Finance (No. 2) Bill

Ashley Fox Excerpts

Wednesday 11th March 2026 Commons Chamber

[Dan Tomlinson]

I am glad to return to the Commons to debate the Finance Bill on Report. Although I am sure that it would have been of interest to Members on both sides of the House, I am also glad that we have not just had a set of two 45-minute debates on the Ways and Means motions. The opportunity was there, but I am glad that Members did not take it in full. We now have ample time for this important Report stage.

I thank Members on both sides of the House for their contributions in Committee. I thank in particular the shadow Exchequer Secretary to the Treasury, the hon. Member for North West Norfolk (James Wild), for his scrutiny and challenge, and for the invitation to his wonderful constituency, which I hope to take up one day. As yet, no other Opposition Front Bencher has offered me such an enticing prospect as a visit to their constituency, but I look forward to those invitations.

Before I turn to individual amendments, I wish to reflect briefly on the Budget that was delivered in November by my right hon. Friend the Chancellor of the Exchequer. That Budget took fair and necessary decisions to deliver on the Government’s promise of change, to support cuts in the cost of living, to enable NHS waiting lists to continue falling, and to ensure that our national debt fell as a share of GDP and that borrowing falls over the course of this Parliament. As the Chancellor said in this place yesterday and on Monday, Government borrowing—public sector net borrowing—has fallen from 5.2% to 4.3% of GDP, which is a fall of 1 percentage point. That is very significant and means that our borrowing is coming down, as part of our plan to bring stability back to the public finances.

[Sir Ashley Fox (Bridgwater) (Con)]

Does the Minister acknowledge that debt reduction is taking place only because the Government have increased taxes by £66 billion? That contrasts with the tax rise of £7 billion that the Labour party promised in its manifesto. Could he explain the huge discrepancy between that manifesto promise and what the Government are imposing on our constituents?

[Dan Tomlinson]

I ask the hon. Member to consider whether his party wishes to identify £66 billion of expenditure cuts or borrow £66 billion more. I do not think that either option is what the British public want; they want us to bring borrowing down and get public finances under control, after they were spun out of control by Liz Truss and the previous Government. The public understand the need for fair and responsible increases in taxation to ensure that we can invest in our public services and in the future of our country.

[Dan Tomlinson]

I strongly agree with my hon. Friend. I thank him for making his representations again and for his ability to mention Harlow in his interventions. It is a fantastic part of the country, not too far from my constituency in north London, and I know just how strongly he seeks to represent it and to make sure that the public services in his patch—the local hospitals and schools—get the investment they need. That is why he and I are able to proudly support this Government’s decisions to bring the public finances back into good order, as well as to invest in our public services and to get borrowing down.

Of course, though, since the Budget, and particularly in recent days, the world has changed. As the Chancellor set out last week in responding to the Office for Budget Responsibility’s spring forecast, it is more important than ever that the Government continue to deliver on our economic plan. The choices that we have made at previous Budgets will fix long-standing issues in the taxation system, restore economic and fiscal stability, and lay the economic foundations that we need for higher growth and higher living standards across our fantastic country.

The Bill legislates to deliver on those choices, all while sticking to our commitment not to raise the main rates of income tax, employee national insurance contributions or VAT. We are also providing stability for businesses by keeping to important commitments in our corporate tax road map to keep our corporation tax rate at 25%—the lowest in the G7—rather than having it chop and change up and down, like it did during previous Administrations.

I thank all those who have submitted written evidence throughout the Bill’s passage. Following concerns raised by professional bodies and concerns discussed in the Public Bill Committee, I would like to take this opportunity to reiterate my reassurances to the sector that measures that directly impact tax advisers are intended to create a fairer tax advice market. I have heard concerns that tax advisers might be penalised if they file a client’s tax return late when their client has not provided their approval for filing the return on time. I want to clarify that these powers are not designed to penalise responsible tax advisers who act in good faith, and in that specific scenario, a tax adviser would not be penalised under His Majesty’s Revenue and Customs’ stronger powers. The Government are committed to ensuring that the tax system works effectively for everyone, which is why we are introducing a number of amendments on Report to ensure that the tax system is working effectively and as intended.

I turn to the first group of Government amendments. New clause 5 removes specific provisions that could prevent offshore income gains from being designated under the temporary repatriation facility, or TRF, to ensure that they can be designated as intended. The amendments also simplify the existing treatment of offshore non-reporting funds held by offshore structures for all taxpayers. New clause 6 introduces transitional provisions for offshore income gains arising before 6 April 2025.

Following the abolition of the lifetime allowance, new clause 7, as we were just discussing, ensures that multiple different regimes do not apply, providing clarity for pension schemes and members. It ensures that any necessary regulations can have a retrospective effect back to 6 April 2024, clarifies the scope of the original power, extends the power by a further three months and ensures that regulations are subject to the affirmative parliamentary procedure.

The Government are making a number of minor and technical amendments to help provide greater clarity and address important points that have been raised by stakeholders, particularly during the passage of the Bill. These amendments simply put the original legislative intent beyond doubt.

Amendments 12 and 13 ensure that clause 23 will apply only to general earnings for the tax year 2026-27 and subsequent tax years that are paid on or after 6 April 2026. Amendment 14 tightens the existing provisions under clause 24 to ensure that those rules do not catch legitimate agency structures.

Amendments 48 and 51 remove legislation that is not necessary under clause 43 and ensure that the TRF legislation works as intended, so that beneficiaries from overseas trusts are able to make designations in connection with offshore income gains.

Amendments 49, 50 and 52 are consequential amendments to schedule 3 and clause 43. They remove references to omitted legislation and insert wording to clarify reference to the Taxation of Chargeable Gains Act 1992.

Amendment 53 to clause 49 makes clear that a person concluding contracts on behalf of a non-resident company must be present in the UK when concluding those contracts in order to create a permanent establishment in the UK.

Amendments 56 to 61 to schedule 11 concern the rules preventing fund managers from circumventing the revised carried interest tax regime. These amendments ensure that the provision operates as intended, where two connected persons work in the same business, with each connected person only taxed on their own carried interest.

[Sir Ashley Fox]

It sounds as if the Minister is adding many, many extra pages to our tax code. What provisions will he be bringing forward to shorten and simplify the tax code?

[Dan Tomlinson]

The hon. Gentleman raises an important point. We need to do all that we can to ensure that we are simplifying our tax code in order to make it easier for tax advisers, individuals and businesses. I have also asked that question, but I am reassured by my officials—I am sure that the hon. Member could consult Hansard too—that this is a typical number of amendments to be made to a Finance Bill. This is a long Finance Bill, but there are a whole range of important changes that the Government wish to introduce and to make progress on. I am sure Members from all parties have enjoyed poring over the changes to the tax legislation. I do take his point about simplification, though; it is something that I wish to focus on. If hon. Members have good ideas in that space, they would genuinely be welcome to write to me.

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[James Wild (North West Norfolk) (Con)]

We are grateful to the Minister for running through the plethora of Government amendments that are being added to this already stonkingly large Finance Bill. The sheer number of amendments is an admission that Ministers did not get this right the first time—or even the second time, in Committee, which we enjoyed.

Let me turn to amendments 1, 2 and 8 and 67 to 94, as well as new clause 10 in my name and the names of my hon. Friends. This Bill embodies Labour’s approach of ever-higher taxes, spending and borrowing, for which hard-working families and businesses are paying the price. The measures in the Budget and in this Bill add a further £26 billion-worth of tax rises, bringing the cumulative total from the Chancellor’s first two Budgets to £66 billion. As my hon. Friend the Member for Bridgwater (Sir Ashley Fox) pointed out, that did not feature anywhere in the Government’s manifesto. Those further tax rises are despite the Chancellor promising not to come back for more.

Debt interest is forecast to hit £140 billion by 2030. Unemployment is set to increase to 1.9 million, and youth unemployment has risen to 16.1%. Meanwhile, welfare spending is set to hit £406 billion, and living standards are expected to slow towards the end of this Parliament. Last week, the Office for Budget Responsibility downgraded its growth forecast once again and warned that the Chancellor’s plan, far from working, could “constrain economic activity”. Instead of backing the risk takers and the wealth creators, this Bill delivers slower growth, higher borrowing and higher taxes.

Let me turn to the freeze in income tax thresholds set out in clause 10. The Chancellor said at the Dispatch Box that there would be no extension of the freeze on income tax thresholds, because it would “hurt working people” and

“take more money out of their payslips.”—[Official Report, 30 October 2024; Vol. 755, c. 821.]

That promise has been broken by the measures in the Bill that do exactly the opposite, putting in place a £23 billion-a-year tax rise and bringing nearly 1 million more people into paying higher-rate tax.

It is not just working people who will pay the price. During this period, the state pension is forecast to be higher than the personal allowance. In the spring forecast, the OBR warned that an additional 1 million pensioners will find themselves liable for income tax by 2030-31 because of the Chancellor’s freeze. In anyone’s book, that is a retirement tax.

The Government have promised to protect people who rely solely on the state pension, but where is the detail? There is nothing in this legislation to do that. The public out there will rightly be sceptical, given that the Chancellor has already broken the promise not to freeze this threshold. Amendment 5 offers the House a very simple choice to stand by working people and pensioners and end the freeze.

Let me turn to the Government’s damaging family farm and family business tax. I know that Labour Members are going around their constituencies saying that they got a great win from the Chancellor just before Christmas, but let us be honest: that win was purely a fig leaf. The Government could have actually corrected their mistake, but the partial reversal that the Chancellor was forced into falls short of what is needed. The Country Land and Business Association has said that it only limits the damage—yet another broken promise from a Prime Minister who pledged not to impose an inheritance tax on farms. That measure epitomises Labour’s apparent hostility towards family farms, tenant farmers and our rural communities. I have spoken to farmers, as I am sure other hon. Members have, who are desperate about this situation. That is why we continue to strongly oppose the family farm and family business tax, and amendment 6 would scrap them.

Our further amendments seek to mitigate the worst effects of those taxes. Amendments 67 to 87 would remove the transition period for changes to the reliefs, and would delay implementation until after March 2027, lifting the unfair anti-forestalling rules that have tied the hands of farmers and business owners. The Chartered Institute of Taxation—which provided a lot of support in Committee and at earlier stages of the Bill, for which I am grateful—has warned that the measures particularly affect older farmers, robbing them of the ability to plan properly.

Amendment 88 would defer the deadline for inheritance tax instalments by a further 12 months. This reflects the conclusion of the House of Lords Economic Affairs Committee that the six-month deadline proposed for the first payment

“does not appear to be realistic”.

As we know, farming estates and family business are often asset-rich but cash-poor, which makes it difficult to raise the funds quickly. The National Farmers Union has warned that expecting probate to be granted within six months is

“completely unrealistic, especially given the complexity of valuing an agricultural business”.

Does the Minister recognise the strain that such unrealistic deadlines place on family farms and family businesses, and will he therefore accept our amendment and extend the payment deadline by 12 months? If he will not, will he explain to family farms and family businesses why not?

Amendments 89 to 94 would exclude from inheritance tax the value of any jointly held tenancy on the death of a joint tenant. This issue is causing concern across the sector, and has been raised by the Tenant Farmers Association and by my hon. Friend the Member for Keighley and Ilkley (Robbie Moore). Exempting genuine arm’s length tenancies between unconnected parties from inheritance tax is simply the fair thing to do. I would be grateful if the Minister could explain what engagement he has had with the Tenant Farmers Association on that point, what his response is, and how he intends to rectify this injustice. Of course, this is not just about farms; family businesses, which make up 90% of our firms and employ well over half the workforce, are firmly in the Chancellor’s crosshairs as well. These are firms that focus on the long term, yet according to Family Business UK, over half of affected businesses have already paused or cancelled investment as a result of the threatened tax.

It would be remiss of me to not mention that the Government’s claims do not seem to add up. Will this tax actually end up raising money? While the OBR forecasts a £500 million gain, analysis by the Confederation of British Industry suggests a net loss of nearly £2 billion, once the wider damage to the economy is considered. The family farm and family business tax does nothing to promote growth or fairness. It targets those who anchor our rural economy and communities—the family businesses committed to long-term growth. It is already having a chilling effect on investment, and now there is a prospect that companies that would otherwise thrive under family stewardship will break up. Again, I urge hon. Members to support amendment 6, which would remove this damaging measure from the Bill.

Savers and investors are not safe from the Chancellor, either. Amendments 1 to 4 deal with the introduction of increases in income tax on dividends, savings, and property income in the years ahead. Increases to the dividend tax will hit 4 million people by 2029-30, while the savings tax rate increase will hit a further 3.8 million individuals, and 2.4 million landlords will now face higher bills, making it less attractive to provide the rental properties that our constituents want. These measures are targeted at entrepreneurs, investors, pensioners and hard-working families. Rather than supporting growth, the Government seem determined to stifle it.

The Government are also scrapping the long-standing inheritance tax exemption for pensions. Some 10,500 estates will be targeted under this measure, costing savers £1.5 billion by 2029. We oppose this extension of inheritance tax, which seems predicated on the Government’s belief that people’s money belongs to the Government, rather than being their own. We should be rewarding saving and people who do the right thing, but extending inheritance tax in this way does exactly the opposite. As we discussed previously, there is also a concern about the burden being placed on personal representatives, and I have mentioned the unintended consequences for unmarried couples. In some cases, a surviving partner could lose up to 40% of a pension fund built up over a lifetime. Again, this is manifestly unfair, and amendment 7 would remove this damaging new tax from the Bill.

[Sir Ashley Fox]

Has my hon. Friend noticed a common thread through the Budget, which is that everyone who works hard, saves hard, invests and creates jobs is being penalised, and all that money is being used to benefit Benefits Street? It is no wonder that the growth rate is going down. [Interruption.]

[James Wild]

My hon. Friend is absolutely right, despite the chuntering that we hear from the Minister. The welfare bill is predicted to rise to £406 billion over the forecast period. The Chancellor keeps saying that she is fixing welfare. Where? What is she doing? She had to back away from very modest savings. We have identified £23 billion-worth of welfare savings, and the Minister could make those if he wished, but he does not, and that is why growth has once again been downgraded. The Chancellor boasts about beating the forecast last year. Well, the forecast at the beginning of the year was 2%, and the Government failed to get anywhere near 2%. They beat the downgraded forecast, so let us not hear any more about that. We want to hear what the Government will do to drive growth, and taxing the people generating it is precisely the wrong thing to do.

New clause 10 requires the Chancellor to review the UK carbon border adjustment mechanism. We debated CBAM extensively in Committee, and it is dealt with in a great swathe of the Bill—in the schedules—but there is plenty more to come. Given the complexity of the policy, many industries believe that the absence from the Bill of a formal oversight and review process is a serious mis-step that needs to be addressed.

There are many potential pitfalls in this new mechanism. First, the measure fails to consider several sectors that are at significant risk of carbon leakage, such as chemicals and refining. Secondly, the Government have decided to link the UK and EU emissions trading schemes. Following the announcement of that alignment, the price of carbon in the UK more than doubled, which cost our economy about £5 billion. We should be reducing the burden of carbon taxes on business, not increasing them. The EU has yet to publish its benchmark beyond 2030, which means that the UK would be signing up to a system that would effectively give Brussels a blank cheque. Moreover, CBAM does not address issues with carbon leakage in export markets. There are proposals to exempt our manufacturing exports from UK ETS costs and CBAM to make the industry more competitive, putting it on a level playing field internationally. Has the Minister considered maintaining long-term free allowances for products destined for the export markets? Given those complexities—I could go on about them more, but the Minister gets the gist—[Hon. Members: “More!”] It seems that other Members may want to come in on this issue.

I think that the Minister should recognise the value of regular reviews. I know he will say that the Government keep all taxes under review, but let us have an actual review that is published, so that we can see what is happening. I encourage Members to support new clause 10.

This is a Finance Bill full of tax increases that break trust with the British people. The Labour Government have introduced the family farm and business tax, frozen personal thresholds, hiked taxes on savers and investors, cut relief on employee ownership trusts, taxed inheritance pensions, taxed taxis—we discussed that in Committee—and increased gambling, alcohol and other duties and environmental levies. The list goes on and on. There is 534 pages-worth, which I could read out if there were any appetite for it. Our amendments and new clause would back the taxpayers, and the investors and businesses trying to drive growth in our economy, and I urge Members to support them.

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[Dan Tomlinson]

I thank all Members for their contributions at this stage of the Bill’s passage—we are almost there. I will take some time to respond directly to the amendments that have been discussed today.

I will first address amendments 1 to 4, 5 and 7, which were spoken to by the shadow Exchequer Secretary, the hon. Member for North West Norfolk (James Wild). Amendments 1 to 4 would remove the increase in dividend, savings and property income tax rates; amendment 5 would prevent income tax thresholds from staying at their current levels until 2030; and amendment 7 would remove reforms to the inheritance tax treatment of pensions. Based on costings that have been certified by the OBR, the direct impact of these amendments would cumulatively reduce forecast revenue raised in 2029-30—the year of relevance for our fiscal rules—by a whopping £12 billion. These amendments therefore pose a significant risk to the sustainability of our public finances and to our ability to fund the NHS and the public services that we all rely on. I therefore urge the House to reject them.

[Sir Ashley Fox]

Would the Minister concede that if that was offset by £12 billion less welfare spending, there would not be any threat to the sustainability of the finances?

[Dan Tomlinson]

If the Conservatives had credible plans and a credible history of reining in welfare spending, then I would, of course, be interested in taking them seriously. However, it was the shadow Chancellor, the right hon. Member for Central Devon (Sir Mel Stride), who was the Work and Pensions Secretary when the welfare budget exploded. We are now trying to get on top of that.

I will not address new clauses 15 to 19 directly. The Government have set out our position on them at previous stages, although I do urge the House to reject them today.

I will now turn to the points raised by the hon. and learned Member for North Antrim (Jim Allister) around amendments 112 to 139, which would have the effect of removing the distinction between the options available in respect of “specified Northern Ireland companies” and other companies from clauses 13, 14 and 15. The hon. and learned Gentleman has made his views known very clearly both today and on Second Reading. I will make the same point that the Economic Secretary to the Treasury made on Second Reading: as he will be aware—although he did not, I believe, mention this in his speech —service companies are able to benefit from the increase in the threshold. It is the Government’s understanding that there are very few, if any, goods and electricity companies in Northern Ireland that are close to the current enterprise management incentive limits, and we therefore think there will be minimal impact from these companies being subject to the previous scheme limits.