The Chancellor made the following announcements on Corporation Tax in his Autumn Budget 2021.

Tax Rates

From 1 April 2023, as announced in the Spring Budget.

Bank Levy

From 1 April 2023

  • Finance Bill 2022 will set the bank Corporation Tax Surcharge to 3% (reduced from 8%) and increase the allowance over which the surcharge applies from £25 million to £100 million.
  • This will set the rate for banks at 28%, a small increase from the current 27% (19% plus the 8% Surcharge).

Corporate residence

  • A consultation 'Corporate Re-domiciliation' has been announced on companies moving their domicile and relocating to the UK.

New taxes

Online sales tax

  • A new consultation to be launched for an online sales tax. No dates have been given for this yet.

Asset Holding Companies (AHCs)

From 1 April 2022

  • A new tax regime for Asset Holding Companies (AHCs) was announced in December 2020 and draft legislation was published in July 2021. The regime will cover the taxation of qualifying AHCs and the treatment of payments, including remittance basis changes.

Creative Relief rates

  • The Museum and Galleries Exhibition Tax Relief (MGETR) was due to end on 31 March 2022 but will now be extended by two years to 31 March 2024.
  • The rates of tax credit relief for Theatre Tax Relief, Orchestra Relief and the MGETR (Cultural Relief Rates) will be increased from 27 October 2021 until 31 March 2024. The increases will vary across the reliefs and tax years.
  • These Cultural Reliefs will also be subject to new legislation in the Finance Bill 2022 to safeguard from abuse.

From 1 April 2022

See Autumn Budget 2021: Creative Industries Reliefs

R&D tax relief

From April 2023

  • Following a consultation, the scope of the Relief is to be expanded to include cloud computing and data costs.
  • Other reforms to refocus support towards innovation in the UK and to target abuse and improve compliance.
  • These changes will be legislated for in Finance Bill 2023.

Diverted Profits Tax

From 27 October 2021

  • Finance Bill 2022 will enable HMRC to implement Mutual Agreement Procedure (MAP) decisions under a tax treaty when considering Diverted Profits Tax (DPT) with effect for all MAP decisions.
  • The legislation will also allow for the intended relief from DPT through amendment of the CT600 to be made whilst the DPT review period is open and prevent HMRC from issuing Corporation Tax closure notices during this period.

Cross Border Group Relief

  • Following the UK's departure from the EU, Finance Bill 2022 will repeal the cross-border group relief provisions in the Corporation Tax Act 2010. Amendments will also be made for losses of EEA resident companies trading through UK Permanent establishments.

Loss relief

Retrospective from 1 January 2019:

  • Amendments will be made in Finance Bill 2022 to allow the loss relief rules to work as intended for those companies adopting IFRS16 for renegotiation of leases.

Insurance, securities & financial transactions

  • The Finance Bill 2022 will allow for the spreading of the transitional impacts of IFRS 17 for insurance companies. A consultation will be published later in 2021.
  • HMRC will receive new powers to make Stamp Duty and Stamp Duty Reserve Tax changes to securitisation and insurance-linked securities arrangements.
  • As announced in July 2021, the Finance Bill 2022 will amend the legislation covering hybrid and other mismatch rules.

Real Estate Investment Trusts (REITs)

From 1 April 2022

  • As announced in July 2021, the Finance Bill 2022 will ease the administrative burden as applying to REITs and make technical changes to ensure that the legislation works as intended. Draft legislation was published in July 2021.

Tonnage Tax reform

  • The Government will introduce legislation in the Finance Bill 2022 to:
    • Reduce the lock-in period from 10 to eight years.
    • Allow HMRC to admit companies into the regime outside of the initial window.
    • Remove the consideration of EU and EEA flags.
  • HMRC will review guidance to reflect the significance of UK flagged vessels, green investment and controls as well as technological and market developments.

Residential Property Developer Tax

From 1 April 2022

Useful guides on this topic

Autumn Budget 2021: At a glance
A summary of key budget announcements together with items published without announcement.

Finance Act 2021: rolling tax planner and tax update
Track previous tax announcements made in the 2021-22 tax year.


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