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UK Autumn Budget and Spending Review 2021 Delivered — Orbitax Tax News & Alerts

The UK Autumn Budget and Spending Review 2021 was delivered by Chancellor of the Exchequer Rishi Sunak on 27 October 2021, including several tax-related measures. Some key points include:

  • The Universal Credit (UC) taper for individuals will be reduced from 63% to 55%, and the work allowances in UC will be increased by GBP 500 a year;
  • The rates of income tax applicable to dividend income will be increased by 1.25% for individuals as announced earlier, including a dividend upper rate of 33.75% and a dividend additional rate of 39.35%, which will apply from 6 April 2022;
  • R&D tax reliefs will be reformed to support modern research methods by expanding qualifying expenditure to include data and cloud costs with effect from April 2023;
  • The temporary GBP 1 million level of the Annual Investment Allowance will be extended to 31 March 2023;
  • The Cross-Border Group Relief (CBGR) for losses in the EEA and other related loss relief will be abolished effective from 27 October 2021;
  • The Museums and Galleries Exhibition Tax Relief (MGETR) will be extended for a further two years until 31 March 2024;
  • The Theatre Tax Relief (TTR), Orchestra Tax Relief (OTR), and MGETR will be increased as follows:
    • from 27 October 2021, the headline rates of relief for the TTR and the MGETR will temporarily increase from 20% (for non-touring productions) and 25% (for touring productions) to 45% and 50%;
    • from 1 April 2023, the rates will be reduced to 30% and 35%, respectively, and will return to 20% and 25% on 1 April 2024 (for MGETR, the relief will expire on 1 April 2024 and no expenditure from this date will be eligible for relief); and
    • from 27 October 2021, OTR rates will temporarily increase from 25% to 50%, reducing to 35% from 1 April 2023 and returning to 25% on 1 April 2024;
  • From 1 April 2022, production companies will be able to switch between claiming Film Tax Relief (FTR) or High-End TV Tax Relief (HETR) during production, ensuring that relief is not lost should a company decide to change their distribution method;
  • Several business rates measures are provided, including:
    • a new temporary business rates relief will be introduced for eligible retail, hospitality, and leisure properties for 2022-23 that includes 50% relief, up to a GBP 110,000 per business cap
    • a new 100% improvement relief for business rates will be introduced from 2023, providing 12 months relief from higher business rates where eligible improvements to an existing property increase the rateable value;
    • targeted business rate exemptions will be introduced from 1 April 2023 until 31 March 2025 for eligible plant and machinery used in onsite renewable energy generation and storage;
  • The new Residential Property Developer Tax (RPDT) will be introduced from April 2022 on the profits that companies and corporate groups derive from UK residential property development, with the tax charged at a rate of 4% on profits exceeding an annual allowance of GBP 25 million.;
  • A package of measures to reform the UK's Tonnage Tax regime will be introduced from April 2022, which will:
    • remove any requirement for ships in the UK Tonnage Tax regime to fly the flag of any EU country now that the UK has left the EU, with focus instead given to boosting the use of the UK flag when determining which companies can participate in the regime;
    • make it easier for shipping companies to participate in the Tonnage Tax regime by reducing the lock-in period from 10 years to 8 years to align more closely with shipping cycles; and
    • raise from 10% to 15% the permitted limit for qualifying secondary (ancillary, passenger-related) income in HMRC practice guidance;
  • The bank corporation tax surcharge will be reduced from 8% to 3% from April 2023, resulting in a total rate of 28% considering the increase in the standard corporation tax rate to 25%; and
  • Income tax basis periods will be reformed so businesses' profit or loss for a tax year will be the profit or loss arising in the tax year itself, regardless of its accounting date from 6 April 2024, with a transition to the new rules in 2023-24.

As part of the Autumn Budget and Spending Review, several consultations are also noted. One of the main consultations concerns new rules for corporate re-domiciliation in the UK, which the government intends to introduce in order to make it easier for companies to relocate to the UK. The government will also continue consultations on a UK-wide Online Sales Tax (OST) that would be used to reduce business rates for retailers in the UK.