UK Act of Parliament 2025 United Kingdom

Finance Act 2025

At a glance

Enforced by

HMRC

What's here

7 compliance obligations, 4 practical guides across 2 topics · 1 journey

Penalty landscape

1 of 7 obligations carry up to 2 years imprisonment. 6 have no criminal penalty — flagged in the list below.

Who this Act binds

Business-side actors with duties under this Act, ranked by how often they appear.

  • Any Person 4
  • Trader 1

Plus 2 non-business duties on Crown ministers, regulators, local authorities or tribunals — shown collapsed under each section below.

Step-by-step journeys using this legislation

Walkthroughs that take you from a real business situation to compliance.

Relevant guidance

Practical guides for businesses affected by this Act, ordered by how closely they engage with it.

Mentioned in related content

1 guides

Other Acts binding the same actors

For each actor bound by this Act, the other UK Acts that bind them most often. Useful for understanding the full compliance landscape facing each role.

Any Person also bound by 2338 other Acts (top 5 shown)
Traders also bound by 826 other Acts (top 5 shown)

What this Act requires

Sections that create concrete duties on businesses or carry penalties. Procedural and definitional sections are folded into the “Browse other sections” expander at the bottom of each group. Click any section title to read the source text on legislation.gov.uk.

Part 1 — Income tax, capital gains tax and corporate taxes

Browse 35 other sections in this Part — procedural / definitional / commencement

Part 3 — Other taxes

Browse 29 other sections in this Part — procedural / definitional / commencement

Part 4 — Miscellaneous and final

s.083

Duty on vaping products

Other duties (1) — Crown / regulator
  • HMRC may prepare for a new vaping products duty Statutory regulator
s.084

Carbon border adjustment mechanism

Other duties (1) — Crown / regulator
  • HMRC may prepare for a new Carbon Border Adjustment Mechanism (CBAM) tax Statutory regulator
Browse 6 other sections in this Part — procedural / definitional / commencement

Schedules

Browse 340 other Schedules — structural / supplementary
s.sch001

Amendments of TCGA 1992

s.sch001

In section 6 of F(No.2)A 2024, omit—

s.sch001

In section 1I (income taxed at higher rates or gains...

s.sch001

In section 222A (determination of main residence: non-resident CGT disposals),...

s.sch001

In section 223 (amount of relief), in subsection (7)(b), for...

s.sch001

Omit Schedule 1B (residential property gains).

s.sch001

(1) Schedule 4AA (re-basing for non-residents in respect of UK...

s.sch001

Amendments of other Acts

s.sch001

In Schedule 1 to FA 2019, omit paragraph 15.

s.sch001

(1) Schedule 2 to that Act (returns and payments on...

s.sch002

Introductory

s.sch002

Introductory

s.sch002

Assets transferred on or after 6 April 2025 under unconditional contract made before 30 October 2024

s.sch002

Assets transferred on or after 6 April 2025 under unconditional contract made on or after 30 October 2024 but before 6 April 2025

s.sch002

Assets transferred on or after 6 April 2026 under unconditional contract made in tax year 2025-26

s.sch002

Paragraphs 11 to 13: supplementary provision

s.sch002

Business asset disposal relief: reorganisations of share capital before 30 October 2024

s.sch002

Business asset disposal relief: reorganisations of share capital on or after 30 October 2024 but before 6 April 2026

s.sch002

Business asset disposal relief: exchanges of securities etc before 30 October 2024

s.sch002

Business asset disposal relief: exchanges of securities etc on or after 30 October 2024 but before 6 April 2026

s.sch002

Investors’ relief: reorganisations of share capital before 30 October 2024

s.sch002

Allocation of amounts to times before or after 30 October 2024

s.sch002

Investors’ relief: reorganisations of share capital on or after 30 October 2024 but before 6 April 2026

s.sch002

Interpretation

s.sch002

Foreign chargeable gains under section 809J of ITA 2007 (section...

s.sch002

Chargeable gains treated as accruing to a settlor under section...

s.sch002

(1) This paragraph makes provision in relation to—

s.sch002

Introductory

s.sch002

Assets transferred under unconditional contract made before 30 October 2024

s.sch002

Investors’ relief: reorganisations of share capital before 30 October 2024

s.sch002

Interpretation

s.sch003

Payments into decommissioning fund treated as general decommissioning expenditure

s.sch003

Meaning of “relevant transferred plant or machinery”

s.sch003

Application of

s.sch003

Prevention of subsequent allowance where expenditure paid out of qualifying payment

s.sch003

Application of the Energy (Oil and Gas) Profits Levy Act 2022

s.sch003

Commencement

s.sch004

F(No.2)A 2023 is amended in accordance with—

s.sch004

Commencement

s.sch004

Permanent establishments as excluded entities

s.sch004

Use of substituted values

s.sch004

Flow-through entities

s.sch004

In section 169 (certain non tax resident entities to be...

s.sch004

In section 170 (adjustments for ultimate parent that is a...

s.sch004

(1) Section 178 (reallocation of tax expense) is amended as...

s.sch004

In section 240 (location of flow-through entities and permanent establishments),...

s.sch004

Tax equity partnerships

s.sch004

In sections 175 and 176, in the headings, for “covered...

s.sch004

Multinational top-up tax to include undertaxed profits rule

s.sch004

(1) Section 176D (tax credits etc allocated under tax equity...

s.sch004

(1) Section 176E (flow-through tax benefits: proportional amortisation method) is...

s.sch004

(1) Section 176F (flow-through tax benefits: subtraction method) is amended...

s.sch004

After section 176F insert— Clawback of earlier qualifying flow-through tax...

s.sch004

In Schedule 15 (elections), in paragraph 2(1) (annual elections), omit...

s.sch004

Blended CFC regimes

s.sch004

No allocation of deferred tax assets and liabilities under blended CFC regimes

s.sch004

Cross-border allocation of current tax under cross-crediting regimes

s.sch004

Cross-border allocation of deferred tax

s.sch004

Extension of qualifying foreign tax credits

s.sch004

Expansion of chargeable persons

s.sch004

Deferred tax recapture

s.sch004

Existing deferred tax assets and liabilities arising under blended CFC regimes

s.sch004

Substance based income exclusion: permanent establishments and flow-through entities

s.sch004

For section 198 (eligible payroll costs and eligible tangible asset...

s.sch004

In section 196 (eligible payroll costs), after subsection (6) insert—...

s.sch004

In section 197 (eligible tangible asset amount), after subsection (9)...

s.sch004

Eligible payroll costs

s.sch004

Additional top-up amounts

s.sch004

(1) Section 206 (additional top-up amounts where recalculations required) is...

s.sch004

Joint ventures

s.sch004

Charge to multinational top-up tax to include UTPR

s.sch004

(1) Section 227 (application of Part to joint venture groups)...

s.sch004

(1) Section 266 (qualifying entities) is amended as follows.

s.sch004

Domestic top-up tax

s.sch004

(1) Section 272 (determining top-up amounts of entity that is...

s.sch004

Domestic top-up tax: excluded entities

s.sch004

De minimis rule

s.sch004

Transitional safe harbour

s.sch004

Transitional safe harbour: arbitrage arrangements

s.sch004

Substance based income exclusion: removal of provision for election

s.sch004

Inclusion ratio

s.sch004

New chapter to deal with UTPR

s.sch004

(1) Section 223 (adjustments) is amended as follows.

s.sch004

Specification of territories and taxes

s.sch004

Filing etc not required before 30 June 2026

s.sch004

Minor amendments

s.sch004

In section 148A (transferable tax credits), in subsection (5)(a)—

s.sch004

In section 170 (adjustments for ultimate parent that is a...

s.sch004

In section 171 (ultimate parent subject to qualifying dividend regime)—...

s.sch004

In section 176B (value of non-marketable transferable tax credits: originator),...

s.sch004

In section 176C (value of non-marketable transferable tax credits: purchaser)—...

s.sch004

In section 176D (tax credits etc allocated under tax equity...

s.sch004

Transition into regime

s.sch004

In section 211 (transfer of assets or liabilities to a...

s.sch004

In section 212 (meaning of “qualifying reorganisation”), in subsection (4),...

s.sch004

In section 215 (undistributed income amount), in subsection (2)(c) omit...

s.sch004

In section 216 (election where assets and liabilities adjusted to...

s.sch004

In section 217 (post filing adjustments of covered taxes), after...

s.sch004

In section 217(8), for paragraph (a) substitute—

s.sch004

In section 220 (top-up amount of investment entity)—

s.sch004

In section 222 (investment entity effective tax rate), in Step...

s.sch004

In section 242 (ownership interests and controlling interests), in subsection...

s.sch004

In section 255 (Pillar Two rules), in subsection (6), for...

s.sch004

Consequential amendments: IIR and qualifying undertaxed profits tax

s.sch004

In Schedule 14 (administration of multinational top-up tax)—

s.sch004

In Schedule 16A (multinational top-up tax: safe harbours), in paragraph...

s.sch004

Commencement

s.sch004

Other consequential amendments etc

s.sch004

(1) In Schedule 17 (index of defined expressions), in the...

s.sch005

FA 2004

s.sch005

TCGA 1992

s.sch005

Consequential repeals of amending provisions

s.sch005

Commencement:

s.sch005

Commencement: Part 4

s.sch005

Anti-forestalling: disposals under unconditional contracts

s.sch005

Corporation tax: accounting periods straddling 1 April 2025

s.sch005

Carry-forward of losses: income tax

s.sch005

Carry-forward of losses: corporation tax

s.sch005

Plant and machinery allowances

s.sch005

Business asset disposal relief: disposals relating to pre-commencement businesses

s.sch005

ITTOIA 2005

s.sch005

Post-commencement disposals by companies with substantial shareholding

s.sch005

ITA 2007

s.sch005

Consequential repeals of amending provisions

s.sch005

CTA 2009

s.sch005

CTA 2010

s.sch005

Consequential repeals of amending provisions

s.sch005

CAA 2001

s.sch005

Consequential repeals of amending provisions

s.sch006

Introduction

s.sch006

Requirement for trustees of employee-ownership trusts to be UK resident

s.sch006

Trustee independence

s.sch006

Temporary breach of trustee independence requirement or residence requirement arising from death of trustee

s.sch006

Consideration requirement

s.sch006

Extended period for disqualifying events

s.sch006

Additional information to be provided in claims

s.sch006

Participation requirement not infringed by exclusion of directors

s.sch006

Relief for distributions to trustees of employee-ownership trusts

s.sch007

Income tax

s.sch007

Corporation tax

s.sch007

Capital gains tax

s.sch007

Application

s.sch008

(1) ITEPA 2003 is amended as follows.

s.sch008

(1) ITA 2007 is amended as follows.

s.sch008

In Part 8 of Schedule 3 to the Social Security...

s.sch008

After section 690C of ITEPA 2003 (employees who were internationally...

s.sch008

Individuals no longer meeting section 26A requirement not qualifying new residents

s.sch008

Certain individuals meeting section 26A requirement treated as qualifying new residents

s.sch008

Limit on relief not to apply to certain foreign employment relief claims

s.sch008

Definitions

s.sch009

No remittance basis for tax years after 2024-25

s.sch009

In section 62 of TCGA 1992 (residence of personal representatives),...

s.sch009

Residence of trustees: domicile of settlor no longer relevant

s.sch009

(1) Section 69 of TCGA 1992 (trustees of settlements) is...

s.sch009

(1) In the Money Laundering, Terrorist Financing and Transfer of...

s.sch009

Application of Income Tax Acts in relation to deemed employment

s.sch009

Pension schemes

s.sch009

In section 7 of F(No.2)A 2005 (social security pension lump...

s.sch009

Domicile of overseas electors

s.sch009

In ITA 2007 omit section 835B (domicile for income tax...

s.sch009

Situs of debt

s.sch009

Amendments of TCGA 1992 connected with end of remittance basis

s.sch009

Trust reporting requirements

s.sch009

Trusts with vulnerable beneficiary

s.sch009

Disposals of deeply discounted securities

s.sch009

The accrued income scheme

s.sch009

FOTRA securities

s.sch009

Reliefs in respect of income from investments etc. of certain pension schemes

s.sch009

Education funding

s.sch009

Making Tax Digital

s.sch009

Amendments of ITEPA 2003 connected with end of remittance basis

s.sch009

Amendment of ITTOIA 2005 connected with end of remittance basis

s.sch009

When amounts will be remitted

s.sch009

Relief for amounts remitted again on becoming UK resident

s.sch009

Removal of exemption for persons not domiciled in United Kingdom

s.sch009

Transferable tax allowance for married couples etc

s.sch009

Residence of personal representatives: domicile of deceased no longer relevant

s.sch010

Introduction and charge

s.sch010

Income tax exemptions and relief

s.sch010

Income tax exemptions: application of transfer of assets abroad rules in future years

s.sch010

Capital gains tax: main exemption

s.sch010

Capital gains tax: reliefs in respect of matched capital payments

s.sch010

Amounts derived from designated qualifying overseas capital

s.sch010

Effect of this Schedule on section 65(5) IHTA 1984 and section 260(2) of TCGA 1992

s.sch010

Temporary disapplication of nominated income ordering rules

s.sch010

Mixed funds: section 809Q of ITA 2007

s.sch010

Mixed funds: section 809R of ITA 2007

s.sch010

Mixed funds: TRF capital account

s.sch010

Temporary application of annualised basis to mixed funds containing TRF capital

s.sch010

Business investment relief

s.sch010

Qualifying overseas capital: main cases

s.sch010

No tax credits for pre 2016-17 dividends etc

s.sch010

Commencement

s.sch010

Capital payments made by settlement: section 87 and 89 TCGA 1992 cases

s.sch010

Capital payments made by settlement: offshore income gains cases

s.sch010

Capital payments made by settlement: Schedule 4C cases

s.sch010

Amounts of income treated as qualifying overseas capital

s.sch010

Deemed income under section 732 of ITA 2007 where pre-2025 gains available for matching

s.sch010

Designation of qualifying overseas capital

s.sch010

Payment of the TRF charge through the income tax system

s.sch011

Rebasing of assets for individuals who have been subject to the remittance basis

s.sch011

Assets becoming situated in the United Kingdom before 6 April 2025

s.sch011

Election for paragraph 1 not to apply

s.sch011

Rebasing under Schedule 8 to F(No.2)A 2017

s.sch012

Chapter 5 of Part 5 of ITTOIA 2005 (settlements: amounts...

s.sch012

In section 637 (qualifications to section 636), in subsections (5)...

s.sch012

For the italic heading before section 643A, substitute— Transitional provision...

s.sch012

Before section 643A insert— “Protected foreign-source income” and “transitional trust...

s.sch012

For section 643A substitute— Benefits paid out of protected foreign-source...

s.sch012

(1) Section 643B (meaning of “untaxed benefits total” in section...

s.sch012

For section 643C substitute— Meaning of “available protected income” in...

s.sch012

(1) Section 643E (reimbursement of tax paid by settlor) is...

s.sch012

After section 643E insert— Onward gifts from non-residents or qualifying...

s.sch012

(1) Section 643F (income attributed by section 643A to user...

s.sch012

(1) Section 643G (section 643F(4): benefits and income “relating” to...

s.sch012

In section 619 (charge to tax under Chapter 5), in...

s.sch012

In section 643H (meaning of close member of settlor’s family),...

s.sch012

Omit sections 643I to 643M (old onward gift provisions).

s.sch012

(1) Section 643N (person liable under section 643J or 643L...

s.sch012

(1) Section 645 (property or income originating from settlor) is...

s.sch012

(1) Section 646 (adjustments between settlor and trustees etc) is...

s.sch012

(1) Section 648 (income arising under a settlement) is amended...

s.sch012

Chapter 2 of Part 13 of ITA 2007 (transfer of...

s.sch012

In section 718 (meaning of “person abroad” etc)—

s.sch012

In section 720 (charge to tax on income treated as...

s.sch012

In section 721 (individuals with power to enjoy income as...

s.sch012

In section 622 (person liable), for “sections 643A and 643I...

s.sch012

Omit sections 721A and 721B (meaning of “protected foreign-source income”...

s.sch012

After section 725 insert— Recovery of tax paid as a...

s.sch012

(1) Section 726 (remittance basis etc) is amended as follows....

s.sch012

In section 727 (charge to tax on income treated as...

s.sch012

In section 728 (individuals receiving capital sums as a result...

s.sch012

Omit section 729A (meaning of “protected foreign-source income”).

s.sch012

Before section 730 insert— Recovery of tax paid as a...

s.sch012

(1) Section 730 (remittance basis etc) is amended as follows....

s.sch012

(1) Section 731 (charge to tax on income treated as...

s.sch012

(1) Section 732 (deemed income where benefit received) is amended...

s.sch012

In section 624 (income where settlor retains an interest), in...

s.sch012

(1) Section 733 (income charged under section 731) is amended...

s.sch012

Omit sections 733A to 733E and 734A (old provision about...

s.sch012

(1) Section 735 (remittance basis etc) is amended as follows....

s.sch012

(1) Section 735A (matching rules) is amended as follows.

s.sch012

After section 735A insert— Transitional provision about protected foreign-source income...

s.sch012

(1) Section 735B (settlor charge: remittance-basis users) is amended as...

s.sch012

(1) Section 735C (old onward gifts provisions: remittance-basis users) is...

s.sch012

In section 736 (exemptions: introduction)— (a) in subsection (1), for...

s.sch012

Omit section 742A (post-5 April 2012 transactions: exemption for genuine...

s.sch012

In section 747 (amounts corresponding to accrued income profits and...

s.sch012

Omit sections 628A to 628C (protected foreign-source income and transitional...

s.sch012

In section 751 (tribunal’s jurisdiction on appeals), omit paragraph (da)....

s.sch012

TCGA 1992 is amended in accordance with this Part of...

s.sch012

In section 1A (territorial scope), in subsection (2)(e), omit “87K,...

s.sch012

In section 1E (losses deductible only when within scope of...

s.sch012

In section 62 (death: general provisions), in subsection (2A), omit...

s.sch012

(1) Section 86 (attribution of gains to settlors with interest...

s.sch012

In section 86A (attribution of gains to settlor where temporarily...

s.sch012

In section 87 (non-UK resident settlements: attribution of gains to...

s.sch012

(1) Section 87B (section 87: remittance basis) is amended as...

s.sch012

In section 87D (sections 87 and 87A: capital payments to...

s.sch012

In section 629 (income paid to relevant children of settlor),...

s.sch012

(1) Section 87G (settlor liable if capital payment received by...

s.sch012

In section 87H (meaning of “close member of the settlor’s...

s.sch012

For sections 87I to 87M (old onward gifting provisions) substitute—...

s.sch012

In section 91 (increase in tax payable under section 87...

s.sch012

In section 97 (supplementary provisions)— (a) in subsection (1)(a)(ii), for...

s.sch012

In section 279A (deferred unascertainable consideration: election for treatment of...

s.sch012

In section 279C (effect of election under section 279A), in...

s.sch012

In Schedule 1 (UK resident individuals not domiciled in UK),...

s.sch012

(1) Schedule 4C (transfers of value: attribution of gains to...

s.sch012

(1) Schedule 5 (attribution of gains to settlors with interest...

s.sch012

Omit section 630A (exception to section 629 for protected foreign-source...

s.sch012

Commencement

s.sch012

Settlements: transitional protection where available protected income is increased by this Schedule

s.sch012

Onward gifts: settlements (income)

s.sch012

Onward gifts: transfer of assets abroad

s.sch012

Onward gifts: settlements (chargeable gains)

s.sch012

In section 635 (capital sums charge: amount of available income)—...

s.sch012

In section 636 (capital sums charge: calculation of undistributed income)—...

s.sch013

IHTA 1984

s.sch013

(1) Section 64 (charge at ten-year anniversary) is amended as...

s.sch013

(1) Section 65 (exit charges etc) is amended as follows....

s.sch013

(1) Section 74A (arrangements involving acquisition of interest in settled...

s.sch013

In section 75A, omit subsection (4).

s.sch013

In section 80 (initial interest of settlor or spouse), in...

s.sch013

In section 81 (property moving between settlements), in subsection (1)—...

s.sch013

For section 81B substitute— Excluded property: property to which section...

s.sch013

Omit sections 82 and 82A (excluded property: property to which...

s.sch013

In section 94 (close companies: charge on participators), in subsection...

s.sch013

In section 136 (transfers within three years before death: transactions...

s.sch013

In section 5 (meaning of estate), for subsection (1B) substitute—...

s.sch013

In section 155 (visiting forces etc), in subsections (2) and...

s.sch013

(1) Section 157 (non-residents’ bank accounts) is amended as follows....

s.sch013

In section 218 (non-resident trustees), in subsection (1)(a), for “domiciled...

s.sch013

Omit section 267 (persons treated as domiciled in United Kingdom)....

s.sch013

(1) Section 267ZA (election to be treated as domiciled in...

s.sch013

In section 267ZB (section 267ZA: further provision about election) (as...

s.sch013

Omit sections 267ZA and 267ZB (election to be treated as...

s.sch013

Before section 267A insert— Election to be treated as a...

s.sch013

(1) Section 272 (general interpretation) is amended as follows.

s.sch013

(1) Schedule A1 (non-excluded overseas property) is amended as follows....

s.sch013

In section 6 (excluded property), omit subsection (3).

s.sch013

In Schedule 4 (maintenance funds for historic buildings etc), in...

s.sch013

FA 1986

s.sch013

FA 2004

s.sch013

In paragraph 11 (exemptions from charge), in sub-paragraph (5), after...

s.sch013

In the italic heading before paragraph 12, for “resident or...

s.sch013

(1) Paragraph 12 is amended as follows.

s.sch013

Constitutional Reform and Governance Act 2010

s.sch013

Inheritance Tax (Delivery of Accounts) (Excepted Estates) Regulations 2004 (S.I. 2004/2543)

s.sch013

In regulation 2 (interpretation)— (a) the existing text becomes paragraph...

s.sch013

(1) Regulation 4 (excepted estates) is amended as follows.

s.sch013

In section 8D(9), omit the definitions of “tax year” and...

s.sch013

In regulation 5 (spouse, civil partner and charity transfers), in...

s.sch013

In regulation 5A (IHT threshold), in paragraph (4)(a), for “died...

s.sch013

In regulation 6 (production of information), in the heading, for...

s.sch013

(1) Regulation 6A (production of information) is amended as follows....

s.sch013

Inheritance Tax (Delivery of Accounts) (Excepted Settlements) Regulations 2008 (S.I. 2008/606)

s.sch013

Commencement

s.sch013

Certain pre-commencement emigrants treated as not being long-term UK residents

s.sch013

Property moving between settlements

s.sch013

Settlor’s death etc: application to bodies corporate

s.sch013

Deemed domicile rules still to apply in relation to times before commencement

s.sch013

In section 13A(3), omit the definition of “tax year”.

s.sch013

In section 18 (transfers between spouses or civil partners), in...

s.sch013

In section 28A, omit subsection (3).

s.sch013

(1) Section 53 (exceptions from charge under section 52) is...

s.sch013

(1) Section 54 (exceptions from charge on death) is amended...

Enforcement and responsible bodies

The regulators that administer or enforce this legislation.

HM Revenue & Customs

Tax collection, customs duties, national insurance, tax credits, and enforcement of the National Minimum Wage. Regulates all UK businesses for tax compliance …

Explore more

Browse legislation

Find other UK business legislation with related guidance.

Regulators

Learn more about the bodies that enforce this legislation.