Finance (No. 2) Bill (Second sitting)

James Wild Excerpts

Committee stage
Tuesday 27th January 2026 Public Bill Committees

[Lucy Rigby]

Clause 42 abolishes the notional tax credit available to non-UK residents on UK company dividends. That credit no longer serves a purpose, under the modern dividend taxation system, and the change brings non-UK residents in line with UK residents, who do not receive the notional tax credit. It will impact fewer than 1,000 non-UK resident individuals who have UK dividend income and other UK income, such as property or partnership income, a year. The clause removes the outdated notional tax credit for non-UK residents receiving UK dividends, aligning their position with that of UK residents. I commend the clause to the Committee.

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

As the Minister says, clause 42 abolishes the notional tax credit that non-residents have historically been able to claim on their UK dividend income. Under the current system, non-domiciled individuals can offset that notional credit against other UK income streams, such as rented income or partnership profits. However, from April, that arrangement will no longer apply. Non-residents will no longer be treated as having already paid UK tax on dividends received from UK companies, meaning that they will lose the ability to reduce their overall UK tax liability from using the credit.

It is worth noting that UK residents lost access to the notional dividend tax credit back in April 2016, so in one sense the clause simply removes what is perceived as a potential unfair advantage enjoyed by non-UK residents. The disregarded income regime will continue to operate, providing some limitation on the tax paid by non-residents in specific circumstances.

We need to look at the clause, and the ones coming up, in the broader context. It represents a shift in how UK tax dividends flow to foreign investors and, in practice, it will effectively increase the tax rate burden on dividend recipients who are non-UK residents. At a time when the UK needs to attract international capital, we need to look at the measures in the Budget as a whole and whether they strengthen or undermine our competitive position. Attracting capital to be invested was a topic that we discussed this morning. International investors might be forgiven for concluding that the Chancellor is creating a tax and regulatory environment that feels increasingly unpredictable compared with some of our international competitors. Stability and certainty matter enormously in investment decisions. [Interruption.]

The Chartered Institute of Taxation has also raised concerns about the figures underlying this policy. The Treasury estimates in the famous tax information and impact note, which was referred to by the Minister, that fewer than 1,000 resident individuals will be affected. The institute has questioned whether that can be accurate, given what its professional members are seeing on the ground. There is particular uncertainty about whether non-resident trust taxpayers have been properly included within those calculations. I welcome a response and assurance from the Minister either way on that. That said, even the institute agrees that those impacted will represent a small minority of the overall non-resident taxpayer population. We concur that this charge brings a welcome simplification to tax calculations.

[Lucy Rigby]

Again, I welcome the shadow Minister’s support for these measures. However, he is absolutely wrong to suggest that these measures and the broader package will discourage foreign investment in UK companies. He will have heard the titter of laughter when he talked about the importance of stability—that not being something that was provided by his party at all when it was in government. The removal of the notional tax credit will not discourage foreign investment in UK companies, as it will not impact the overwhelming majority of overseas investors who remain outside the scope of UK tax.

In order to be affected by the measure, overseas investors will also need to have other taxable UK income, typically rental income or partnership income. If they do not have that, their dividends will not be taxable in the UK while they remain overseas. The shadow Minister is right to refer to my earlier figure that fewer than 1,000 non-resident individuals have taxable UK income in addition to their UK dividends, and that remains the figure that we are working with.

Question put and agreed to.

Clause 42 accordingly ordered to stand part of the Bill.

Clause 43

Non-resident, and previously non-domiciled individuals

Question proposed, That the clause stand part of the Bill.

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The Government will also reject amendment 33. The facility referred to here is designed to encourage individuals to bring their capital to the UK so that they spend and invest it here. Widening the scope of the facility to allow non-residents to benefit from the reduced charge without living or contributing in the UK would remove any incentive to become or remain a UK resident. We also reject amendments 34 and 35. I ask that the amendments are not pressed to a vote, and I commend clauses 43 and 44 and schedule 3 to the Committee.

[James Wild]

The Minister has skirted over quite a few detailed issues rather briefly. It will reassure the Committee to know that I intend to take a bit more time to go through what are detailed and important principles, and to reflect on questions raised in an earlier clause—how competitive we are, what we want to do, and whether we want to attract wealthy people to the country.

I will initially speak to clause 43, schedule 3 and amendments 30 to 35, which were tabled in my name. Clause 43 introduces schedule 3 of the Bill, and members of the Committee will see that the schedule runs to 14 pages of complex detail, so it is important that we properly scrutinise it. Those pages make various changes to the foreign income and gains regime brought into effect by the Finance Act 2025. On the surface, this may look like a simple tidying-up exercise, but on closer inspection it raises some important questions about the coherence of the Government’s overall approach to taxing globally mobile individuals.

While we support fair taxation, this Government have once again produced needlessly complex legislation that contains retrospective elements and leaves ordinary people potentially facing unexpected tax bills.

[Oliver Ryan (Burnley) (Lab/Co-op)]

Could the shadow Minister reflect on the fact that this clause has more amendments tabled to it than any we have dealt with so far? It deals with non-resident non-dom individuals who have previously tried to get away with paying certain levels of tax in this country. I know that he will take us through some of the details of that, but I would like to go back to the macro of his party position. If he talks about ordinary people, surely he should agree with the benefits of these changes. They would not only simplify the system but bring in much-needed tax revenue from those previously non-dom individuals who did a good deed for so long under the previous Conservative Government.

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[James Wild]

Well, indeed. I will come on to the detail. On the broader point, we support the initiative behind these measures—to encourage people to bring more of their money to the UK, precisely so it can help fund our public services. Our concern is about the implementation, and I will come on to some of the comments that representatives of the Chartered Institute of Taxation, who are widely acknowledged as experts in this area, have raised about the complexity and the retrospective elements.

As I said, schedule 3 is in three parts. Part 1 relates to relief for new residents on foreign income and gains—FIG. Under the new FIG regime, when someone moves to the UK, they do not pay UK tax on their foreign income for the first four years here. That is very sensible, but the Government have made claiming that relief so complicated that honest taxpayers risk falling into traps simply through lack of awareness.

I hope the Government will take account of the following sensible steps suggested by the Chartered Institute of Taxation: first, to remove the requirement to report every possible element of FIG as part of the claim, and instead making relief from UK tax on FIG the default position; similarly, extending the relief to the personal representatives of a deceased individual who themselves qualified; and finally, simplifying the legislation by aligning the income tax position on trust distributions with the capital gains position. I would be grateful for the Minister’s response on those points when she winds up.

Part 2 relates to the temporary repatriation facility, clarifies how remittances to the UK under that temporary facility should be matched to their original source. For years, non-domiciled individuals could keep foreign money offshore, paying UK tax only if they brought it here. The TRF offers a window until 2028, precisely to encourage people to bring money to the UK at reduced rates of 12% in the next two years or 15% in ’27-28. That is, as I said to the hon. Member for Burnley, a good idea in principle, but the devil, as ever, is in the detail.

Our friends at the Chartered Institute of Taxation pointed out some serious concerns that there are several paragraphs within the schedule—which I see the hon. Member turning to—that do not appear to work as intended or that produce unintended consequences. First, they believe that, as drafted, the new offshore income gains paragraph introduced here leads to an anomaly in the way that trust distributions are matched where a trust has generated offshore income gains. That results in trusts with surplus pre-6 April 2025 capital gains tax being treated differently from those without. We do not believe that to be the Government’s intention; perhaps the Minister can clarify.

Secondly, investments clearly fall in value, but under this legislation, if someone invested foreign income overseas and it is now worth less, they will still pay the temporary repatriation facility charge on the original higher amount. That could mean paying 12% tax on £100,000 even though the investment is worth only £60,000. Do Committee members think that is fair? Do they think it will encourage or discourage the repatriation of funds that this facility is designed to encourage, to help support our economy and public services?

I would contend that the incentive, as a result, is to keep the money out of the UK, which is not what we on the Opposition side—or, I believe, on the Government side—of the Committee want to see. We therefore tabled amendment 30 to remedy this issue, and I encourage Members to support us on it when the moment comes.

Thirdly, the Bill contains retrospective taxation. Let us be clear: retrospective taxation should be reserved for the most egregious tax avoidance, but here, trustees who made payments to beneficiaries in good faith after April, relying on existing law, may now face double taxation because of rules that look backwards. That is not about closing a loophole; it is about changing the rules after people have already acted. Our amendments 31 and 32 would ensure that double taxation does not apply retrospectively.

Fourthly, in this clause and schedule the Government have created arbitrary restrictions so that the TRF is available only to UK residents. Why should someone temporarily living abroad not be able to use this facility? The temporary non-residence rule means that they will be paying UK tax when they return anyway, so why not let them use the TRF? The rules create a situation where someone who wants to pay tax voluntarily is not able to do so. Our amendment 33 would ensure that the TRF is available to both UK residents and non-residents.

Similar concerns have also been raised regarding offshore trusts. The temporary repatriation facility applies a 12% or 15% rate to the personal FIG of individuals who have previously used the remittance basis as well as certain capital payments from offshore trusts. This was to encourage the winding-up of foreign trust structures. Right now, though, the trusts part works only if the beneficiary getting the capital could have used the remittance basis in their own right. That creates an unfair outcome in families where one beneficiary has used the remittance basis but another has always paid full UK tax on worldwide income, because only the former can benefit from the lower temporary repatriation rate if the trust is wound up.

Perhaps I could give the Committee an example to illustrate this point further: a family has an offshore trust for two adult children and one child previously used special tax rules while the other has always paid full UK tax. Under this Bill, only the first child could benefit from the TRF when the trust is wound up. That does not encourage bringing money to the UK but, I would contend, actively discourages it. Amendment 34 would therefore enable offshore trust beneficiaries who have not themselves used the remittance basis to use the TRF. Amendment 35 would enable trustees to pay a temporary repatriation facility charge on the trust’s past FIG while retaining the funds within the trust, without having to make capital payments to the beneficiary.

Amendments 1 and 2, in the name of my hon. Friend the Member for Windsor (Jack Rankin), relate to this issue. The Government refer to the temporary repatriation facility as encouraging wealthy people to stay and invest here, and the Treasury is counting on these measures to raise a significant sum for public services, although I note that the OBR suggests there is considerable uncertainty about that. However, we know that the wealthiest people—the wealthiest investors, the people who are supporting our entrepreneurs and the high-growth businesses that we want to see—are leaving the UK as a result of steps that the Chancellor has taken. By some estimates, 10,000 people have already got on a plane and left—those are figures from Oxford Economics. We can debate whether the number is 10,000 or 5,000, but some figures suggest that the equivalent of 750,000 basic rate taxpayers have left the country. So this is not about ideology; it is about giving certainty and addressing the points that the Bill as drafted does not.

The TRF could become unusable for some because of the risks it exposes them to. There is the double taxation, which I have talked about, as well as the retrospective elements, but in addition, accusations of tax avoidance could arise from using a scheme that Parliament has itself created and lead to potentially lengthy investigations. People are leaving, and the Chartered Institute of Taxation has said that tax rules under the measure make the UK a less attractive destination for people. It should be easier to understand and apply measures aimed at getting people to bring money back to the UK. There is a risk that, as drafted, these measures drive against the Government’s intention.

Amendments 1 and 2 are tabled in a constructive spirit. Amendment 1 would stop the double counting, and amendment 2 is about the retrospective and unfair action. They would provide the certainty that, according to some experts in this field, is currently missing. Without the TRF being attractive, we will not be able to get the money coming into the country. I urge the Minister to respond more fully than she did in her opening remarks and to consider whether, on Report or at a later stage, amendments could be tabled to deliver the clarity that my amendments and those tabled by my hon. Friend the Member for Windsor offer.

Without clear guidance, ordinary commercial transactions could inadvertently be caught. The Government must publish comprehensive examples, or businesses and individuals will be left guessing. When Ministers replaced the long-standing non-dom regime last year, they promised a clean, modern and transparent framework, yet within a year we have a schedule of corrective provisions to make the legislation operate “as intended”. That rather suggests that the original drafting was not as watertight as claimed, and that further tweaks along the lines we have suggested might still be needed before the system settles.

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[James Wild]

Clause 45 will extend the PAYE notification process to include treaty non-residents and introduce the 30% cap, to which the Minister referred, on overseas workday relief that can be claimed through PAYE. In simple terms, clause 45 and schedule 4 will change how employers operate PAYE for people who move to the UK but are treated as resident in another country under a tax treaty. The clause will let employers agree with HMRC that the part of the employee’s salary that is expected to be exempt overseas be left out of PAYE during the year, and it will formally limit how much foreign employment relief can be given to 30%.

The changes under the clause will require employers to send further notification to HMRC whenever there is a change in the employee’s circumstances that affects the proportion of earnings subject to PAYE. That sounds reasonable in practice, but I want an assurance from the Minister about the potential administrative burden that it will place on employers. It could mean that employers will now be expected to monitor the day-to-day working practices of globally mobile working employees. They will need to track whether individuals are working from home or from a hotel room in Boston, which is not necessarily a simple task. For multinational companies with hundreds of employees, this represents a potentially significant compliance burden at a time when we want to reduce the burdens on business. For smaller businesses venturing into international markets for the first time, it could be a disincentive—indeed, a barrier—to their trying to do so.

The Government must provide clear, comprehensive guidance on exactly what level of review and monitoring employers are expected to undertake not to fall foul of the rules. Without that clarity and guidance, we risk creating a compliance minefield in which well-meaning employers inadvertently break rules that they could not reasonably be expected to follow. Guidance can help employers to comply with the law, as we all want them to do.

The Government like to talk about making Britain the best place to do business and to champion our competitive advantage in attracting global talent—we have just discussed one area in which that may or may not be the reality—but we should seek to avoid introducing measures that potentially add to the compliance burden without giving guidance to employers. I hope that the Minister can assure the Committee that she will look at the case for publishing clear guidance to ensure that businesses are not adversely impacted.

[Lucy Rigby]

I can confirm that guidance will be forthcoming, and I am absolutely sure that it will be clear. I am also pleased to confirm that there will be no additional administrative burden on employers, because employers already have to enter a percentage figure on the PAYE notification form; as I say, this change will just require them to limit the in-year relief provided to no more than 30%. The guidance will be given to employers in April when the changes go live.

Question put and agreed to.

Clause 45 accordingly ordered to stand part of the Bill.

Schedule 4 agreed to.

Clause 46

Unassessed transfer pricing profits

Question proposed, That the clause stand part of the Bill.

[Lucy Rigby]

Clause 46 will introduce a new corporation tax assessing provision for unassessed transfer pricing profits. It will replace the diverted profits tax, a stand-alone tax that will be repealed in its entirety, providing a significant simplification.

The changes made by the clause will make the rules clearer and more straightforward for businesses to implement, and will support access to treaty benefits, including relief from double taxation under the mutual agreement procedure. The removal of the diverted profits tax as a stand-alone tax is a very significant simplification, and bringing the rules into the corporation tax framework will clarify the interaction with transfer pricing and access to treaty benefits. I therefore commend clause 46 and schedule 5 to the Committee.

[James Wild]

The clause introduces schedule 5, which will repeal the diverted profits tax and replace it with new rules to tax unassessed transfer pricing profits within the corporation tax regime, coming into effect for periods beginning on or after 1 January. The diverted profits tax will continue to apply for prior accounting periods. In effect, the clause creates a higher tax charge on profits that should have been taxed here, but were shifted out of the UK by using non-market prices between groups.

Like the DPT, the new transfer pricing profits rules are intended to target structured arrangements that are designed to erode the UK tax base by omitting profits that are subject to transfer pricing. These unassessed transfer pricing profits will be taxed at a rate that is six percentage points higher than corporation tax. In simple terms, if a global business structures its arrangements to shift profits from the UK in a pricing manipulation, HMRC will be able to bring those diverted profits into UK tax at a higher, penalty-style rate.

In principle, we support that approach. Moving away from the stand-alone tax and bringing diverted profits under corporation tax provides better treaty access and clarity, and clearly the six percentage point charge works as a deterrent, as countries that play games with their transfer policies will risk paying more tax than if they had priced their UK dealings properly in the first place. However, I would welcome the Minister’s response to the concerns that the Chartered Institute of Taxation has raised about the drafting of the clause.

First, the new tax design condition is very broad: it captures transactions designed to reduce, eliminate or delay UK tax liability. There is a question as to whether legitimate commercial decisions made for regulatory compliance or capital requirements could be caught by the condition simply because they are deliberate and happen to reduce tax liability, even when tax planning is not the primary motive. I know that is not the intention behind the drafting, but that point has been raised, so I hope that the Minister will respond in order to avoid any uncertainty as to whether businesses that think they are operating within the law, without seeking to reduce, eliminate or delay tax liability, may be captured.

Will the existing arrangements be grandfathered? Can HMRC revisit settled positions under these broader rules? As the Chartered Institute of Taxation rightly says, it is unsatisfactory to pass legislation with a wide definition and simply hope that HMRC guidance and rules will narrow it down later. That is not how we in Parliament should legislate. We discussed the loan charge during this morning’s sitting; HMRC applied rules in a way that most MPs did not consider reasonable, and we have now had to make changes through this Bill to address that historical issue. The law should be made clear in the Bill, not left to administrative interpretation.

I would be grateful if the Minister confirmed how many multinational companies HMRC estimates are using pricing manipulation to avoid tax. Can she guarantee that legitimate business structures that have previously been accepted by HMRC under the DPT will not suddenly fall foul of the scope of the new rules? Will she also comment on the main purpose test, to provide clarity and certainty for businesses?

[Lucy Rigby]

I hope that what I am about to say will provide a good deal of reassurance to the shadow Minister. The purpose of the reform was to simplify the legislation and bring the regime into the corporation tax framework. There is no intention at all to change the scope of the regime.

I appreciate that the question as to when the reforms will come into effect is of some importance. I can confirm that they will take effect for chargeable periods beginning on or after 1 January 2026. For prior periods, the diverted profits tax will continue to apply.

The shadow Minister asked how many companies would be affected. I am afraid that I do not have the statistics to hand, but I can investigate and confirm them to him in writing.

Question put and agreed to.

Clause 46 accordingly ordered to stand part of the Bill.

Schedule 5 agreed to.

Clause 47

Transfer pricing reform

Question proposed, That the clause stand part of the Bill.

[Lucy Rigby]

Clause 47 will simplify the UK’s transfer pricing rules, which protect our tax base by ensuring that transactions between UK companies and related parties are priced appropriately. The changes made by the clause include the general repeal of UK-to-UK transfer pricing where there is no risk of tax loss. This will provide a meaningful simplification for businesses. Alongside it, amendments have been made to the participation condition, intangibles, commissioners’ sanctions, interpretation in accordance with OECD principles, and financial transactions.

Government amendment 20 will ensure the consistent use of terminology with respect to financial transactions throughout the legislation.

The changes made by the clause will update UK law in line with international standards, will reduce compliance obligations and will address areas of potential legislative weakness. I commend clause 47, schedule 6 and Government amendment 20 to the Committee.

[James Wild]

Clause 47 and schedule 6 mark an evolution in the UK’s transfer pricing regime. The Opposition recognise the importance of getting this right: it goes to the heart of how multinational profits are attributed and taxed, and therefore how we ensure that companies pay the correct amount of tax in this country. The principle behind transfer pricing is simple, even if it is rarely simple in practice. I believe that these measures flow from a consultation process launched by the last Conservative Government, so they have a good origin. I hope that they will lead to greater certainty and reduce the burden that some companies may face.

[Lucy Rigby]

I confirm that the shadow Minister is right about the origin of the proposals and the date of the consultation. It is entirely right that we are bringing UK transfer pricing legislation up to date; it was last materially updated in 2004, so it is high time that these rules were updated.

Question put and agreed to.

Clause 47 accordingly ordered to stand part of the Bill.

Schedule 6

Transfer pricing

Amendment made: 20, in schedule 6, page 318, line 41, at end insert—

“(ba) in subsection (4)(b), for ‘issuing company’, in both places it occurs, substitute ‘borrower’,”.—(Lucy Rigby.)

The amendment deals with a missing consequential change to section 154 of the Taxation (International and Other Provisions) Act 2010 (transfer pricing).

Schedule 6, as amended, agreed to.

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[James Wild]

New clause 4 stands in my name and that of my hon. Friend the Member for Wyre Forest. As the Minister says, clause 48 introduces a power for HMRC to implement a new reporting obligation: the ICTS, which will come into force in 2027.

This new power would require businesses engaged in significant cross-border transactions to disclose specified information about their dealings. Rightly, the intention is to give HMRC better tools to identify transfer pricing and international tax risks that could affect the tax take, and to allow it to conduct more efficient and better-targeted compliance activity. I recognise that objective and support it in principle. I agree that the ICTS could help HMRC to identify risk earlier and to avoid wasting the time of the Department and businesses. Chasing down questions and embarking on inquiries can often lead nowhere and can cost businesses time that could be spent on growing their business.

However, it is also important that the Government explain how the system will work in practice and how it will be seen to work. Our new clause 4 would therefore require a report on the impact of these changes on cross-border trade and the administrative burden on businesses.

During the consultation last year, the Treasury acknowledged that more needed to be said about how the data collected through the ICTS system would be used and how it would fit alongside existing obligations such as master and local files. That remains a crucial point of detail that the industry and advisers will be looking for as this measure is implemented. Can the Minister shed some light on those concerns today?

As the Minister rightly says, most major economies already have some equivalent form of reporting, but it should be pointed out that the differences between them are significant. Australia, for example, operates a single transaction-driven disclosure process through its international dealings schedule; the United States of America relies on a more fragmented, relationship-based approach spread across multiple forms. Each system clearly has its benefits and disadvantages. What matters is that each country has a clear, consistent model to which businesses can understand and readily adapt.

What the Government seem to be proposing is a hybrid. That might mean that we have the best of both worlds—let us all hope so—but it might also lead to an approach that is inconsistent with the systems that some multinationals already have.

The Treasury has said that it will consult on detailed regulations in the spring of this year. We welcome that commitment. Can the Minister give an assurance that she will make sure that businesses and representative bodies will be closely involved in shaping how the system is put into practice? With the planned 2027 start date, there is not a lot of time to get the rules in place or for companies to build or modify systems to provide the new data. Can that be done without causing undue cost and disruption to businesses?

Finally, I want to make a slighter broader point on the clause. We clearly understand the importance of robust compliance and the need to protect the UK tax base on behalf of our constituents so that we can deliver public services. However, each new requirement—whether it is the ICTS, pillar two returns or transfer pricing documentation—adds to the cumulative impact on businesses.

We need to see these obligations in the round, not as each one being reasonable on its own terms. What is the overall picture of what we are imposing on companies? If that load becomes too great, the UK will be seen as a less attractive place to invest, which is certainly not what we want. Although we support the principle of better risk assessment, we continue to press Ministers to ensure that we have proportionate and workable solutions that add value for HMRC, businesses and our constituents. New clause 4 would simply require a report setting out those impacts.

I would add that, according to the Budget costings, the reporting duty would raise around £25 million in 2026-27, growing to £350 million a year, helping HMRC to tackle artificial profit shifting. That is welcome, but we should also consider the one-off and ongoing costs for businesses that have to re-engineer their systems. I would be grateful for the Minister’s response to my points about implementation and whether the hybrid model will actually be the best of both worlds.

[Lucy Rigby]

The ICTS will help HMRC to focus compliance resources, as has been discussed, on the most meaningful transfer pricing risks. We think that it will also lead to greater efficiencies by encouraging up-front compliance and reducing the length of transfer pricing inquiries. Those outcomes will benefit the compliance of taxpayers and HMRC.

Clause 48 gives the commissioners of HMRC the power to issue regulations that will determine the detailed design of the ICTS, including the information to be provided, the format of the schedule and the commencement date of the filing obligation. A consultation was held in 2025, and we will carry out a technical consultation on the draft regulations in spring 2026. The obligation is expected to take effect for accounting periods beginning on or after 1 January 2027, which is designed to allow time for businesses to adapt to what they need to do.

The shadow Minister suggested that the proposal will lead to an administrative burden; actually, it is intended to mitigate additional administrative burdens by requiring the reporting of readily available objective information. We will continue to be guided by these principles as we move into the detailed design phase, working—as one would expect—with affected businesses.

Question put and agreed to.

Clause 48 accordingly ordered to stand part of the Bill.

Clause 49

Permanent establishments

Question proposed, That the clause stand part of the Bill.

[Lucy Rigby]

Clause 49 modernises and simplifies the UK’s law on permanent establishments, which governs how the UK taxes non-residents who are carrying out business here. Specifically, the changes made by clause 49 reduce uncertainty over how profit should be attributed to permanent establishments under UK law. The greater clarity provided by these changes, in the same way as the previous clause, will assist taxpayers and HMRC by offering greater clarity. I commend clause 49 and schedule 7 to the Committee.

[James Wild]

Clause 49 and schedule 7 make changes to the rules that decide, where a company has a permanent establishment in the UK, how its profits are then taxed and when they apply. The Minister talked about modernising and simplifying the rules to bring them into line with international best practice.

To clarify, in November 2025 the OECD published new guidance on the definition of a “permanent establishment”. Can the Minister confirm whether the UK’s current approach reflects that updated guidance, as I have been advised that it does not? Some expert bodies have pointed out that the OECD changes are generally helpful and would bring more consistency across countries, so does the Minister agree that it would make sense for the UK to broadly adopt them? Is that the Government’s approach, or have they deliberately decided to have a set of UK rules? If so, what is the purpose of that, considering that we might be dealing with multinational companies operating in multiple jurisdictions that would have to follow separate rules when the OECD has brought together a coherent package?

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[Lucy Rigby]

Just to warn anyone who is not aware, clause 50 and schedule 8 are not the shortest. The changes they make are technical, but very important. Paragraphs 20 to 22 of schedule 8 prevent multinationals from trying to reduce their pillar two liability by entering into favourable tax arrangements to create pre-regime deferred tax assets or liabilities. Paragraphs 24, 25 and 34 ensure that the profits and losses relating to a UK real estate investment trust are excluded from the charge to domestic top-up tax to avoid double taxation. Paragraph 32 allows the UK to recognise the qualifying undertaxed profit rules of other jurisdictions before the OECD inclusive framework has completed a formal peer review.

Paragraphs 36 and 37 provide for a payment for group relief to be treated as a covered tax amount for domestic top-up tax purposes. Paragraph 39 reduces compliance burdens for smaller or non-material entities within a multinational group. Finally, paragraphs 2, 3, 6 to 12 and 16 to 19 update the rules on flow-through entities, permanent establishments, intragroup amounts and cross-border allocations of deferred tax so that the regime operates more smoothly in practice.

Taxpayers can elect for most amendments to apply retrospectively from the introduction of pillar two on 31 December 2023. However, taxpayers cannot select individual amendments to apply retrospectively; one election covers the whole package to prevent cherry-picking of favourable amendments. I should remind Members that, in line with the written ministerial statement of 7 January 2026, the clause does not include any amendments connected with the publication of the side-by-side agreement by the OECD/G20 inclusive framework earlier this month. The Government will introduce legislation to do that in the next Finance Bill following a technical consultation.

Government amendment 23 ensures that the legislation works as intended by making a small correction to legislative references used. Government amendments 21, 22 and 24 temporarily extend the deadline for making elections to give taxpayers more time to bed in the new IT systems needed to meet their filing obligations.

New clause 5 would require the Chancellor to review those technical amendments to the pillar two rules every six months and report on the international implementation of pillar two, among other things. We have already committed to the implementation of pillar two, which, as hon. Members will know, aims to ensure that large multinationals pay their fair share of tax. As a matter of course, the Government keep all areas of tax policy under review, so I reject the new clause.

Taken together, these changes implement internationally agreed changes, respond to taxpayer consultation, and ensure that the pillar two rules continue to be effective and administrable in the UK. I therefore commend clause 50 and schedule 8, together with Government amendments 21 to 24, to the Committee.

[James Wild]

I rise to speak to clause 50 and to new clause 5, which is in my name. Clause 50 will amend parts of the Finance (No. 2) Act 2023 and implement the multinational top-up tax and domestic top-up tax. As I set out in the last Finance Bill Committee, in October 2021 more than 135 countries signed up to the G20/OECD agreement on reforming international transactions and taxation, which the clause refers to—a major achievement that aims to ensure that multinational groups pay a fair share of tax where they generate profits. Pillar two delivers a minimum global effective tax rate of 15% for large multinational groups in every country they operate in, and the UK has been one of the first jurisdictions to legislate for the changes.

New clause 5 would require the Chancellor to review the changes on a six-monthly basis and lay before Parliament a report assessing three key issues: whether other major economies are implementing pillar two on comparable timelines and with comparable scope, whether any competitive disadvantage is arising for UK-based multinationals, and the impact of differentiated treatment for the United States. Crucially, if that review identified a material competitive disadvantage to the UK and UK businesses, the Treasury would be obliged to provide remedial measures within three months.

In rejecting new clause 5—another new clause that asks for a review—the Minister says that the Treasury is always conducting regular reviews of measures. If it is conducting this work anyway, why not share it with Parliament, and accept that it is a proportionate step to ensure ongoing parliamentary scrutiny in a very important area—a level playing field for British firms? The Minister referred to the length of the schedule. The sheer volume of amendments, coming less than two years after pillar two was first introduced, highlights the extreme technical complexity of the global minimum tax and the challenges for businesses that have to comply with it to keep up to date.

The Government’s aim is to ensure that UK rules remain consistent with the OECD model legislation, and schedule 8 is therefore aligned with the guidance and technical fixes. Those are sensible to maintain international consistency, but throughout last year there was growing international uncertainty about pillar two, the subject of the clause, as political divergence emerged over how it should operate, particularly regarding the treatment of US-parented companies.

The Minister referred to the side-by-side agreement made between G7 Governments last summer—and formalised, I think, this month—allowing certain UK and US multinationals to be exempt from parts of the rules while retaining access to the newly defined safe harbours. The agreement might bring some short-term stability, but it raises questions, and clearly we will be scrutinising it when, as the Minister said, it comes forward in future legislation. The US Treasury Secretary has described the side-by-side deal as

“a historic victory in preserving US sovereignty and protecting American workers and businesses from extraterritorial overreach.”

Will the Minister comment on what pillar two means in that context and on the UK’s position?

The impacts that might flow from that are precisely why new clause 5 is needed. The Government say that the UK is aligned with international developments, but the international landscape is shifting. Other major economies have delayed implementation or have adopted narrower regimes; meanwhile, the US has its own agreement and has not legislated for this framework at all. Without scrutiny, the risk is that UK-headquartered multinationals will find themselves complying with complex and burdensome rules, while their competitors operating elsewhere face a lighter regime. I simply note that the Chartered Institute of Taxation pointed out that it thinks the burdens of pillar two

“continue to appear disproportionate to the amount of tax that will be raised”.

If the Government truly believe that the regime provides a balanced and proportionate approach to a level playing field and that we can be assured that the competitive advantage does not go to other countries, let us have that report, see it set out to Parliament and have the matter resolved. To conclude, international co-operation on tax is essential, but we need to ensure not only that the UK is honouring its commitments, but that other countries are meeting theirs, so that UK companies are not losing out as a result.

[Lucy Rigby]

I am grateful to the shadow Minister for his comments. International co-operation on such matters, as he said, is extremely important. The side-by-side agreement, as I have made clear, will be the subject of future legislation, which will be the opportunity for scrutiny. However, as I also made clear, that agreement ensures that all large multinationals will pay their fair share of tax through the application of pillar two and pre-existing minimum tax rules, while offering welcome simplification and stability to UK businesses.

We have to be clear that US multinationals, like every other multinational company, are still subject to the UK’s 25% corporation tax on the profits that they make in the UK. They are also still subject to the UK’s domestic minimum tax rate of 15%. We recognise that a degree of complexity is inherent in pillar two, but we must not forget that it applies only to large multinational businesses and that it is needed to stop businesses shifting their profits to low-tax jurisdictions and not paying their fair share of tax in the UK. I think the shadow Minister acknowledges that that is exactly why we need it.

That being said, in relation to the complexity, the UK continues to be a strong proponent of work to develop simplification of the system, including the recently agreed permanent safe harbour. As stated in our “Corporate Tax Roadmap”, the Government will also consider

“opportunities for simplification or rationalisation of the UK’s rules for taxing cross-border activities”

following the introduction of pillar two.

Question put and agreed to.

Clause 50 accordingly ordered to stand part of the Bill.

Schedule 8

Pillar Two

Amendments made: 21, in schedule 8, page 358, line 9, leave out “50” and insert “50A”.

This amendment is consequential on Amendment 22.

Amendment 22, in schedule 8, page 379, line 26, at end insert—

“50A In Schedule 16 (multinational top-up tax: transitional provision), after paragraph 2 insert—

‘Transitional extension to deadline for elections

2A (1) Schedule 15 (multinational top-up tax: elections) has effect in its application to a pre-2026 election as if in paragraphs 1(2)(b) and 2(2)(b) of that Schedule for “no later than” there were substituted “before the end of the period of 12 months beginning with the day after”.

(2) In sub-paragraph (1), a “pre-2026 election” means an election which specifies an accounting period ending before 31 December 2025 as—

(a) in the case of an election to which paragraph 1 of Schedule 15 applies, the first accounting period for which the election is to have effect, or

(b) in the case of an election to which paragraph 2 of Schedule 15 applies, the accounting period for which the election is to have effect.’”

This amendment extends the deadline for making an election to which Schedule 15 of the Finance (No. 2) Act 2023 applies in cases where the election specifies an accounting period ending before 31 December 2025.

Amendment 23, in schedule 8, page 379, line 27, leave out paragraph 51 and insert—

“51 (1) In FA 1989, in section 178 (setting of rates of interest), subsection (2) is amended as follows.

(2) In paragraph (x)—

(a) for ‘51’ substitute ‘33A’;

(b) after ‘Finance’ insert ‘(No.2)’;

(3) In paragraph (y), for ‘51’ substitute ‘33A’.”

This amendment deals with a consequential amendment that was missed when paragraph 33A was inserted in Schedule 14 to the Finance (No.2) Act 2023 by the Finance Act 2024.

Amendment 24, in schedule 8, page 379, line 38, at end insert—

“(3A) The amendment made by paragraph 50A has effect in relation to accounting periods beginning on or after 31 December 2023.”—(Lucy Rigby.)

This amendment provides for the amendment inserted by Amendment 22 to have effect in relation to accounting periods beginning on or after 31 December 2023.

Schedule 8, as amended, agreed to.

Clause 51

Controlled foreign companies: interest on reversal of state aid recovery

Question proposed, That the clause stand part of the Bill.

[Lucy Rigby]

The clause makes changes to ensure sufficient repayment interest is paid to affected companies following a successful challenge of a European Commission decision. It provides that interest is also paid on the amounts of late-payment interest that were recovered and are now repayable. It will affect a small number of UK companies that had amounts collected and later repaid following the successful challenge of the Commission decision. The changes are expected to have a negligible impact on the Exchequer.

[James Wild]

As the Minister said, this is a fairly straightforward measure allowing HMRC to pay interest to companies that have had to hand over money under a now overturned EU state aid ruling relating to the controlled foreign company rules. The 2019 ruling was subsequently annulled. My only question for the Minister is: does the clause mark the final chapter in the UK’s compliance with the EU state aid rules relating to the controlled foreign companies regime, or could other outstanding matters give rise to further issues or payments?

[Lucy Rigby]

The shadow Minister will appreciate that it is a requirement of UK domestic legislation to put companies in the position that they would have been in had the recovery legislation not been introduced, and it is that principle on which the clause is based.

Question put and agreed to.

Clause 51 accordingly ordered to stand part of the Bill.

Clause 52

Legacies to charities to be within scope of tax

Question proposed, That the clause stand part of the Bill.

--- Later in debate ---

[Lucy Rigby]

Clause 52, in combination with the other clauses in the Bill, will support the Government’s aims of closing the tax gap by strengthening compliance powers to challenge abusive arrangements by which donors or trustees of charities can enrich themselves. The clauses also simplify the tax rules by equalising the tax treatment of investment types and tax reliefs used by charities. The changes made in clause 52 will bring legacies into the definition of “attributable income”.

New clause 6 would require the Government to report on the impact of clause 52 on charitable giving through estates and on the income of the charity sector. The changes are aimed at those charities and donors who seek to make a financial gain. They will not penalise charities when legitimate donations are received and investments are made. The Government have published a tax information and impact note that sets out the impact of the changes, and it showed that the measures will have a negligible impact on businesses and civil society organisations such as charities. Once the measures have been implemented, HMRC will assess the impact by monitoring tax reliefs claimed by UK charities, so a formal evaluation is not required. I therefore propose that clause 52 should stand part of the Bill, and that new clause 6 should be rejected.

[James Wild]

Charities are a very important topic. We need to ensure that we give it appropriate scrutiny, given the importance of charities in our society and communities. Clause 52 and new clause 6—which I will speak to—relate to extending the definition of attributable income to include legacies left to charities. In practice, that means that when a charity receives a gift left in a person’s will, it could face a tax charge if that money is not spent on its charitable activities.

How charities use their funds is a topical subject in the context of the Church of England, which is planning to spend £100 million on its fund for healing, repair and justice—effectively a reparation fund for slavery, which many consider not to be an appropriate use of the funds, or what people gave funds to the Church for.

I now turn to the clause. The change will apply to gifts made on or after 6 April this year. New clause 6, in my name—it bears repetition—would require the Chancellor, within six months of the Act becoming law, to publish a report on the impact of the measure on charitable giving through estates and on the wider impact on the charity sector.

Concerns have been raised that expanding rules to cover legacies could have unwelcome implications if charities do not apply inherited funds quickly enough to their charitable purposes, leading to them being taxed. The Institute of Chartered Accountants in England and Wales warns that that uncertainty, particularly around the timing, may discourage potential donors from including charities in their wills. Clearly, none of us would wish to see that.

HMRC has said that it will not set a deadline for how soon money must be used, although that ambiguity creates issues in itself. If the rules are unclear, HMRC could later decide that a gift has not been applied appropriately and withdraw the tax relief, undermining confidence that legacy gifts to charities will remain tax-free. Perhaps the Minister could give the Committee some clarity on that point, and on how HMRC will determine what counts as timely or appropriate application of funds.

There is also a concern about the administrative burden it may place, particularly on smaller charities, which will have to prove that each legacy received has been properly applied to charitable purposes, even when the money is placed in long-term endowments or reserves. The Charity Finance Group warns that the changes could mean more record keeping, compliance checks and bureaucracy, taking money away from frontline charitable activities and towards administration. I do not think that anyone would wish to see that. I do not know whether the Minister has anything more to add on that complexity.

Adding complexity could also make life harder for executors and delay the administration of estates, which could affect the timing of cash flows to charities at a time when finances in the sector are under considerable pressure, and income is critical for them to do their job. There is also a risk that wealthier donors might think twice about leaving legacies to smaller charities, if they think that the charity might struggle to comply with HMRC rules.

I am really asking for the Minister’s assurance that HMRC will take a sensible and proportionate approach, particularly with smaller charities that are seeking to do the right thing in applying these rules. We all want to avoid the potential risk that this measure could deter charitable giving, when that is clearly not the intention. It is important that the concerns raised by the sector are aired in the Committee, and it is our role to do so.

[Lucy Rigby]

I will start with the principle that, because legacies have received tax relief, it is important that they are spent on charitable purposes, otherwise they will be subject to a tax charge. More broadly, the Government are very much committed to supporting charities and their donors through tax relief, which was worth over £6.7 billion in 2024.

The changes in the clause are aimed at those charities and donors that seek to make financial gain. They will not penalise charities where legitimate donations are received and investments are made. The measures are intended to protect the integrity of the charitable sector by ensuring that donations, investments and charity expenditure are deployed for charitable purposes, not the avoidance of tax.

The shadow Minister fairly referred to any burden that may fall on smaller charities. The Government of course recognise that many small charities are run by unpaid volunteers, and for that reason we have sought to design the new rules in a fair and proportionate way. HMRC will help the sector to understand and prepare for the changes by providing clear communications and guidance.

I also want to be clear, in response to the shadow Minister, that the changes to the attributable income rules mean that legacies received by a charity will become chargeable to tax if they are not spent charitably. The changes reflect the fact that this income may have already received considerable tax relief. We have no plans to stop charities accumulating donations, so there will be no deadline for the spending of legacy funds.

Question put and agreed to.

Clause 52 accordingly ordered to stand part of the Bill.

Clause 53

Approved charitable investments: purpose test

Question proposed, That the clause stand part of the Bill.

--- Later in debate ---

[Lucy Rigby]

Clause 53 changes the definition of “approved charitable investments”. The Government recognise 12 types of investments for charitable tax relief, but presently only one type of investment is required to be for the benefit of the charity and not the avoidance of tax. The Government are extending this rule to all 12 types of investment, making the rules both simpler and tighter.

New clause 7 would once again require the Government to report on the impact of clause 53 on charity investment strategies. As with clause 52, these changes are aimed at those charities and donors that seek to make financial gain. They will not penalise charities where legitimate donations are received and investments are made. As the shadow Minister may expect, we have published a TIIN setting out the impact of these changes, which showed that these measures will have a negligible impact on businesses and civil society organisations such as charities. I commend clause 53 to the Committee, and I ask that new clause 7 be rejected.

[James Wild]

I rise to speak clause 53 and new clause 7, which was tabled in my name. My comments will reflect submissions from people involved in the charitable sector and my discussions with them. The clause extends the allowable purpose to all categories of recognisable charitable investment—at present, it applies to only one, but it will cover all 12. The Institute of Chartered Accountants in England and Wales has raised a suggestion that the test be reframed from

“for the sole purpose of”

to “wholly or mainly” to the benefit of the charity. The concern is that there could be increased obligations for compliance on trustees who have to demonstrate that their every investment in, for example, their portfolio was made for the benefit of the charity rather than an ancillary purpose therein. Was that more flexible approach something that the Government have considered, and if so why did they chose to reject it?

[Mr Reynolds]

As the Minister has outlined, clause 53 extends the purpose test from one category to all 12 categories. What guidance will HMRC provide for charity trustees to determine where the line is to be drawn between a legitimate investment strategy and those that are seen as having an ulterior purpose, because anti-avoidance should not penalise prudent charitable investment strategies?

Can the Minister also confirm exactly which charity sector bodies were consulted on these provisions and how they responded to that consultation, because many charity trustees are volunteers and this seems to place a significantly larger burden on those charity trustee volunteers to determine where to draw the line? It would be interesting to see what the consultation came back with as to where they would see that line and how they would attribute it.

--- Later in debate ---

[James Wild]

I rise to speak to clause 54 and to new clauses 8 and 9 tabled in my name. The clause makes significant changes to how tainted donations are treated. At present the donation is considered tainted only if it was made with an improper purpose. This clause replaces the motive-based test with an outcome test. If someone connected to the donor under the new regime receives financial assistance from a charity, such as a grant, guarantee or loan, the donation will be deemed tainted regardless of the donor’s intent. I have tabled new clause 8 to require the Government to publish a report on how the change affects legitimate charitable giving, or genuinely tackles tax abuse.

New clause 9 would require a review of the implementation of the new outcome test after two years and would assess whether it proves to be clearer than the existing purpose test. The Minister and the Government said that this measure is about tightening anti-avoidance rules and the challenge of proving intent. But I have been approached by the Charity Finance Group, which represents over 1,400 organisations and manages one third of the sector’s £20 billion annual income, and it has raised concerns around the change. It warned that the outcome test could unfairly penalise both donors and charities for results outwith their control.

For example, a donor could make a genuine good faith contribution only for a charity months later to make a routine investment or financial arrangement that inadvertently benefits a linked person. That donor could then find themselves caught by the anti-avoidance rules without ever having done anything wrong. That could cause uncertainty and raise concerns about people leaving legacy gifts that the charity sector relies on.

It is not just the charity and that one body. The Institute of Chartered Accountants in England and Wales has warned that donors may have limited influence over the outcome once the donation has been made. It, too, questions the fairness and practicality of shifting from a motive to an outcome test. Indeed, it proposes that the existing rules are not altered for that precise reason. We tabled the two new clauses to introduce proper scrutiny of the measures and ensure Parliament understands the effect on the charitable sector and whether donations continue to be given.

Does the Minister consider there is a risk that shifting to such an approach could have the effect that the charitable sector has set out? If so, will she commit to perhaps providing some practical guidance, with examples that charities and their compliance teams could look at so that they can see that charitable giving is not undermined? None of us on this Committee would want to do anything that would undermine the ability of charities to raise money and disincentivise anyone from giving money for fear that they might be caught inadvertently by rules when they have done nothing wrong.

[Lucy Rigby]

It is important to recognise that the tainted donations rules ensure that the usual tax reliefs are not available where someone gives money to a charity with the intention to benefit financially from it. Previously, HMRC was only permitted to consider the intention of a donation and whether a donor had received a financial advantage from a donation, but now, with these changes, it will also be able to consider the outcome of the donation and whether a donor had received financial assistance. In that respect, considering the outcome of a tainted donation is a positive step towards challenging abusive arrangements. As I have said in relation to previous clauses, HMRC will come forward with clear guidance on the application of the clauses, and, to the shadow Minister’s point, that guidance might well contain examples.

We are taking a range of steps to ensure that the charity sector and the wider public are aware of the changes, which I hope reassures the shadow Minister. A detailed summary of consultation responses has been published. As I said, HMRC will provide clear and practical guidance in advance of implementation.

Question put and agreed to.

Clause 54 accordingly ordered to stand part of the Bill.

Schedule 9 agreed to.

Ordered, That further consideration be now adjourned. —(Mark Ferguson.)

Covid-19: Financial Support

James Wild Excerpts

Thursday 15th January 2026 Commons Chamber

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

I, too, congratulate the hon. Member for Stratford-on-Avon (Manuela Perteghella) on securing this important debate. I thank all hon. Members who have spoken—I think more than 10 did—about what their constituents suffered and continue to suffer. They set out some very powerful examples.

It is almost six years since the first cases of covid were recorded in the UK, after two Chinese nationals travelled here from Wuhan. As has been said, these were some of the most challenging times for our nation. Some 230,000 people tragically died, and there is a very powerful memorial just across the river to remind us; we see it every day. Lockdowns and restrictions were imposed. Choices were made that no Government would want to make. As a newly elected MP, I was faced with the need to vote for and support measures restricting people’s freedom—something that I did not expect to have to do when I came into this place.

Clearly, not every decision taken was right. Mistakes were made, as they would be in a pandemic, but overall this unprecedented challenge was met with unprecedented action. On the economy, the subject of this debate, the actions taken by the then Conservative Government protected millions of jobs, and supported businesses and those most in need. When the pandemic struck, the Government acted swiftly. The coronavirus job retention scheme—the furlough scheme—which protected 11 million jobs at a cost of £70 billion, was announced on 20 March. Shortly afterwards, the first lockdown was announced. At its peak, nearly 9 million people were on furlough, preventing widespread unemployment. For the self-employed, a topic covered in most contributions, the self-employment income support scheme was set up and delivered nearly £30 billion, across five rounds of grants, to nearly 3 million individuals. Those schemes provided a lifeline to those whose livelihood was threatened through no fault of their own.

Beyond the employment support schemes, eight grant schemes saw £23 billion paid to small businesses. They were administered by local authorities. I pay tribute to the work they did to put in place systems and mechanisms for processing those payments rapidly and getting the support to people who needed it. Through three loan schemes, nearly £80 billion-worth of loans were approved. The bounce back loan scheme supported 1.5 million businesses with nearly £50 billion of funding.

It was not only loans that provided crucial support. Some £10 billion was made available in business rates relief to nearly 370,000 premises in the retail, hospitality and leisure sector, and we are now seeing the consequences of unwinding some of that support. VAT for the hospitality sector, which was particularly affected by the restrictions and rules that were put in place, was cut to 5%. I supported the campaign for that cut, as did many Members across the House. That unprecedented package supported jobs and livelihoods across the UK.

The Government also acted to help certain groups who faced particular challenges. A £20-a-week uplift was put in place for people on universal credit to help those on the lowest incomes, and rules about eligibility for benefits were relaxed. Additional support for jobseekers through the kickstart and restart schemes was also rolled out.

Of course, as the hon. Member for Stratford-on-Avon and other hon. Members have said, the support did not reach everyone. ExcludedUK was established in May 2020 to represent individuals and small business owners who fell outside the main financial support schemes. As has been set out, the group estimates that around 3.8 million people were unable to access full financial support, despite losing their income. Those individuals included the newly self-employed, company directors paid in dividends, and those whose self-employment income was less than half their overall earnings.

I know the genuine hardship faced by my constituents in that situation from my time in this House, and from raising constituents’ issues with Ministers. Hon. Members from across the House will remember the constant Teams and Zoom meetings with Ministers, in which we put forward the position of those people, as well as the debates held in the House and the reports by the Treasury Committee and others drawing attention to the situation.

The response that was consistently provided was about the challenges in identifying workable solutions for HMRC’s system, which, as the hon. Member for Didcot and Wantage (Olly Glover) said, was unable to differentiate dividends coming from an individual’s company from money from other sources. The cut-off points—the £50,000 threshold—for self-employed people also led to real difficulties and unfairness. The fraud risk, which has been referred to by a number of hon. Members, was one of the reasons given by the then permanent secretary to the Treasury as to why schemes put forward by the Federation of Small Businesses were cited as not being possible. There were changes through the five self-employment income support scheme grants. Frankly, though, the restrictions created the impact on the people to whom hon. Members have referred. The ongoing concerns raised by the campaign merit serious consideration—and the covid inquiry will give them that consideration during the module referred to by the hon. Member for Stratford-on-Avon.

Looking to the future, we should ensure that if and when the next pandemic strikes, we have better data, and better systems to put in place support, if needed; Making Tax Digital may help in that regard. We should ensure that rules do not exclude people unfairly. Equally, we must learn the lessons from the pandemic, particularly around the damaging impact of lockdowns, as my right hon. Friend the Member for Tatton (Esther McVey) said; if we do not put those restrictions in place, such huge financial firepower will not be needed.

In the pandemic, the pressure for action to help people and businesses was incredibly intense. There were trade-offs relating to time and the checks that could be implemented on support schemes. I recall vividly the clamour for support for small businesses, which I was part of. That led to the bounce back loan scheme, which had limited checks, leading to consequences involving fraud. That scheme, however, enabled lots of businesses to survive that would not otherwise be here today. The Government could have spent months designing the perfect scheme while businesses collapsed and families struggled; instead, they acted to protect lives and livelihoods. Some £410 billion was spent on covid measures—an extraordinary sum that added greatly to our debt. However, predictions by the Bank of England that unemployment would reach 9% were prevented. Unemployment peaked at 5.2%, before falling back to 3.7% two years after the first lockdown.

However, a lot of people clearly missed out on full financial support. While there will continue to be debate about the decisions taken and lessons to be learned, undoubtedly our country would be in a far worse place today were it not for the decisions taken at the time.

Finance (No. 2) Bill

James Wild Excerpts

Committee of the whole House
Tuesday 13th January 2026 Commons Chamber

[The Second Deputy Chairman]

I call the shadow Minister.

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

On behalf of His Majesty’s Opposition, I wish to speak to new clauses 22 to 24, tabled in my name and those of my hon. Friends. As the Minister set out, clauses 63 to 68 introduce measures to apply inheritance tax to unspent pension assets and other death benefits for deaths occurring after 6 April 2027.

This Labour Government have taken taxes to record levels, with £26 billion in additional taxes in this Budget and £66 billion since the election. These tax increases were not mentioned in Labour’s manifesto. Labour is increasing taxes on family businesses, farms, jobs, dividends, savings, motorists and now death. Removing the inheritance tax exemption for pensions could undermine efforts to encourage people to save at a time when people are not saving enough. And what do the Government do? They limit the salary sacrifice pension contributions scheme and introduce a new raid on people’s pensions pots.

The Minister did not refer to the impact assessment, but it is worth pointing out that it estimates that 10,500 estates will now become liable for inheritance tax, raising £1.5 billion by 2029, and 38,500 estates will pay more inheritance tax than was previously the case. That is why we oppose this extension of inheritance tax and the underlying principle, to which the Minister seemed to allude, that people’s money belongs not to them but to the state.

New clause 22 is straightforward. It would require the Chancellor to set out the impact of these measures on pension saving, household saving decisions and personal representatives. There is real concern—I am surprised the Minister did not address this—about the administrative burden being placed on personal representatives and the effect on the industry. Personal representatives will be required to identify every pension asset, calculate the inheritance tax due and ensure payment within six months, and they will be personally liable if they fail to settle all the liabilities due. In many cases, that deadline would be impossible to meet and must be extended. Furthermore, if a pension fund has to quickly sell illiquid assets, such as commercial property, it may not get the full market value, but the Bill does not introduce a relief where the underlying assets must be sold and the proceeds are less than the value of the assets at the time of death. Late payments will attract interest at 8%. By contrast, someone in self-assessment has 10 months to pay tax on the income they already understand.

Both the Association of Taxation Technicians and the Chartered Institute of Taxation have offered some practical solutions, the first of which is to extend the withholding periods. Personal representatives can ask pension administrators to withhold 50% of funds for up to 15 months, but that is simply not long enough for the complex cases I have referred to, particularly where business property valuations have to be agreed with HMRC. Will the Minister consider allowing HMRC to extend withholding in such complex cases?

Secondly, the Government should allow instalment payments for illiquid pension assets. Billions of pounds of pensions wealth are in illiquid assets. The Government allow inheritance tax to be paid over 10 years for illiquid estate assets. Why deny the same practical relief for pensions?

When this policy was announced, the Office for Budget Responsibility gave it a “very high” uncertainty rating and estimated that behavioural effects will cut the static yield by about 43%; the Government’s own forecasters accept that the changes may well significantly alter saving behaviour. The new clause would simply require the Chancellor to assess that impact and come to the House to make it clear.

New clause 23 would require the Chancellor to consult on the impact of clauses 63 to 67, and whether they deliver better outcomes for savers and pensioners. The truth is that the Government rushed the consultation out after the 2024 Budget and followed it with a very narrow technical consultation, which did not consider the principled question of whether this approach to pensions being brought within the inheritance tax framework was appropriate. As the Investing and Saving Alliance told the House of Lords Economic Affairs Committee in its inquiry to which the Exchequer Secretary also gave evidence:

“If we were consulted and listened to, we probably would not be having this discussion today, because I do not think pensions would be going into IHT.”

Both the chartered institute and the ATT have criticised the Government for consulting on pensions in isolation, rather than in the context of individuals’ wider inheritance tax position. Our new clause is explicit. Consultation must take place to assess whether these changes

“deliver better outcomes for savers and pensioners”

—wording that reflects the commitment the Labour party made in its manifesto.

New clause 24 is essential. It would require HMRC to publish comprehensive guidance on the new rules for pensions and to set up a dedicated helpline. Why does that matter? Because this measure will be incredibly complex in practice. The chartered institute has said that professional executors are already questioning whether they can continue to operate in the market at all. Some firms, we are told, are already leaving the market. If professionals step back, the burden falls on lay personal representatives: often grieving family members or friends, with more errors, delay and potentially a wider tax gap ensuing.

Professional indemnity insurers also need clarity, yet when is HMRC due to deliver detailed guidance? Not until spring 2027, just weeks before the changes take effect. That is completely outrageous and far too late. That is why the new clause requires guidance to be published within six months of the Bill being passed.

I want to touch on a broader concern that has been raised with me on the potential serious unintended consequences for unmarried couples. Today, couples can anticipate making financial provision for each other via pensions, but if this measure comes into force they will have to look at other options. If one member of an unmarried couple in their 50s or 60s dies with a pension at peak value, the survivor could lose up to 40% of that fund. Are Ministers talking to pension scheme administrators to mitigate the risks for such couples and to provide clear guidance?

These clauses increase taxes, add complexity, penalise saving and add stress for grieving families. Despite clause 67, we are also advised that there is still a risk of double taxation of inheritance tax and income tax, which could see beneficiaries paying an effective tax rate of 67%. Our amendments seek to mitigate their worst impacts. The Chancellor should assess the real impact on saving behaviour and personal representatives. She should consult properly on these provisions and she must provide clear guidance, backed by dedicated support. We should be incentivising saving and encouraging people to do the right thing. Extending inheritance tax does the opposite, and we will oppose the Government’s measures.

--- Later in debate ---

[The Second Deputy Chairman of Ways and Means (Caroline Nokes)]

I call the shadow Minister.

[James Wild]

These changes were presented as some sort of simplification and modernisation, but clauses 83 and 84 nearly double remote gaming duty from 21% to 40% and increase general betting duty to 25%. We will have some of the highest rates of tax on gambling in the world. As we have heard from some Members, the industry has warned that that could have severe consequences for an internationally competitive sector that supports tens of thousands of jobs, underpins horseracing and other sports and already contributes significantly to the Treasury. It is questionable whether these measures will lead to stable, long-term revenue gains for the Exchequer, and there is a very real risk that they will result in job losses and greater use of unregulated operators in the black market. New clause 25 would require the Chancellor to come back to the House and explain what the consequences have been for revenue, sports and horseracing, high street betting shops, the black market, jobs and the public finances.

Of course, the origin of these changes owes much to Gordon Brown, who encouraged the Chancellor to hike taxes in order to increase welfare spending. Proponents of higher taxes often suggest that they will not have any consequences, but it is the role of us in this House to scrutinise potential changes and assess the impact after the event. Independent modelling from EY shared by the Betting and Gaming Council suggests that the impact of doubling remote gaming duty could be the loss of 15,000 jobs, and a further 1,700 jobs could be lost as a result of the increase in general betting duty. In total, 17,000 positions located in Stoke-on-Trent, Leeds, Sunderland, Manchester, Nottingham, Newcastle-under-Lyme, Norwich and other areas could be affected. Of course, those are simply projections—they could prove to be pessimistic, and we certainly hope that will be the case—but when unemployment has risen consistently under this Government due to the jobs tax and other costs, such warnings should not just be dismissed. That is why the Chancellor must account for the impact of her choices, as new clause 25 requires.

There has been some mention of horseracing. I was pleased to join colleagues across the House in support of the “Axe the Racing Tax” campaign. That is another tax that the Chancellor wanted to introduce, but she was forced into one of her all-too-regular U-turns.

[Alex Ballinger (Halesowen) (Lab)]

Does the hon. Gentleman accept that the proposal to harmonise gambling taxes, which the horseracing industry was most opposed to, was first proposed by his Government? It is something that they were proposing; we have just inherited it.

[James Wild]

We are debating the measures in this Bill, which was introduced by this Government. I was not involved in the changes that the hon. Gentleman refers to, and I certainly would not have supported hitting the horseracing sector in the way that was proposed. I do not remember that being in a previous Finance Bill introduced by a previous Government; it is this Government who sought to bring forward those measures, but they were roundly rejected, because horseracing supports around 85,000 jobs and contributes £300 million in tax revenue every year.

Despite the Government’s climbdown in exempting horseracing from the higher rates, the industry could still feel the consequences of this Government’s approach to gambling duties. When the online betting sector is squeezed, sponsorship is likely to be reduced, and because racing’s funding depends heavily on those partnerships and that sponsorship, we could see an impact on racing. In my area of Norfolk, we are very fortunate to have Fakenham races—I went there to support the British Horseracing Authority’s campaign against the Government’s plans. That venue is synonymous with the area and its identity, and is a source of local employment, not just at the track itself but for the farriers, the pubs, the hotels and the whole ecosystem that supports racing. That is why these clauses in the Bill continue to pose a risk to the sector and other sports, and that risk needs to be accounted for.

I now turn to the black market, an issue that was raised by the hon. Member for Stoke-on-Trent Central (Gareth Snell) and my right hon. Friend the Member for Stone, Great Wyrley and Penkridge (Sir Gavin Williamson). The Government have acknowledged the risks associated with taking this approach, which is why they quietly set aside £26 million for the Gambling Commission to combat expansion of the black market, but the same EY analysis suggests that over £6 billion in stakes could migrate to the black market, doubling its current size and undermining the progress that has been made through the existing regulatory framework. The Office for Budget Responsibility has identified potential leakage of around £500 million in lost revenue as activity shifts away from properly regulated markets. Those projections—which again could be wrong, but could also be right—raise legitimate questions about the overall effectiveness of the Government’s approach.

When taxes rise too far, behaviour can change and the yield can go down, which is what we will see with a number of the tax rises that the Government have included in their Finance Bill. Rather than reducing demand, activity will move to unregulated markets where consumer protections are weaker, fraud risks are higher, and tax revenue is not collected. I am not sure we have heard a convincing response from the Minister about how that will be addressed and whether those risks have been taken properly into account.

Let us look at what happened in the Netherlands, where the Dutch Government raised their remote slots tax rate to 34% last January. Within months, gross gaming revenue fell by a quarter and gambling tax receipts dropped to just 83% of the previous year’s figure, leaving a €200 million shortfall from the projections. Somewhat predictably, the Dutch regulator then reported a huge growth in the number of people accessing unlicensed domains, rising from 200,000 to a million. That should serve as an example of why we should be cautious about the Chancellor’s plans. Experience suggests that changes have unintended consequences, and those risks must be carefully assessed. In winding up, will the Minister provide a bit more clarity about how that will be monitored and what steps the Government will take if there are unintended consequences and those projections prove to be accurate?

There is some debate and confusion in the sector and some of the professional bodies about the treatment of free bets and free plays. The sector and those bodies have raised concerns about that. The Budget costings document calculates gambling duty using the gross gambling yield, which is the revenue retained by operators after paying out winnings to customers. However, current law uses a wider measure, which also counts the value of free bets and free plays. That means there is a potential mismatch. Will the Minister clarify that? I am sure she has had representations on it directly.

We need to strike a balance with the levels of taxation. The industry is warning that these increases will impact on sports and lead to job losses and more black market activity. New clause 25 seeks transparency and an answer to those concerns. It asks the Chancellor to assess the impact of these rises on horseracing, the black market, jobs and the public finances. That is the minimum that Parliament should expect, and I hope Members will support our new clause.

[Lizzi Collinge (Morecambe and Lunesdale) (Lab)]

I rise to speak to clauses 83 to 85 and schedule 13, which respectively outline: an increase in tax on online gaming, such as online slots or casino games; a new rate of general betting duty specifically for online betting, such as placing a bet on a football match; and, removing bingo duty.

Online gambling has evolved quickly, and legislation has simply not kept up. Before, someone might have popped down to their local high-street betting shop or organised a trip with their friends to the casino. It was confined to a specific place that people had to go to and then at some point leave. That does not mean that there were no problem gamblers—of course there were—but it did impose necessary social and physical limits on gambling. Online gambling has changed that beyond all recognition. Now, that casino fits into someone’s pocket. Online platforms know people’s habits, when they use their phone most and when they have not gambled in a while, and the platforms can tailor notifications to pull people back in. The technology is designed to prey on human instinct, using algorithms that make betting time-sensitive, compulsive and constantly available. In case the opportunity to gamble ever slips someone’s mind, gambling companies will be sure to remind them in a commercial break for sports matches, on the side of buses and emblazoned on the microphone at premier league post-match interviews.

People might see some of the seemingly generous offers they are given. For their first £5, the betting companies might give them £100 or even £200 credit to gamble with. That feels like a lot of money to most people, but it is pennies compared with what the companies are making from their current customers and what they might make from you, once you are hooked.

As someone who, to be frank, does not like gambling—I do not gamble, and I do not understand why people enjoy handing their money over to betting companies—I detest the tactics used by gambling companies to pull people in. As online gambling has evolved exponentially, the online platforms have been able to get away with dodging responsibility for problem gambling or for paying their fair share into the Treasury. As my dad always says, “You never meet a poor bookie.” That is why I support clause 84, which will introduce a new higher rate of tax on remote betting, so that online bets are more expensive compared with in-person betting. Those taxes will be paid by the platform, so that we can catch up, finally, with the reality of the gambling world, which has moved far beyond the traditional model of shops and casinos that the tax system was designed around.

Clause 83 raises the rate of remote gaming duty, the tax on online slots and casinos. That reduces the incentives for operators to push the most harmful forms of online gambling, making the system fairer and safer for everyone. I represent Morecambe, a seaside town with a host of gaming businesses on the front and a bingo hall. The evidence shows that it is not the penny slots or the weekly bingo games that drive the majority of problem gambling, and I am pleased that the new remote gaming and betting duties recognise that.

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[The Chairman of Ways and Means (Ms Nusrat Ghani)]

I call the shadow Minister.

[James Wild]

It feels like we are getting warmed up for scrutinising the 536 pages of the Bill upstairs in the Public Bill Committee shortly. It is good to see that the popularity of the topics we are debating has increased as we move on to alcohol duty, which clause 86 increases in line with the retail prices index from 1 February.

I am proud to confirm that His Majesty’s Opposition are big supporters of beer, wine, spirits and hospitality businesses. As such, we oppose these tax rises. This £26 billion tax-raising Budget piles pressure on households and businesses that are already struggling because of the decisions of the Chancellor. Prices are high, growth is sluggish and now the Chancellor has chosen to impose another duty hike.

Our new clause 26 would therefore require the Chancellor to publish a statement on the impact of increasing alcohol duty on the hospitality sector, on pubs, on UK wine, spirit and beer producers, on jobs and on the public finances. These sectors are already being hammered by this Government’s economic choices. A Government who say that the cost of living is their priority are raising alcohol duty, putting more cost on to people and businesses that keep our rural communities and high streets alive.

[Dr Scott Arthur (Edinburgh South West) (Lab)]

May I start by wishing everybody taking part in dry January good luck? I admit that I am not one of them. It is fantastic that the shadow Minister is talking about the impact of these changes, but I am surprised that his list did not include alcohol harm. Many charities and campaign groups are pleased that the Government are trying to move people away from drinking at home to drinking in the hospitality sector. Does he accept that that is a good thing and its benefits should be evaluated?

[James Wild]

Indeed. When we brought in the new duty system, we focused on the strength of alcohol in terms of the tax. We want to encourage more people into the hospitality sector, but the Government seem to have a policy of driving people away from going into pubs—and not just Labour MPs.

In government, we recognised the importance of those sectors to jobs, to our communities and to growth, and the simplified duty system, including the two new reliefs—draught relief and small producer relief—were warmly welcomed. My hon. Friend the Member for Kingswinford and South Staffordshire (Mike Wood) made the point that the Government are choosing not to implement similar measures on draught relief. At the 2023 autumn statement we froze alcohol duty rates, and we extended that freeze in the spring Budget of 2024. I am proud to support that record: we had a Government working with the sector, not against it. It gives me no pleasure to say that this Government have chosen a very different path.

[Sir Edward Leigh (Gainsborough) (Con)]

My hon. Friend and I both represent large, rural constituencies. Could Members across the House think creatively about how we are going to save the great British rural pub? That could be by giving special credence to those who sell draught beer, rather than selling it in supermarkets, or through national insurance—all that sort of thing. Otherwise a great institution, which most people have to drive to, will be in danger of extinction. Are those pubs not part of our history?

[James Wild]

They absolutely are. I would be happy to come to my right hon. Friend’s constituency to discuss this over a pint in one of those small rural pubs, which are the hub of our villages and hamlets. Once they are gone, it is very difficult to replace them. The Government clearly have the hospitality sector in their crosshairs, and clause 86 is just the latest salvo.

This is no small corner of the economy. Some 3.5 million people are employed directly in the sector, which invests £7 billion a year, yet the industry is being punished by the Chancellor’s decisions and this clause. UKHospitality’s “#TaxedOut” campaign has highlighted the nearly 90,000 jobs lost in this sector. With unemployment now above 5%, young people in particular are paying the price. That is a consequence of the Chancellor’s damaging tax rises, which were supported by Labour Members.

Higher alcohol duties, the jobs tax, energy bills and soaring business rates are layering cost on cost. It is little wonder that UKHospitality has called the Government’s approach a “hammer blow”.

[Ian Roome (North Devon) (LD)]

Does the shadow Minister agree that as a result of this policy, lots of local pubs, including lots more in the hospitality industry, will go out of business?

[James Wild]

That is very clearly the risk.

The British Beer and Pub Association has said that the proposed increases will be damaging to the sector, and we may well see more closures as a result. New clause 26 would shine a light on the real impact that these decisions will have on rural pubs, jobs and businesses. I hope the Minister will consider the new clause and not simply dismiss it by referring to the tax and information impact note, as she did with an earlier group of amendments. That is a prediction of what will happen; it is not a review of what the actuality is.

[Dr Luke Evans (Hinckley and Bosworth) (Con)]

This new clause is even more important given the fact that the Government, the Chancellor and the Prime Minister understand the impact that the Bill will have on pubs. They have said that they will bring forward measures to help and support pubs, yet we have not seen those measures, because they are not in this Bill. We therefore need to have some form of accountability to be able to understand the impact of not only the measures before us, which we can vote on, but the proposed ones that will come in to support the measures that the Government are already looking to put in this Bill, which will have an impact. Does that make sense? Does my hon. Friend agree?

[James Wild]

I think that makes sense, and I certainly agree with my hon. Friend.

The Government are having to try to put in place solutions to deal with problems that they have created. If Labour MPs were welcome in pubs across the country, they would hear quite how difficult—

[Gareth Snell]

I am!

[James Wild]

I am sure that the hon. Member is welcome, but let us be clear that some are not.

If I go into a pub, I do not think I will find many publicans who think that this Government are pro-pub. We have a Chancellor who said that she did not understand the impact that her Budget, the revaluation and the removal of the discount on business rates would have. That is staggering. Frankly, it shows once again that she does not understand business and was not listening when the sector and many others warned that that was precisely the impact that her policy would have.

The Chancellor is reportedly about to do a U-turn on her business rates raid. She has not come to the House yet to inform us or the sector, but what is being briefed is likely to be wholly inadequate. On the radio this morning we heard Ministers saying that the impact will be limited to pubs, but the hospitality sector, leisure businesses and retail all face huge increases in business rates.

[Mr Joshua Reynolds]

Does the shadow Minister agree that if this Labour climbdown is happening, it is not enough for there to be a smaller increase than the one that was planned? There needs to be no increase in business rates.

--- Later in debate ---

[James Wild]

The hon. Gentleman tempts me on to my next paragraph.

Instead of tinkering, the Chancellor should adopt Conservative party policies and abolish business rates for pubs, hospitality businesses, retail and leisure businesses, as well as slashing the average pub’s energy bill by £1,000. That is real help—the Minister can have those ideas for free.

The duty increases will also have an impact on the UK’s world-class wine and spirits producers, which together generate £76 billion in economic activity. Across our wine sector, there are more than 1,000 vineyards, including some excellent ones in North West Norfolk, which I recommend. Despite that success, we see the Government putting yet more costs on to the sector; some 60% of the price of a bottle of wine already goes to tax. Instead of listening to calls from the sector to freeze duty, the Chancellor has decided to increase it, and she has failed to fix the small producer relief so that it works for wine makers and distillers.

The picture is no rosier in the spirits sector. The Scotch Whisky Association has said that the increase piles additional pressure on to a sector already suffering from job losses, stalled investment and business closures. It estimates that the lost revenue to the Treasury as a result of the previous rise in spirits duty amounted to about £150 million. The UK Spirits Alliance has called the Budget

“a sad day for the nation’s distillers, pubs and the wider hospitality sector.”

WineGB joins its ranks in pointing out that higher prices will likely lead to lower sales and reduce the Treasury revenue, so the sector could not be clearer. The only people still pretending this is good economics are those on the Government Benches.

When the Government should be backing businesses, they are instead choosing to add to their costs. Increased taxes have consequences—they depress demand and revenue. In October, YouGov found that one in four regular drinkers was likely to reduce their alcohol spend this year due to price increases, and the Wine and Spirit Trade Association has called for the OBR’s forecasting assumptions to be reviewed. The Government are putting themselves and the UK on the wrong side of the Laffer curve, which the hon. Member for Stoke-on-Trent Central (Gareth Snell) should read more about—he will be persuaded. Ministers should take fresh advice on the impact of these changes.

The UK’s brewers, producers and hospitality businesses are resilient. Frankly, in the face of this Government’s onslaught, they need to be. They are at the heart of our communities, creating jobs, driving local growth and giving many young people their first opportunity in work. Now is the time to support the sector, not tax it more, which is why we will be voting against these measures this evening.

[Laurence Turner (Birmingham Northfield) (Lab)]

I draw attention to my chairship of the GMB parliamentary group, a union that represents workers in the distillery and retail trades. I will limit my comments to the uprating of excise duty, but I welcome this Budget more generally. It represents the right choice—investment and renewal over austerity and decline.

Clause 86 of the Finance (No. 2) Bill represents a simple uprating of alcohol duty in accordance with the retail prices index. In that sense, the clause represents continuity with the policy of successive Governments over many years, going back to the early 1970s, and of course the principle of excise duty predates that by many more years. Having noted the shadow Minister’s comments, it is telling that none of the amendments we are considering today would actively reverse that increase. The effects of the escalator is also softened to an extent by the reduction for draught products, which, combined with pre-existing changes to the tax system, amount to a somewhat more favourable regime for the drinks most sold in pubs. This direction of policy is welcome, given everything we know about the attendant health and social harm that can be the result of solo drinking.

It is worth noting that the increase is in line with international best practice. It is timely that just today, the World Health Organisation published a new report titled “Global report on the use of alcohol taxes”. That report says that

“specific excise taxes need to be regularly adjusted for inflation or their real value risks erosion over time.”

It also establishes that the UK’s effective tax take is firmly in line with many other European countries, including Belgium and much of central and eastern Europe, and of course it is significantly lower than in Scandinavia. As such, uprating the duty strikes the right balance between the different objectives of encouraging social activity, supporting the hospitality and manufacturing industries, and not encouraging excessive consumption. It is true that there have been changes in alcohol consumption rates among the general public, changes that have been particularly marked since covid. As the 2024 living costs and food survey found, there has been a notable fall in real-terms alcohol consumption, both in and out of the home, which is why specific measures are needed to support the pub trade.

If I may, I will say a few words about the revaluation 2026 process. I have raised questions about this before, and the Minister has indicated that—as the phrase goes—discussions are ongoing, so in the interests of time I will not repeat my questions today. However, I would like to note two things. First, the Valuation Office Agency has been genuinely independent since the days of the increment value duty, and secondly, valuation 2026 has been coming for a long time. It was the last Government who changed the law to introduce three-year valuation exercises, and as successive annual reports of the VOA make clear, the risk of valuations in individual sectors that are not of sufficient quality was foreseen. A delivery plan was developed before the 2024 general election to mitigate that risk, as the VOA saw it. Presumably the Government of the day did not have concerns about the VOA’s approach, because if they did, they would have raised them on the record.

I will make two further brief points, the first of which is about the tax system’s treatment of different types of alcohol sales. Something needs to be done about the sale of high-strength drinks on our high streets in proximity to betting shops. If you were to go to Northfield high street, Ms Cummins, you would see a succession of small betting shops immediately next to off-licences where very low cost, but very high strength beers and ciders are sold. There is a revolving door between those premises, and it is a major contribution to some of the antisocial problems that we have on our high streets. I hope that future exercises will look at different treatments, whether that is powers for local authorities or changes to the tax system to try to remedy the problem.

Rural Fuel Duty Relief

James Wild Excerpts

Wednesday 7th January 2026 Westminster Hall

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

I congratulate the hon. Member for North Devon (Ian Roome) on securing this debate, and I thank all hon. Members for the contributions that we have heard. It was a Conservative Government that introduced the rural fuel duty relief scheme in 2019, and that was in recognition of the fact that remote communities face higher pump prices due to the high cost of transporting and distributing fuel.

The scheme was subsequently extended again in 2015 to include more areas across England and Scotland, providing a welcome 5p per litre reduction in prices to help families and businesses in those areas, particularly where they might have only one filling station to choose from. The scheme recognised that rural communities, especially isolated ones, face challenges that justify targeted support. As we have heard from hon. Members, it has proved effective and needed.

In the main Chamber, my right hon. Friend the Member for Louth and Horncastle (Victoria Atkins), the shadow Environment Secretary, has been setting out the support that the Conservatives have consistently provided for people in rural Britain; many of my colleagues are speaking in that debate. In government, we demonstrated our commitment to those who live and work in the countryside, including my North West Norfolk constituents.

Our fuel duty record underlined that. As well as the rural fuel duty relief, we froze fuel duty every year from 2011. In March 2022, we went further and introduced a 5p cut to fuel duty across the board. That was not merely about tax policy; it was about recognising that, for rural communities, a car or a van is a lifeline, not a luxury. It connects farmers to markets, helps children get to school, helps people get to work or health appointments and keeps rural enterprises in business. Every penny added to the cost of fuel has a multiplied effect in areas where public transport is limited and journeys are longer.

Our support for rural communities extended far beyond fuel duty to infrastructure and supporting agricultural businesses, recognising their vital contribution to our country and to the social fabric—what a contrast to what we have seen under this Government. The Government say that the cost of living is their priority, but they are adding to the costs for families and businesses. Inflation was at 2% when the Government came in, and they have nearly doubled it. The much-vaunted promise of £300 off energy bills is nowhere to be seen.

In her Budget, the Chancellor announced that Labour would end the 5p fuel duty cut that we introduced. That measure will take effect from September this year, and will see the average family pay £100 a year more. The Road Haulage Association estimates that it will add more than £2,000 a year to the operating costs of a heavy goods vehicle. From April next year, the Government will scrap the 16-year fuel duty freeze that we introduced, and inflation-linked rises will follow. That marks the end of the support offered to motorists through the freeze since 2010, which has saved them £120 billion. That puts in context the modest £5 million or so cost of the rural fuel duty relief.

In November, the Chancellor also announced her pay-per-mile tax on electric vehicles, which is set to cost drivers an extra £255 a year. It is little wonder that the RAC has said that simply keeping vehicles on the road has become a significant financial challenge. The Prime Minister has been boasting about the £3 bus cap—a cap that he increased by 50%. Whether it is fuel duty or public transport, the Government are making things harder and more expensive for rural communities.

Rural communities are not only being punished at the pump. In the debate, we have heard reference to the family farm tax, which breaks up the farms that form the backbone of our rural communities. The modest change that the Minister has announced is welcome as far as it goes, but given the damage that the tax will do, the Conservatives are committed to reversing it entirely.

As well as the increases to fuel duty, business rates will increase, hitting rural pubs and businesses. UKHospitality estimates that an average pub will pay an extra £12,900 over the next three years. The Minister was sent out to defend the farm tax, and he said there would not be changes, but then there were. At Treasury questions, I called on the Chancellor to look again at business rates increases, and the Minister ruled that out then, but we read today that there may be changes. Apparently the Business Secretary has even noticed the damage that the increases will do—presumably not after discussing them in a pub, given that many Labour MPs have been barred. Will the Minister therefore confirm whether the Government are considering making those changes, as the sector and many across the House have called for?

The rural fuel duty relief scheme reflects an approach to governing that recognises the distinct challenges and vital importance of our rural communities. We introduced the scheme and extended it, and throughout our time in government we demonstrated that we understand and support those who live and work in the countryside. Given that it is now more than a decade since the scheme was last expanded, and given its modest cost, I fully support a review of the relief. The Treasury often says that it keeps taxes under review, but this measure deserves a proactive review, and I hope that the Minister will commit to one.

By contrast, this Government’s tax rise after tax rise make life harder for rural businesses and rural people. Against a backdrop of weak growth and rising unemployment, Labour’s approach sadly threatens the fabric of our rural communities. Those rural communities deserve much better.

Conduct of the Chancellor of the Exchequer

James Wild Excerpts

Wednesday 10th December 2025 Commons Chamber

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

This is a rare and serious conduct motion that calls on the Chancellor of the Exchequer to apologise for misleading the country about the state of the public finances, breaking promises on tax and breaching the OBR confidentiality process—in short, for not being straight with the British people.

I was expecting to refer to more contributions this afternoon, but it has been a slightly curtailed debate. [Interruption.] We had the comprehensive introduction from my right hon. Friend the shadow Chancellor. The hon. Members for Harlow (Chris Vince) and for Loughborough (Dr Sandher) were surprised and disappointed that the Chancellor is being held to account not for her personality, but for her conduct. As my right hon. Friend the Member for Beverley and Holderness (Graham Stuart) just said, this debate is about honesty, trust and confidence and what happens as a result, and about the “shenanigans”, as my hon. Friend the Member for West Worcestershire (Dame Harriett Baldwin) put it.

On Times Radio this morning, the shadow Chancellor was asked why this debate matters. It matters because the deliberate briefing and misrepresentation of the Budget has damaged workers, savers, pensioners and investors. Let us start with the simple truth: this Government and the Chancellor spun false narratives about the public finances to justify their political choices to increase welfare spending.

[Peter Swallow (Bracknell) (Lab)]

During the Budget debate, I asked the shadow Chancellor whether he would address the fact that, on multiple occasions, he referred to the public finances in a fantastically negative tone that appeared far from the truth that was revealed at the Budget, suggesting at one point that there was a £40 billion black hole in the public finances. As the shadow Minister says that we were not being straight with the public about the state of the public finances, will he take this opportunity to apologise on behalf of his colleague for doing just that?

[James Wild]

If the hon. Gentleman had been here for the whole debate, he would have had the opportunity of the opening 45-minute speech to put that to my right hon. Friend.

What happened as a result of all the policy kites that were flown? Pensions were drawn down, fewer mortgages were approved and investment was paused. That is not my verdict; the Bank of England warned that the economy was heading for slowdown as a result of the uncertainty, the British Chambers of Commerce said that that uncertainty affected investment and recruitment, and hundreds of thousands of people drew down their pensions. Those are the real impacts of that activity—the shenanigans—and there is genuine anger across the country at the damage such uncertainty caused. The Chancellor must take responsibility because she is responsible for that uncertainty.

People are already cynical about politics, but what could do more to undermine trust than abusing the OBR process to cook up a story to make a case for higher taxes that were not needed? It is the Chancellor who is at the centre of misleading the country. On 4 November, she staged that unprecedented press conference to roll the pitch for tax rises.

[Luke Murphy]

Will the hon. Gentleman give way?

[James Wild]

I will not. In breach of the confidentiality rules, the Chancellor warned that the OBR productivity downgrade meant lower tax receipts. Indeed it did, but the OBR report makes it clear that that downgrade was more than addressed by higher tax receipts. In other words, there was no black hole. The Chancellor had the numbers and she knew the position. Now we know what she said was simply not true. Instead, she crafted a narrative to justify decisions to increase taxes to fund higher welfare spending.

On 13 November, the Financial Times reported that the Chancellor had decided against the much-briefed income tax increases. The next day, after the gilt market had responded badly, journalists were briefed that the tax rises would not happen thanks to an improved fiscal forecast. Yet that is not what the OBR pre-financial measures said. Little wonder the OBR took that extraordinary step of publishing the forecasts, exposing the truth that there was no giant deficit, as briefed to the press.

The OBR said it took that action to address misconceptions about the forecasts. Where might such misconceptions come from? We do not need to be Sherlock Holmes to identify the Treasury as the culprit.

[Luke Murphy]

The OBR told the Treasury Committee, on which I sit, that the narrative that the Chancellor set out on 4 November was consistent with the forecast at that time. When the OBR made that point, was it right or wrong? Are you questioning what the OBR said?

[James Wild]

I am sure that Madam Deputy Speaker is not questioning anyone. I am pointing out that the Chancellor said that there was a big £16 billion downgrade from the productivity—that was all offset—but she did not mention that—[Interruption.] If the Minister wants to intervene to say that she did mention that on 4 November, I will give way. She did not. She did not at all.

Yesterday, when the Chancellor was asked in the House if she had authorised or allowed confidential details of the Budget or forecasts to be briefed to the press, she gave a categorical no. If the Chancellor did not license briefings, can the Minister give a cast-iron commitment that no other Ministers, special advisers or officials in the Treasury or No. 10 briefed or authorised briefings about potential measures or the forecasts? Frankly, if you believe that all of those were unauthorised briefings, the Treasury is utterly out of control and I have a bridge to sell you. There is a leak inquiry, but the permanent secretary said today that it centres on 13 November, not on the tsunami of tall tales on potential Budget measures. Why might that be, I wonder. Nothing less than a full inquiry, with the findings made public, will do.

That brings us to the broken promises referred to in the motion. A year ago, the Chancellor delivered the biggest tax-raising Budget in modern history, hitting the British people with £40 billion of tax rises. Then in this Budget, taxes were increased yet again, by £26 billion, despite the Chancellor promising not to come back for more. Life comes at you fast. A year ago, the Chancellor also said that extending the freeze on income tax thresholds

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

Do Labour Members remember her saying that? I certainly do. She said that she would not freeze the thresholds. Then what did she do? Oh, she froze the thresholds. She imposed a three-year extension, with £23 billion coming out of the pockets of 1.7 million people who will pay higher taxes for her failures. As the motion says, the Chancellor should apologise for breaking her promise not to raise taxes again.

What Chancellors say matters. The public and the markets need to believe them, and to trust that they are not being misled. That is not the case around the events of this Budget. That is why this motion calls on the Chancellor to apologise for the misleading picture she presented of the public finances, for the Treasury briefings that did so much damage to businesses and to people, and for breaking her promise not to increase taxes. Frankly, in the face of such a charge sheet, an apology is the very least that the British public deserve. I commend this motion to the House.

--- Later in debate ---

[Dan Tomlinson]

I agree entirely with my hon. Friend. Too many Conservative Members defended the mini-Budget, which crashed the economy and added thousands of pounds to mortgages. In contrast, since this Government have come to power, the Bank of England has cut interest rates five times, taking £1,200 off a typical two-year fixed rate mortgage. At this Budget, we cut £150 from the average energy bill, froze rail fares and prescription charges, and extended bus fare caps and fuel duty cuts, but the Conservatives do not want to talk about that either. They could have chosen in their Opposition day debate to talk about fiscal stability and increased headroom, but again, they chose not to do that because of the £21.7 billion of headroom that the Chancellor secured at the Budget, which will help protect our country from global shocks and unforeseen challenges.

Of course, the Conservatives do not want to talk about child poverty either because they know that this Budget has lifted 550,000 children out of poverty, whereas the last Government were content to leave them, preferring instead to rebrand the hungry children who they let down while in power as benefit scroungers. They should be treated as our future, not as our opponent.

I have a couple more minutes, so let me address some of the points made during the debate. I thank the Liberal Democrat spokesperson, the hon. Member for St Albans (Daisy Cooper), for engaging on policy. We have had conversations on business rates already this week, and I am sure that we will have more. We have begun the work to rebalance the system with a £900 million switch from the highest value properties to those on the high streets.

I thank my hon. Friend the Member for Harlow (Chris Vince) for his Thatcher quote. It was a good quote that bears repeating. She said,

“I always cheer up immensely…if they attack one personally, it means they have not a single political argument left.”

I thank the hon. Member for West Worcestershire (Dame Harriett Baldwin) for going through every single tax change and saying that she opposes them all. That is the sort of opposition we have got used to. Rather than constructive opposition, which comes forward with proposals that would raise revenue in a fair way, such as the changes on electric vehicle excise duty, which will stop us losing £12 billion of fuel duty revenue in the coming years, we just hear, “No, no, no,” over and over again. I thank my hon. Friend the Member for Loughborough (Dr Sandher). His experience in economics is richly valued in this place, and I enjoyed his speech, as I always do.

Finally, it has been a short debate, has it not, Madam Deputy Speaker? I am glad that the right hon. Member for Beverley and Holderness (Graham Stuart) took the time during the debate to read the Labour manifesto—that was much appreciated—and that he was able to clarify for the House that my right hon. Friend the Chief Secretary was right to say that we have stuck to our manifesto commitment.

[James Wild]

To bring the Minister back to the debate, it is about honesty and the real-world consequences of the briefing that happened around the Budget. Does the Treasury accept that hundreds of thousands of people drew down their pensions, which is an irrevocable decision—yes or no?

[Dan Tomlinson]

What the Treasury does accept is that at this Budget, the Government had to make the decisions to ensure that we could increase our fiscal stability and get borrowing falling in every single year. The previous Government were not able to control our public finances, and yet in every year of this forecast, borrowing will be falling, and we have more than doubled our headroom to £21.7 billion.

Oral Answers to Questions

James Wild Excerpts

Tuesday 9th December 2025 Commons Chamber

[Mr Speaker]

I call the shadow Minister.

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

The Chancellor promised a new golden era of hospitality, but the reality of her business rates raid, as the British Beer and Pub Association has said, is

“sleepless nights, pay cuts and staff layoffs”

for publicans, who will be paying an extra £13,000 on average. Why did the Chancellor tell businesses last week that their taxes were going down when they are going up, and will she think again and change the multipliers?

[Dan Tomlinson]

The multipliers are a product of the change in the valuation, and they did come down. We brought them down even further for retail, hospitality and leisure businesses. Without intervention this year, the bills paid by pubs would have increased by 45% as a result of the increase in value since the pandemic; because of this Government’s significant intervention this year, bills are going up by 4%. That is the impact of the changes this Government have made.

The Customs Tariff (Establishment) (EU Exit) (Amendment) Regulations 2025

James Wild Excerpts

Monday 8th December 2025 General Committees

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

It is a pleasure to serve under your chairmanship, Ms Barker. As the Minister said, this statutory instrument clears up a couple of errors, one of which happened on our watch, as he pointed out—fair cop; we plead guilty to that one. The other part of the instrument corrects a previous error by reinstating the 14% import duty for fruit jellies, marmalades, fruit or nut purée and fruit or nut pastes.

There is no impact assessment for the instrument because, as the explanatory memorandum says, the impact on the private and public sector is expected to be minimal, but I did get the House of Commons Library to do a bit of research for me. According to HMRC’s trade tariff tool, the incorrectly applied 0% tariff on jams, fruit jellies, marmalades, fruit or nut purée and fruit or nut pastes appeared on July 2025, and the UK imported roughly £3.2 million of such products in 2024. I am keen to understand from the Minister how the error occurred. Was it simply human error? What measures are in place to prevent slightly more important tariff codes being incorrectly entered, with the impact that that could have?

Tariffs are taxes, of course, with higher prices passed on to consumers. We have just had a Budget that increased taxes on incomes, savings and employment, and that introduced a new tourist tax and a taxi tax. We now have another one: the marmalade tax. Marmalade makers in Peru will be giving the Minister a Paddington stare after this.

On basmati rice, as the Minister said, this was an error made by the previous Conservative Government. The Library was unable to find any data on the volume imported, so how much does he expect the new £25 a tonne rate—the rate that should have been in place—to raise in the years to come? If he does not have those figures at his fingertips, perhaps he will write to me.

To conclude, higher import tariffs mean higher prices for consumers. There can be good reasons for them, such as ensuring a level playing field for our domestic producers, but it does seem that this Government have yet to come across a tax they do not like—even on marmalade.

Alcohol Duty: UK Wine Sector

James Wild Excerpts

Tuesday 11th November 2025 Westminster Hall

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

It is a pleasure to serve with you in the Chair once again, Mr Turner. I congratulate my hon. Friend the Member for Farnham and Bordon (Gregory Stafford) on securing this important debate. In Blur’s immortal words, he knows his claret from his Beaujolais, but I will not have anyone say he is a charmless man.

It is a pleasure to speak in support of an industry that is doing well in this country, although it is facing some challenges. Wine is a home-grown success story, with more than 1,000 vineyards and nearly 5,000 hectares under vines across the country. In my North West Norfolk constituency, I am fortunate to have wineries including the award-winning Burn Valley and Cobble Hill, which are contributing to the local economy, supporting tourism and creating jobs. Overall, the wine and spirits industry contributed £76 billion in economic activity last year, with nearly half of that coming from the wine sector. Despite this success, the Government are putting more burdens on the sector.

This has been a good debate, and I think my hon. Friend the Member for Weald of Kent (Katie Lam) wins the prize for the number of wineries in her constituency. The hon. Member for Edinburgh South West (Dr Arthur) made some important points about public health. Unfortunately, the hon. Member for Witney (Charlie Maynard) could not resist mentioning Brexit—he seems slightly obsessed.

The domestic sector is largely made up of small producers, with two thirds producing fewer than 10,000 bottles a year. Generally, these are family businesses, local employers and passionate entrepreneurs. Employment in the sector has grown significantly over the past few years, and since 2010 bottle sales have increased to over 9 million.

The UK is a global hub for the trade, being the second largest importer of wine by volume and value. This is a sector that we should be nurturing, not penalising. When we were in government, that is what we did. We introduced the simplified duty system, based on taxing alcohol by strength, with an 18-month easement to help the sector. We encouraged businesses to diversify and move into wine production.

Importantly in the context of this debate, we froze alcohol duty rates in the 2023 autumn statement, and we continued that in the spring Budget of 2024. That is a record of support, but sadly this Government have taken a different path. At last year’s Budget, they raised the headline rate of alcohol duty by inflation. As we have heard, around 60% of the cost of a bottle of wine is now tax, and Wine GB warns that the increases are driving down demand and, in turn, cutting revenue to the Treasury. One in four drinkers say they will buy less alcohol as a result of the price increases.

Let us be clear that producing wine in Britain is not easy. Yields are 30% to 50% lower than in France or Spain, labour costs are higher, the weather is obviously unpredictable, and input prices keep rising. But instead of backing the sector, the Government keep piling on costs. Alcohol duty—up. Business rates—up. National insurance—up. As we have heard, the Wine and Spirit Trade Association has said that revenues from alcohol duty are down £300 million in the first six months of this financial year. If that continues, the Treasury will be bringing in £1 billion less than was forecast by the Office for Budget Responsibility at the spring statement.

The Government are putting the country on the wrong side of the Laffer curve, not just on alcohol taxes but across the board. The Minister is relatively new in post, but has he commissioned advice on the duty’s impact on the sector? Has he taken a fresh look at the data or at the assumptions used by the OBR? If not, will he do so, and do so rapidly? The Opposition are firmly on the side of Britain’s wine producers. It is a vibrant, innovative and home-grown sector that deserves support, not more taxation.

Of course, it is not possible to have this debate without talking about the hospitality sector, as a number of colleagues have. Wine is more than a drink; it is about socialising and shared experiences. The sector clearly depends heavily on pubs, restaurants and hotels to introduce consumers to this great British product.

However, under this Government, hospitality, like so many sectors, is struggling. Nearly 90,000 jobs have been lost since the disastrous Budget a year ago, and today we have seen the unemployment rate hit 5%—it has gone up every month under this Government. That is the result of the Chancellor’s terrible judgment in making it more expensive to employ people. With rising employment costs, the jobs tax, the extended producer responsibility and higher business rates, we see layer upon layer of additional cost, so it is no wonder that UKHospitality has described the Government’s approach as a “hammer blow”.

The wine sector has put forward some suggestions for the Chancellor and Ministers ahead of the Budget. First and foremost, it asks that they reconsider some of the decisions to increase business taxes, and it asks them to consider a freeze on excise duty or a wine tourism relief. As was highlighted by my hon. Friend the Member for Bridgwater (Sir Ashley Fox), and echoed by others, it also asks for the alignment of small producer relief with the realities of the wine industry. Those are all practical ideas that are worthy of consideration, so will the Minister commit to looking seriously and carefully at all of them?

Rather than taxing success, we should be nurturing it. The wine sector is a model of sustainable, rural growth, and it deserves our support. Its ask of the Minister is simple: will the Government work with the sector and listen to it, and will they look at the evidence and commit to easing the burden on our wine producers?

[The Exchequer Secretary to the Treasury (Dan Tomlinson)]

I am glad to be serving under your chairmanship, Mr Turner. I am grateful to the hon. Member for Farnham and Bordon (Gregory Stafford) for securing this important debate, and for speaking so eloquently in support of the UK wine sector. It is fantastic to hear him speak about the sector’s growth, as well as its continuing progress on exports, which is a really good thing. The irony is not lost on me, though, that he said that Treasury Wine Estates has some reservations about the Treasury’s tax policy—I will look into that.

I heartily echo the hon. Gentleman’s praise for the UK wine industry’s significant contribution to our economy, culture and tourism. As he mentioned, the statistics speak for themselves: we are the world’s second largest wine importer, bringing in 1.7 billion bottles in 2024. Sales of both imported and home-grown wine support hundreds of thousands of jobs, particularly in hospitality and retail. In recent years, as many Members have mentioned, more and more people have taken up work in the UK’s domestic wine sector, which is much like a dessert wine—small, but strong.

Industry figures suggest that more than 1,000 vineyards and 200 wineries contribute to our rural economy, with land under vine growing fivefold since 2005. The hon. Member for Weald of Kent (Katie Lam) listed many of the wineries in her patch; one of the challenges of being a Parliamentary Private Secretary, like my hon. Friend the Member for Hastings and Rye (Helena Dollimore), is that they do not always get to speak in these debates. However, I have been reliably informed by note that the two Members have the same number of vineyards in their constituencies—there may have to be a little Kent-based competition.

It is great to see that the number of home-grown products is increasing, with production exceeding 10 million bottles last year, and with sales rising too. This Government are committed to fostering an environment in which the wine industry, like its vines, can thrive and grow.

The hon. Member for Farnham and Bordon, as well as other Opposition Members, made important points about the UK’s alcohol duty system. Before I turn to those points, I will first acknowledge the Government’s wider work to support the wine industry through agricultural grants and export promotion. The Government have committed at least £200 million to the farming innovation programme through to 2030, and we champion domestically produced wines on the international stage. For example, we showcased English sparkling wine at the Osaka expo earlier this year.

As I have mentioned English sparkling wine, it is important that I also mention the contribution of my hon. Friend the Member for Edinburgh South West (Dr Arthur), who talked about Scotland’s growing wine industry and the impact it is having on high streets. He also said that, in designing a sensible tax system, it is important that it takes account of the impact on the health of the population, which I think is reflected in the current system.

Members have spoken about the previous Government’s reform of the alcohol duty system. I am a Labour MP, so it is not lost on me that I am defending an alcohol duty system implemented by Conservative MPs, and that Conservative MPs are opposed to a system implemented by their own Government. We learned in opposition that it is not always wise to oppose the decisions made by our party when it was previously in government. Indeed, I think that one of the reasons we won the last election is because we were able to talk proudly and confidently of the achievements of previous Labour Governments. Anyway, it is up to Opposition Members to choose which aspects of previous Government policy they wish to support, or not.

As others have mentioned, the alcohol duty system is now based on the principle of taxing alcohol by strength, which means that alcohol duty increases with a product’s ABV. Although it is true that some higher-strength wines have faced increases in duty, that has been balanced by reductions in duty for lower-ABV wines, including some British wines. Prior to the reforms, wines with 11% ABV and wines with 14% ABV both paid the same duty per bottle. Now, there is a difference: wines with 11% ABV pay £2.43 in duty and wines with 14% ABV pay £3.10.

I am interested in the point made by the hon. Member for Weald of Kent about the extent to which British wine companies are producing wine with an ABV below 8.5%. I will consider that point. Indeed, I was thinking the same thing when I was reading up on this topic earlier today. However, I know the changes were introduced alongside conversations with industry representatives, and those conversations will continue as the changes bed in.

In recognition of the big changes that were implemented, it is right to assess their impacts after they have had time to take effect. We have said that will take place at least three years after their introduction in 2023. I will take that work forward next year with officials from HMRC, and I would welcome evidence from Members in this Chamber, including representations from the businesses and communities they represent, and of course I will engage with the wine industry.

The hon. Member for Farnham and Bordon said he had three points, but I think he had four in the end, including on the cumulative impact—I will try to address all four. On his third point, yes, we will consider in the round all aspects of the system’s current design. I do not want this review to be one that does not properly interrogate the design of the system, and I also do not want to pre-empt where it will get to, but in my role overseeing that review, I want us to look carefully at the design of the system as a whole. I think the system is sensible and fair, but I also know there are challenges that have been raised by Members today.

On the hon. Member’s big point about cuts or freezes to alcohol duty, it is worth realising that any such cuts or freezes would come at a cost to the Exchequer. The Office for Budget Responsibility produces the costings for any changes to taxation policy.

[James Wild]

They are always wrong.

[Dan Tomlinson]

The hon. Gentleman might think that some of the OBR’s assumptions are wrong. I encourage Members, if they have evidence, facts or figures that they want to put to the OBR on the elasticities—as I believe it is called when a tax rate is changed and has an impact on consumption—to send them in. The Government are confident in the OBR’s independence, but I will always want to ensure that we are putting forward accurate costings. In this instance, I believe that the OBR is in the right place when it comes to the elasticities, but Members should feel free to send in their own representations.

It is worth noting that freezing alcohol duty this year, if inflation was around 4%, would be equivalent to a 3.85% duty cut. Using HMRC’s published ready reckoner, this would cost the Exchequer roughly £440 million a year. It is right, therefore, that any decision on alcohol duty weighs the impact on overall revenues carefully. That is what I am confident that the Chancellor will do when she makes a decision in the Budget in just a few weeks.

I will try to run through some of the points made by Members in this debate. The hon. Members for Bridgwater, for Weald of Kent and for Farnham and Bordon, and the Opposition spokesperson, the hon. Member for North West Norfolk (James Wild), raised the issue of small producer relief for wine. That question was considered in detail as part of the previous Government’s review into alcohol duty, and as I have said, we will look to review it three years after the implementation that took place on 1 August 2023. We want to gather data and really look at the impact of the reforms. If Members want to come forward with proposals for change, then they should do so.

Oral Answers to Questions

James Wild Excerpts

Tuesday 4th November 2025 Commons Chamber

[Mr Speaker]

I call the shadow Minister.

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

This morning the Chancellor failed to take responsibility for her poor choices in a Budget that whacked up taxes, borrowing and spending, and made it clear that she would once again break her promises on tax. The farmers whom I have met have been in tears about the family farm tax, not because they are worried about losing their jobs but because the Chancellor is putting generations of farming at risk. Can the Minister tell the House whether the Chancellor has actually met any farmers, the NFU or other farming organisations to understand the impact of her policy and why she should scrap the family farm tax?

[Dan Tomlinson]

The Government have assessed the impact of this policy. According to the estimates that we issued at the time of last year’s Budget, about 500 farms would pay additional tax as a result of the changes; those numbers were contested by all Opposition Members, but the CenTax report—which the hon. Member has said that he and others are interested in reading—backs them up and confirms the Government’s estimates.

--- Later in debate ---

[Mr Speaker]

I call the shadow Minister.

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

When the Chancellor imposed £40 billion of tax rises, she chose to double business rates for leisure, retail and hospital businesses—and she is going to come back for more. It may be in vain, but perhaps I can offer her a policy suggestion: scrap business rates for 250,000 shops, pubs and restaurants. Rather than hike taxes, will she adopt Conservative policy and control welfare spending so that we can back our small businesses?

[James Murray]

That question barely deserves a response. The business rates relief we inherited from the previous Government when we came into office was due to end entirely in April of this year. It is only because of us that it was extended for a year while we put in place permanently lower multipliers for retail, leisure and hospitality businesses. Those are businesses on high streets right across our country, and that will be announced at the Budget on 26 November.

Oral Answers to Questions

James Wild Excerpts

Tuesday 9th September 2025 Commons Chamber

[Mr Speaker]

I call the shadow Minister.

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

The Government want to drive growth through house building, but even before the departure of the Deputy Prime Minister, they were predicted to miss the 1.5 million new homes target by half a million. How does the Chancellor and her team of tax raisers think a 3,000% hike in the builders tax, adding £28,000 to the cost of building a new home, will help to deliver the new homes that young people need? Rather than consult on it, why will she not rule out this damaging tax rise?

[Rachel Reeves]

I think Opposition Members will recognise that building companies have strongly welcomed the reforms we have made to get the country building, and they are very much against the Conservatives, the Liberal Democrats and others in the House of Lords opposing the Planning and Infrastructure Bill, which could have been given Royal Assent by now without that opposition. Instead of scaremongering about something that is being consulted on, the shadow Minister might want to get on and back the positive things that the Government are doing.

Finally, I pay tribute to the former Deputy Prime Minister, my right hon. Friend the Member for Ashton-under-Lyne (Angela Rayner), for the amazing work she did to get housing on the agenda to build the 1.5 million homes that this country desperately needs, and for being an inspiration for so many people from working-class backgrounds. I applaud her efforts and her work.