James Murray MP: speeches

Speeches

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  The hon. Gentleman’s question goes slightly beyond the ambit of the tax measures we are discussing. As I understand, he is talking about the wider regulation and the approach to lettings in Scotland. To echo my response to the hon. Member for Gordon and Buchan, the measures really relate to the tax treatment of FHLs in comparison to standard property lettings, making them more equal. It does not make them entirely equal—VAT remains a point of difference—but it is about levelling the playing field between FHL landlords and the landlords of standard lettings in the tax system.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  I will briefly address clause 21 before explaining what the amendment seeks to achieve. The clause makes changes to simplify the process for operating pay-as-you-earn where an employee is eligible for overseas workday relief. It relates to some of the reforms we are making around non-UK domiciled individuals, which we will return to later in Committee, because those clauses are in a different part of the Bill. More broadly, the context of this measure is that the Government are removing the outdated concept of domicile status from the tax system, and replacing it with a new, internationally competitive, residence-based regime from 6 April 2025. Currently, where an employer makes an application to treat only a portion of the income that they pay to an employee as PAYE income, they are required to wait for HMRC to approve an application, which can result in delays. The changes made by clause 21 will mean that from 6 April 2025, an employer will be able to operate PAYE only on income relating to work done in the UK once they have received an acknowledgment from HMRC of their completed application, rather than having to wait for HMRC to approve it. That approach will simplify the operation of overseas workday relief for employers, while still allowing HMRC to direct employers to amend the proportion of income on which PAYE is operated, should it be necessary to do so. Amendments 15 to 19 are needed in order to ensure that the legislation regarding the correct operation of PAYE works as intended. The Government are committed to making the tax system fairer so that everyone who is a long-term resident in the UK pays their taxes here. The new regime ensures this, while also being more attractive than the current approach, as individuals will be able to bring income and gains into the UK without attracting an additional tax charge. That will encourage them to spend and invest those funds in the UK.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  I listened to the shadow Minister’s comments, and he must have a different definition of “overnight” from me. Legislating now for changes that will come in in 2028 does not feel like overnight. Some Budget changes come in on the day of the Budget—had he called one of those overnight, I might have had some sympathy with the description, but not for legislating now for changes that will come in in 2028, toward the end of this decade. Part of the point of legislating now for changes that will happen some years down the line is precisely to give that signal to consumers and manufacturers, to ensure that the consumers are aware of what is to happen and manufacturers know what is planned.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  Yes. In the context of this discussion on corporation tax, I will address the comments about other taxes. The shadow Minister again mentioned business rates and business rates relief, but he might want to recall the situation we inherited on business rates relief. This year it is operating at a 75% discount for retail, hospitality and leisure properties, up to a cap of £110,000, and it was due to expire entirely in April 2025. What we inherited was not just instability, but a cliff edge—it was going to go entirely in April this year. I notice that that part of the story is conveniently erased from the shadow Minister’s account of history. Business rates relief was going to expire entirely in April 2025, so we were keen to ensure that we continued it, while being mindful of the public finances. Our decision to continue it for a further year at 40% was the right thing to do while we ensure that we are ready from April 2026 to have permanently lower tax rates for retail, hospitality and leisure businesses with a rateable value of below £500,000. That is the stability that businesses so badly need. Frankly, the shadow Minister, who is talking about business rates in the context of corporation tax, overlooked that fact entirely. Under the previous Government, the reliefs were extended one year at a time, with the rates going up and down, which provided no stability for businesses trying to make investment decisions. From April 2026, with our permanently lower rates, we want to provide exactly that stability. To return to corporation tax, which is the subject of these two clauses, one of the conversations that I had many a time with businesses while in opposition was about their desire for certainty on corporation tax and the system of allowances. I recall challenging the shadow Minister, when he was a Treasury Minister himself, about the number of changes there had been to full expensing, the annual investment allowance and indeed to the super-deduction, which came and went entirely within one Parliament. That instability is what prompted our desire to provide stability for businesses, and publishing the corporation tax road map and these clauses begins to implement the commitments we made. Question put and agreed to. Clause 13 accordingly ordered to stand part of the Bill. Clause 14 ordered to stand part of the Bill. Clause 19 Pillar Two Question proposed, That the clause stand part of the Bill.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  Clause 13 sets the charge for corporation tax for the financial year beginning April 2026, setting the main rate at 25%; and clause 14 sets the small profit rate at 19% for the same period. As Members know, the charge for corporation tax must be set every year, so it is important to legislate on the rate for 2026 now to provide certainty to large and very large companies, which will pay tax in advance on the basis of their estimated tax liabilities. That is also why we have committed to cap corporation tax at 25% for the duration of the Parliament, as set out in the corporate tax road map published at the autumn Budget. The changes made by clause 13 will establish the right of the Government to charge corporation tax from April 2026. The clauses maintain the current rates of 25% and the small profits rate of 19%. Tax certainty is of great importance to businesses, and clauses 13 and 14 ensure that they continue to benefit from stable and predictable tax rules. I commend both clauses to the Committee.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  I thank the shadow Minister for his questions and his support for the clause. He mentioned a question that the ATT raised about the interaction between the extension of the 100% first-year allowance we are proposing, particularly for charge points, and the context of full expensing in the annual investment allowance. For businesses that are investing over the annual investment allowance limit, there may be circumstances where, if the first year allowance were not extended as it is by these clauses, some investment in EV charge point equipment would qualify for only a 50% first-year allowance rather than 100% full expensing. The Government want to support investment in EV charge point infrastructure by providing full relief for investment in equipment for EV charge points. That is why we have introduced this measure. The shadow Minister asked for a specific figure. I do not have that to hand, but I am happy to look into what information is available and get back to him. More broadly, the 100% first-year allowance was due to expire in April 2025. This conversation has echoes of an earlier discussion we had around retail, hospitality and leisure business rates relief, and reliefs or allowances that we inherited and which are due to expire in April 2025. We have decided to extend this, and the reason why is to help support businesses and individuals who are buying or making electric vehicles and associated infrastructure. We see this as one of a series of measures to support the EV transition. It has come up in relation to a number of clauses, so I think it is clear to the Committee that the Government are pursuing a range of different interventions and policies to carefully calibrate the right level of Government support.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  I was expecting a series of amendments from the Opposition; I was not expecting the shadow Minister to quote back at me an amendment I tabled several years ago. It is a new, although interesting, approach to opposition to rely on what I tabled in opposition and quote that back at me. I am sure it was an excellent amendment, although I cannot remember its exact detail. On the hon. Gentleman’s questions about corporation tax rates, I am sure he will remember from his time in the Treasury that it is standard practice to legislate the charge to corporation tax on an annual basis, even when the rates remain unchanged. That is a long-standing convention that applies to income tax as well. However, because we were so determined to give businesses stability and certainty, we published the corporate tax road map alongside the Budget. In that road map, we made clear our commitment to maintaining the main rate—or, indeed, to capping it—at 25% for the duration of the Parliament. The small profits rate and marginal relief will also be maintained at their current rates and thresholds. Full expensing and the annual investment allowance are also guaranteed for this Parliament. When it comes to corporation tax, full expensing and the annual investment allowance, the various Finance Bills in this Parliament will be quite a different experience compared with those in the previous Parliament.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  The clause and the schedule abolish the furnished holiday lettings tax regime from April 2025, removing the tax advantages that landlords who offer short-term holiday lets have over those who provide standard residential properties. Furnished holiday let owners benefit from a more generous tax regime than landlords of other property types, such as standard residential properties. The advantages of that tax regime include capital gains tax reliefs: FHLs can qualify for gains to be charged at 10%, unlike buy-to-let properties and second homes. FHLs also benefit from unrestricted income tax relief on their mortgage interest, rather than the 20% restriction on relief for standard lettings, and from capital allowance on furniture and furnishings. FHL profits are also counted as earned income for pension purposes. The previous Government announced at the spring Budget 2024 that they would abolish the FHL tax regime to level the playing field with landlords of standard residential properties. We are now legislating for that measure and abolishing the FHL tax regime from April 2025, which will raise around £190 million a year by 2029-30 and thereby support the vital public services we all rely on. The changes made by clause 25 and schedule 5 mean that FHL landlords will be treated the same as other residential landlords for the purposes of income tax, corporation tax and capital gains tax.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  Clause 22 introduces technical amendments to provide certainty that advance pricing agreements are available for all financing arrangements covered by the transfer pricing rules, in line with the existing HMRC guidance. The transfer pricing rules ensure that transactions between related parties, such as companies in the same multinational group, are priced as though they were between independent entities, in line with the arm’s length principle. This makes sure that each related party pays the appropriate amount of tax in the country in which it operates. That ensures a fair distribution of tax revenues across different jurisdictions and prevents companies from manipulating intra-group prices to shift profits to lower tax jurisdictions. The UK’s advance pricing agreement legislation provides for agreements to be entered into between HMRC and businesses in scope of the transfer pricing rules, which determine the transfer pricing method that businesses should use to determine the arm’s length price. An advance pricing agreement is not special treatment for that taxpayer; rather, it provides improved certainty to taxpayers in areas where the correct application of the transfer pricing rules may be in doubt. HMRC has recently become aware of a technical gap in the legislation that was contrary to its long-established statement of practice. The said statement of practice allows for an advance pricing agreement to be entered into where the parties are acting together in relation to financing arrangements. The changes made by this clause fix that gap and will ensure that HMRC can provide businesses with tax certainty in relation to the application of the transfer pricing legislation to all in-scope financing arrangements, in line with HMRC’s statement of practice. The intention of this clause is to fix a technical gap in existing legislation and to ensure that HMRC can provide certainty in line with its existing published guidance.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  Clauses 5 and 6 make changes to ensure long-term certainty on company car tax by setting the rates for 2028-29 and 2029-30. The increases in the appropriate percentages will help to ensure that the tax system contributes to supporting the sustainability of the public finances. The effect of the clauses is to gradually narrow the differential between zero emission and electric vehicles and their petrol and diesel counterparts, while ensuring that significant incentives to support the take-up of EVs remain in place. The provisions also increase rates for hybrid vehicles. Company car tax applies when a company car is made available to an employee or their family member for private use. Company car tax rates were confirmed by the previous Government up until 2027-28. In the 2024 autumn Budget, the Government set out the rates for 2028-29 and 2029-30, to provide certainty. The Government recognise that the company car tax regime continues to play an important role in the EV transition by supporting the take-up of EVs and their entry into the second-hand car market. Although it is important to maintain strong incentives to encourage the take-up of EVs, the Government need to balance that against the responsible management of the public finances by gradually withdrawing them over time, as EVs become more normalised. That is why we have committed to raising the company car tax rates—or appropriate percentages—for EVs, hybrids, and petrol and diesel vehicles in 2028-29 and 2029-30, gradually narrowing the differential between EVs and other vehicle types, and bringing the treatment of hybrids closer to that of petrol and diesel cars. The changes made by clauses 5 and 6 will set the company car tax appropriate percentages for the tax years 2028-29 and 2029-30. Appropriate percentages for EVs will rise by two percentage points per year, rising to 9% by 2029-30. Meanwhile, the appropriate percentages for cars with emissions of 51 grams of carbon dioxide per kilometre or over will rise by one percentage point per annum. By 2029-30, the appropriate percentages for petrol and diesel cars will rise to between 20% and 39%, depending on the car’s specific emissions. Together, the measures will gradually narrow the gap between EVs and their petrol and diesel counterparts, while maintaining a generous incentive for EVs. On the changes to the hybrid appropriate percentages, I draw the Committee’s attention to recent research from the European Commission that has shown that the real-world emissions of hybrid vehicles are in fact three and a half times higher than previously thought. Consequently, the Government have announced that they will align the treatment of hybrids more closely with that of petrol and diesel cars.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  I thank the shadow Minister for his support for the provisions before us and our general approach. First, it is the case that we are amending the Bill in Committee, but that is because, as his colleagues may remember from their time in government, these are complex rules and it is important that pillar two rules work as intended. This is a complex international agreement and it represents one of the most significant reforms of international taxation for a century. It is to a degree inevitable that revisions would be needed as countries and businesses introduce pillar two and set it in progress. It is complex, but we should not forget that pillar two applies only to large multinational businesses, and the reason it is being introduced is to stop those businesses shifting their profits to low-tax jurisdictions and not paying their fair share here in the UK. The rules need to respond to that, and we need to make sure that they work for all sectors and all types of businesses.

• 28 Jan 2025 · Finance Bill (First sitting) · Hansard source

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  The clause repeals the offshore receipts in respect of intangible property legislation, known as ORIP, which was aimed at disincentivising large multinational enterprises from holding intangible property in a low-tax jurisdiction if the intangible property was used to generate income in the UK. Such enterprises could thereby gain an unfair competitive advantage over those that held intangible property in the UK. The policy is no longer required, because pillar two—the global minimum tax—will more comprehensively discourage the multinational tax planning arrangements that ORIP sought to counter. As set out in the corporate tax road map, which we debated earlier, the Government are committed to simplification of the UK’s rules for taxing cross-border activities in the light of pillar two. Repeal will take place alongside the introduction of pillar two’s undertaxed profit rules in the UK from 31 December 2024, which we debated with clause 19. Clause 20 simply repeals chapter 2A of part 5 of the Income Tax (Trading and Other Income) Act 2005, and I commend it to the Committee.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  The OBR’s publication yesterday sets out the costings that were in the October Budget. There is no difference between the costings set out in October and what the OBR set out yesterday. It simply showed more of the background behind how they calculated those costings, for transparency and so that people are aware. Indeed, it says in the report that that is done in an effort to improve the public debate and ensure that people understand what is behind the data published at the time of the Budget. As I said to several Opposition Members, clearly this was one of many tough decisions that we took in the Budget to balance the public finances, but we also made sure that there is greater protection from inheritance tax under our proposed reform scheme than is available more widely.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  The way to calculate the impact of changes to inheritance tax policy is to look at the inheritance tax claims that have been made, and that is what we have used as the basis for our calculations. In fact, the OBR publication yesterday confirms that it used HMRC’s data on inheritance tax reliefs in the past and inheritance tax projected forward, and it is on the basis of that data that we designed our policy.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  My hon. Friend is absolutely right. The party opposite—in fact, the parties opposite—routinely support the Government’s spending and investment decisions but will not support any of the difficult decisions we have to take to fund them.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  The OBR document published yesterday refers to the level of uncertainty associated with this policy, which is exactly what was set out at the time of the Budget, and it is a typical way in which the OBR responds to new measures. What was published yesterday simply reiterates the OBR’s conclusions from the end of October.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  The comments in the OBR publication yesterday about older individuals reference a point that has been made since the Budget in debates in this place and elsewhere. We have pointed out that our reform of agricultural property relief and business property relief maintains generous exemptions from inheritance tax; £1 million is subject to relief, and there is the 50% relief beyond that, the existing nil-rate bands, and other exemptions in the system.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  There certainly is evidence that the current inheritance tax system has caused people to use these reliefs for tax planning and to avoid inheritance tax bills. My hon. Friend alludes to the broader question of the fairness and sustainability of this measure. As I mentioned earlier, 40% of agricultural property relief benefits the top 7% of estates, and 50% of business property relief benefits the top 4% of estates. The Leader of the Opposition has said that she thinks this is a good way to prioritise public money, but we think it is neither fair nor sustainable.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  Obviously, the Government put the highest priority on food security. That is why our policies set out to support it, and the farming sector more widely. The policy is one of many difficult decisions that we had to take in the Budget to balance the public finances, support public services and provide the economic stability we need for investment and growth.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  There still seems to be confusion among Opposition Members about what the OBR publication set out. It reiterates the costings that were published at the time of the Budget, on 30 October. It explains how those costings were arrived at, so that people can understand the calculations behind them, but the costings are the same as those published at the time of the Budget.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  I thank the hon. Gentleman for his question, but I think it was based primary on the OBR publication yesterday. I reiterate the point I have made several times now: that OBR publication reiterated the costings and figures set out at the Budget, it reiterated the level of uncertainty associated with the measure, as published at the Budget, it provides more detail behind that, but the conclusion is the same as it was on 30 October.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  We recognise that when the Conservative party was in government, it got it badly wrong. The country decided to change course, which is why they elected us into government to fix the public finances, put our public services back on their feet, boost investment and get the economy growing.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  The hon. Gentleman is a kindly man, too. I value the conversations that he and I have had outside the Chamber. People looking at this policy, and all our policies in the Budget, will recognise that we had to take difficult decisions, and will understand the context: our inheritance from the previous Government. We recognise the toughness of those decisions—they were not easy to make—but we prioritise balancing the public finances and economic stability, because that is how we get investment in growth, which our country so badly needs.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  I thank the hon. Gentleman for raising his constituent’s concern. I do not know the specifics of the case, but more broadly, investment decisions depend above all else on a stable economy and stable public finances. Without the hard work that we have done since taking office to fix the public finances and bring back economic stability, investment would be hampered, and our growth ambitions would not materialise in the way that we are determined to ensure happens.

• 23 Jan 2025 · Agricultural and Business Property Reliefs: OBR Costing · Hansard source

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  At the autumn Budget, we took difficult decisions on tax, welfare and spending that were necessary to restore economic stability, fix the public finances and support public services. We had to do that to address the mess we inherited from the previous Government, which the right hon. Member for Louth and Horncastle (Victoria Atkins) will remember well, having served in that ill-fated Government. We have taken these decisions in a way that makes the tax system fairer and more sustainable. The Government are better targeting agricultural property relief and business property relief to make them fairer. These reforms mean that despite the tough fiscal context, the Government are maintaining very significant levels of relief from inheritance tax beyond what is available to others. Under the current system, the benefit of the 100% relief on business and agricultural assets is heavily skewed towards the wealthiest estates. According to the latest data from His Majesty’s Revenue and Customs, 40% of agricultural property relief benefits the top 7% of estates making claims. That is just 117 estates claiming £219 million of relief. It is a similar picture for business property relief, with more than 50% of it being claimed by just 4% of estates making claims, which equates to 158 estates claiming £558 million in tax relief. Our reforms mean that individuals can access 100% relief for the first £1 million of combined business and agricultural assets, and 50% thereafter. Given the nil rate bands, this means that a couple can pass on up to £3 million between them to a direct descendant, inheritance tax free. Yesterday, the Office for Budget Responsibility published further details on the data sources and modelling used to estimate costings across a number of the tax measures announced at Budget, including the reforms to agricultural property relief and business property relief. The costing is the same as published at Budget, and the approach to modelling the costing is typical and in line with other tax policies. As the Government have set out, the reforms mean that almost three quarters of estates claiming APR in 2026-27, including those that also claim BPR, will not pay more inheritance tax. This is a fair approach that protects farms while also fixing the public services we all rely on.