Dan Tomlinson

I look forward to working with my hon. Friend, and other Members who are interested in this topic, to make sure that we move as quickly as we possibly can. Let me thank all Members for their contributions during this this debate. Question put and agreed to. New clause 5 accordingly read a Second time, and added to the Bill. New Clause 6 Offshore income gains: savings “(1) This section applies in relation to an offshore income gain arising to the trustees of a settlement in a case where Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to that gain for the tax year 2025-26 or any subsequent tax year because of the amendments made by section (Offshore income gains). (2) If the offshore income gain arose in a tax year before the tax year 2025-26 and, by reason of that offshore income gain or a part of it, an offshore income gain was treated as arising in a tax year before the tax year 2025-26 to an individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)— (a) Chapter 2 of Part 13 of ITA 2007 is to be treated as not applying in relation to the offshore income gain arising to the trustees or that part of that gain, and (b) references in section 734 of ITA 2007 to chargeable gains treated as accruing to an individual are to be treated as including the offshore income gain treated as arising to the individual. (3) An individual is not chargeable to income tax under Chapter 2 of Part 13 of ITA 2007 on income treated as arising to the individual under section 732 of ITA 2007 by reason of the offshore income gain to the extent that the income, without the amendments made by section (Offshore income gains)(1) and (2)(b)— (a) would have been treated as arising to that individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and (b) would have been non-chargeable income (see subsections (4), (5) and (6)). (4) The income would have been non-chargeable income if, without the amendments made by section (Offshore income gains)(1) and (2)(b)— (a) the income would have been treated as arising by reason of— (i) the matching of a capital payment received (or treated as received) by the individual before 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising before 6 April 2008, and (b) paragraph 100 of Schedule 7 to FA 2008 would have applied to the income. (5) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income— (a) which would have been treated as arising to the individual by reason of— (i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, and (b) to which paragraph 101 of Schedule 7 to FA 2008 would have applied, and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (9) to (18) of paragraph 126 of that Schedule as they would have been modified by sub-paragraph (3) of paragraph 101 of that Schedule. (6) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income— (a) which would have been treated as arising to the individual by reason of— (i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or (ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, (b) to which paragraph 102 of Schedule 7 to FA 2008 would have applied, and (c) to which paragraph 101 of that Schedule would not have applied, and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (4) to (7) of paragraph 127 of that Schedule as they would have been modified by sub-paragraph (4) of paragraph 102 of that Schedule. (7) Subsection (3) does not prevent Chapter 2 of Part 13 of ITA 2007 from having effect as though the income not chargeable to tax under that subsection had been charged to tax under section 731 of that Act. (8) Accordingly— (a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of that income will be deducted at Step 2 and at paragraph (a) of Step 5, and (b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of that income will be deducted at paragraph (b) of Step 5. (9) In section 733 of ITA 2007, after subsection (2D) insert— “(2E) See subsections (7) and (8) of section (Offshore income gains: savings) of FA 2026 (offshore income gains: savings relating to amendments made by section (Offshore income gains) of that Act) for special provision about income that is treated as arising under section 732 but that is not chargeable to income tax under subsection (3) of that section.” (10) This section— (a) is to be treated as having come into force on 6 April 2025; (b) has effect for the tax year 2025-26 and subsequent tax years.” —(Dan Tomlinson.) Brought up, read the First and Second time, and added to the Bill. New Clause 7 Pensions: abolition of the lifetime allowance charge “(1) Paragraph 134 of Schedule 9 to FA 2024 (power to make further provision in connection with the abolition of the lifetime allowance charge) is amended as follows. (2) In sub-paragraph (2)— (a) for paragraph (b) substitute— “(b) have effect for the tax years 2024-25 and 2025-26 (as well as subsequent tax years);”; (b) in paragraph (d), at the end insert“(including any provision that could be made under paragraph 133)”. (3) In sub-paragraph (3) omit “that increase any person’s liability to tax”. (4) In sub-paragraph (4), for “5 April” substitute “30 June”.” —(Dan Tomlinson.) Brought up, read the First and Second time, and added to the Bill. New Clause 11 Uprating of allowance amounts for agricultural property “The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”—(Charles Maynard.) Brought up, and read the First time. Question put, That the clause be read a Second time.