2023年度英国秋季财政预算案（英）-德勤-7页_203kb

UK Autumn Statement 2023 Summary

1. Introduction

• Chancellor: Jeremy Hunt delivered the 2023 Autumn Statement
• Context: Falling inflation, below-forecast borrowing, and focus on encouraging business investment; broader measures for individuals and self-employed.
• Key Points:
  • Permanent 'full expensing' for capital investment.
  • Abolition of Offshore Receipts in respect of Intangible Property (ORIP) rules.
  • Changes to National Insurance Contributions (NICs): Employee NIC rate reduced from 12% to 10% (from Jan 2024); self-employed Class 2 NICs abolished (from Apr 2024), Class 4 reduced from 9% to 8%.
  • Implementation of Pillar 2 Undertaxed Profits Rule from 2025.

2. Business Tax

2.1 Full Expensing

• Effective: Permanent measure for qualifying capital expenditure incurred between Apr 2023 and Apr 2026.
• Details: 100% first-year allowance for plant and machinery; 50% first-year allowance for special rate assets.
• Note: Expansion planned to cover leasing.assets; consultation to follow.
• Benefit: Average taxpayer savings estimated at £10bn/year.

2.2 Repeal of ORIP Rules

• Effective: Income from Dec 31, 2024.
• Purpose: Abolishes rules targeting low-tax jurisdictions. Pillar 2 replaces this function.

2.3 Pillar Two

• Implementation: Undertaxed Profits Rule to apply from accounting periods beginning after Dec 31, 2024.
• Monitoring: UK Government will continue monitoring international implementation.
• Amendments: Technical updates to Multinational and Domestic top-up taxes via Autumn Finance Bill 2023.

3. R&D and Other Investment Incentives

3.1 Merged R&D Tax Regimes

• Effective: Apr 2024.
• Changes: Consolidated scheme replaces SME and RDEC regimes.
• Relief: 20% above-the-line credit for all claimants; loss-making companies receive 19% notional tax charge (net 16.2% relief on spend).
• Target: SMEs and R&D-intensive loss-making businesses.

3.2 Additional R&D Relief for SMEs

• Details: Loss-making SMEs with R&D intensity >= 30% receive higher tax credit (14.5%).
• Timeline: Effective from Apr 2024; grace period provides two-year transition for qualifying companies.

3.3 Investment Zones and Freeports

• Expansion: Investment Zones program extended from 5 to 10 years; Freeports tax relief now for 10 years.
• Funding: Each Zone capped at £160m funding vs. previous £80m.
• Eligibility: 4 new zones in England announced.
• Incentives: Enhanced allowances, Stamp Duty relief, Business Rates relief, NIC relief, and grants.

4. Industry Specific Measures

4.1 Creative & Media Sectors

• Audio-Visual Expenditure Credit: 34% tax credit for films/TV; potential extension to visual effects (Apr 2025 consultation).
• Animation & Children's TV: Extended uplift.
• Video Games: Replaced with Video Games Expenditure Credit (34%).

4.2 Strategic Sectors

• Funding: £4.5bn for strategic manufacturing, life sciences, green industries, space, and aerospace over 2025-2026; additional £500m/year for AI compute.

5. Employment Taxes and National Insurance

5.1 Employee NICs Reduction

• Change: Main employee NIC rate from 12% to 10% (effective Jan 2024).
• Benefit: 27m employees affected; average tax cut £450 in 2024-25.

5.2 Self-Employed NICs Simplification

• Abolition: Class 2 NICs ending Apr 2024.
• Reduction: Class 4 NIC rate from 9% to 8% (effective Apr 2024), affecting ~2m people.

5.3 IR35 Offsets

• Change: Public sector/medium/Large orgs can recover taxes withheld for off-payroll workers found incorrectly self-employed.
• Effective: From Apr 2024, for direct payments not settled by Apr 2017.

6. Other Tax Measures

6.1 Business Rates

• Small Businesses: Multiplier frozen at 49.9p.
• Retail/Hospitality/Leisure: Relief extended; capped at £110k support per eligible RHL property.

6.2 Tax Avoidance Penalties

• Enforcement: New criminal offence for promoters ignoring notices to stop promoting avoidance; directors' disqualification possible via court.