector as it was widely felt that the VAT charges on these types of charity were unfair, creating a considerable financial burden and diverting much-needed funds away from patient care at a time of increased demand.
Further support for military charities from LIBOR fines
The government has committed to use a further £50 million from fines imposed on banks for attempting to manipulate the London Interbank Offered Rate (LIBOR) over the next 6 years to support military charities and other causes.
GAAR. HMRC is to consult in early 2015 on whether and, if so, how to introduce GAAR-related penalties. Currently, there are no GAAR specific penalties if the GAAR applies and counteraction adjustments are required to be made (although penalties for errors and late payment under the existing penalty regimes may apply). For further discussion about the GAAR, see Practice note, General anti-abuse rule (GAAR).
Publishing DOTAS scheme details and naming scheme promoters. The government will empower HMRC to publish information about scheme promoters and schemes that are notified under DOTAS. Legislation to implement this measure is expected in the Finance Bill 2015.
Strengthening the DOTAS regime. Following a consultation in the summer (see Legal update, Consultation on strengthening DOTAS rules) it is confirmed that legislation will be introduced in the Finance Bill 2015 to strengthen the current regime. This will include introducing new, and widening existing, hallmarks and removing the grandfathering provisions, which have allowed promoters to argue that new arrangements that rely on existing arrangements as building blocks, need not be disclosed. Further, penalties for failing to disclose are to be increased and the information disclosure requirements amended. The legislation will take effect from Royal Assent to the Finance Bill 2015. For the current DOTAS regime, see Practice note, Disclosure of tax avoidance schemes under DOTAS: direct tax.
DOTAS taskforce. A new taskforce will be created to ensure the effective policing of the DOTAS regime.
Serial avoiders. HMRC is to consult in early 2015 on introducing further deterrents (penalties, reporting obligations and "naming and shaming") on repeat users of known avoidance schemes.
The government has confirmed that the direct recovery of debts (DRD) legislation to be introduced in a Finance Bill in 2015 will include a number of safeguards to protect against errors and to improve independent oversight. For the background to DRD and details of the proposed safeguards, see Legal update, Direct recovery of tax debts: government increases safeguards.
The government also confirmed that Scotland, where HMRC already has powers similar to DRD, will be excluded from the measures.
Closure of one or more aspects of tax enquiry to be allowed
The government has announced that it will consult on a new power to enable HMRC to close one or more aspects of a tax enquiry while leaving other aspects open.
Paragraph 32 of Schedule 18 to the Finance Act 1998 requires HMRC to issue a closure notice at the conclusion of a tax enquiry setting out the details of the outcome. While a closure notice does not need to identify and include a view on all the technical arguments of an enquiry, it currently concludes all aspects of the enquiry. The proposed introduction of the new power should be welcomed to facilitate the speedier resolution of enquiries.
OTS recommendations on competitiveness of UK tax system
The government has adopted the vast majority of the recommendations made by the Office of Tax Simplification (OTS) to improve the competitiveness of the UK's tax system. The report, which was commissioned in the 2013 Autumn Statement and published on 9 October 2014, made 50 "key" and a number of "other" recommendations over a wide range of taxes (see Legal update, OTS final report on competitiveness of UK tax administration).
According to the Autumn Statement, the government has adopted 51 out of 58 of the OTS's recommendations and has already started work on a number of them. No details of which recommendations have been adopted have been announced, but further details will no doubt be published in due course.
The government will work with the private sector to introduce a single, co-ordinated approach to debt collection, using a variety of debt collection services. Although HMRC already employs private sector debt collection services, going forwards, it will do so using a single "debt market integrator".
Cross-party agreement on Welsh devolution will be reached by 1 March 2015.
The Devolution Cabinet Committee is to consider decentralisation proposals for England, as well as the so-called "West Lothian question" (whether MPs in Scotland, Wales and Northern Ireland should be entitled to vote on purely English matters).
Legislation to devolve corporation tax rate-setting powers to Northern Ireland will be introduced in the current parliamentary session provided the Northern Ireland Executive satisfies the government that it is able to manage the financial implications. This will depend on the outcome of current cross-party talks aimed at agreeing the Executive's 2015-16 budget and future finances, among other things.
Scotland's block grant adjustment to reflect devolution of SDLT and landfill tax in 2015 has been delayed so that the changes to SDLT announced in the Autumn Statement can themselves be reflected in the adjustment.