2023年度英國(guó)秋季財(cái)政預(yù)算案（英）-德勤

22November

2023AutumnStatement2023ContentsIntroduction123456BusinesstaxR&D

andotherinvestment

incentivesIndustryspecificmeasuresEmployment

taxesand

NationalInsuranceOthertax

measures1.

IntroductionThe

Chancellor

of

the

Exchequer,

Jeremy

Hunt,

today

delivered

the

UK’s

2023

Autumn

Statement.Against

a

backdrop

of

falling

inflation

and

below-forecast

borrowing

figures,

the

Chancellor

soughtto

encourage

business

investment

through

a

package

of

targeted

tax

cuts

and

investment

incentives,while

focussingbroader

measuresonindividualsand

the

self-employed.Business

tax

developments

include

permanent

‘full

expensing’

for

capital

investment

and

theabolition

of

rules

relatingtothe

taxationof‘OffshoreReceiptsin

respect

of

IntangibleProperty’.Headline

grabbing

reforms

of

the

UK’s

National

Insurance

Contribution

regime

will

largely

impact

theself-employed

and

individuals,

but

UK

employers

will

be

required

to

administer

a

reduction

in

themain

NIC

rateforemployees

from

12%to

10%

witheffect

from

6

January2024.In

relation

to

the

introduction

of

Pillar

2

legislation,the

Government

intends

to

apply

the

UndertaxedProfit

Rule

from

2025,but

will“continueto

monitor”internationalimplementation.This

bulletin

sets

out

the

key

tax

measures

for

non-UK

owned

corporate

groups.

For

detailedcoverageandcomment

onthe

AutumnStatement2023,visit

Deloitte

UK’s

dedicatedwebsitehere.2.

Businesstax2.1Full

expensingofcapital

expenditureIn

Spring

Budget2023,

the

Government

introduced

‘full

expensing’

for

qualifying

capital

expenditureincurred

between1

April

2023

and

1

April2026.TheGovernment

hasnow

announced,asexpected,that

fullexpensingwillbe

madepermanent.1Underthefull

expensing

rules,companies

can

claim

100%first-year

capitalallowances

for

qualifyingplant

and

machinery

expenditure,

and

a

50%

first-year

allowance

for

qualifying

special

rate

assets.Cars,

assets

forleasingand

second-hand

assets

continue

to

beineligibleforthis

relief.However,theGovernment

is

exploring

the

case

for

expanding

the

scope

of

full

expensing

to

include

assets

forleasingandwillpublisha

technicalconsultationinduecourse.While

this

announcement

was

widely

anticipated,

it

remains

welcome

news

for

companies

andshould

providegreatercertaintyinplanninglong-term

investments,

forexamplein

decarbonisationtechnology

or

in

newer,

greener

plant

and

machinery.

The

Chancellor

described

this

change

as

the“biggest

business

tax

cut

in

modern

British

history”

and

the

Government

forecasts

that

the

newpermanent

measurewillbenefit

taxpayers

by

an

average

of

￡10bn

peryear.The

Government

also

announced

that

it

will

launch

a

technical

consultation

on

wider

changes

tosimplify

the

UK’s

capitalallowances

legislation

in

due

course.2.2Repeal

ofUKORIPrulesThe

Government

has

announced

that

it

will

repeal

the

Offshore

Receipts

in

respect

of

IntangibleProperty(ORIP)rules

in

respect

of

incomearisingfrom31

December

2024.The

ORIP

rules

were

implemented

in

2019

to

discourage

multinational

groups

from

placing

intangibleproperty

in

low

tax

jurisdictionswhereincome

issubject

to

nooralowrate

oftax.The

repeal

of

the

ORIP

rules

will

coincide

with

the

introduction

of

the

Pillar

2

Undertaxed

Profits

Rule,which

the

Government

considers

to

more

comprehensively

discourage

the

behaviours

that

ORIPsought

to

counteract.Whilst

any

income

which

was

subject

to

ORIP

will

now

potentially

be

subject

to

the

UndertaxedProfitsRule,

therepealisa

welcomesimplification

ofthe

UK

tax

regime.2.3Pillar

TwoThe

Government

intends

to

introduce

the

Undertaxed

Profits

Rule,

which

forms

part

of

the

G20-OECD

global

minimum

tax

framework

on

Pillar

2,

in

an

upcoming

Finance

Bill,

to

take

effect

foraccountingperiodsbeginning

onor

after31

December2024.The

Government

noted

inthe

documentspublished

immediately

after

the

Chancellor’sspeech

that“it

is

important

that

the

UK

implements

Pillar2

toa

similartimelineas

other

countries”and

that

the“Government

willcontinue

to

monitorinternationaldevelopments

onimplementation”.The

Government

will

also

make

technical

amendments

to

the

Multinationaltop-up

tax

and

Domestictop-up

tax

legislation

through

the

Autumn

Finance

Bill

2023.

The

Multinational

top-up

tax

andDomestic

top-up

tax

were

introduced

in

the

Finance

(No.2)

Act

2023.

The

proposed

changes

arecomprised

of

amendmentsidentified

from

stakeholder

consultation

and

those

necessary

toensurethat

UK

legislation

remains

consistent

with

administrative

guidance

to

the

Pillar

2

model

rules

agreedby

the

UKand

othermembersof

theOECD

InclusiveFramework.23.

R&Dandotherinvestmentincentives3.1Merger

ofR&DtaxreliefsThe

Government

has

confirmed

thatitwillproceed

withmerging

thetwo

UKR&Dregimes,

the

SMEand

the

Research

and

Development

Expenditure

Credit

(RDEC)

schemes,

into

one

consolidatedscheme.

The

merging

of

the

twoschemeswas

expected,

following

earlier

announcements

includedinSpring

Budget

2023.Under

the

merged

scheme,

all

claimantswill

nowreceive

reliefviaanabove-the-line,

taxablecreditat

the

current

RDEC

rate

of

20%.

Loss-making

companies

will

suffer

a

lower

notional

tax

charge

of19%,

delivering

a

net

benefit

of

16.2%

on

qualifying

spend,

slightly

higher

than

the

15%

effectivereliefavailable

totax-payingclaimants.Further

announcements

relate

to

the

ability

to

claim

RDEC

for

contracted-out

R&D,

subsidisedexpenditure

and

externally

provided

workers

(EPW).

It

hasbeen

clarified

that

payment

of

an

RDECcredit

must

be

madetotheclaimantcompany

goingforward,

and

that

no

new

assignmentsof

RDECcreditsto

nomineecompanieswillbe

possible.Themerged

scheme

will

be

included

in

the

Autumn

Finance

Bill

2023

and

will

apply

for

accountingperiodsbeginning

on

or

after

1

April

2024.

Thisisa

slight

change

from

earlier

plans,

which

wereforthe

mergedschemeto

apply

forexpenditure

incurredafter

1

April2024.

This

changeshould

removesome

complexity,

ascompanieswill

not

be

required

tosplit

an

accounting

period

intotwonotionalperiods

toapplythe

merged

and

unmergedschemes.Overall,

while

the

Government

has

sought

to

simplify

the

R&D

tax

reliefs

through

the

implementationof

a

merged

scheme,

claimants

will

still

need

to

manage

complex

nuances.

While

large,

profitablebusinesses

may

not

materially

benefit

from

these

changes,

loss-making

companies

and

SMEs

may

doso.3.2Additional

tax

relieffor

R&Dintensive

loss-makingSMEsNotwithstanding

that

the

Government

will

introduce

a

merged

scheme,

some

rules

will

remainspecifically

relevant

to

SME

claimants.

For

example,

loss-making

SMEs

whichmeetthe

threshold

tobe

considered

a

‘research

and

development

intensive

business’

(RDIB)

will

be

able

to

claim

therepayable

tax

credit

at

a

higher

rateof14.5%,

equivalent

to

up

to

27p

in

the

pound.

The

Governmenttoday

announced

a

change

tothe‘R&Dintensityratio’,which

iscalculated

based

on

qualifyingR&Dexpenditureas

a

percentageof

total

expenditure.

Businesses

with

an

‘R&D

intensityratio’ofat

least30%

(previously

40%)willbeeligiblefor

the

additionalrelief.A

grace

period

will

applyto

provide

more

certainty

for

companies

whofall

under

the

RDIB

threshold,allowingthem

to

maintain

theirstatusfor

two

consecutiveperiods.For

RDIBs,

a

claim

for

qualifying

expenditure

incurred

from

1

April

2023

can

be

made

once

theAutumn

Finance

Bill

2023

has

received

Royal

Assent.

The

reduction

in

the

R&D

intensity

ratio

andthe

grace

period

willcomeinto

effect

foraccountingperiodsbeginning

onorafter1

April

2024.3.3InvestmentZones

andFreeportsThe

Government

has

announced

plans

to

extend

the

Investment

Zones

programme

originallyannounced

at

the

Spring

Budget

2023,

from

five

to

ten

years.

The

measures

will

therefore

extend

thebenefits

available

in

English

Freeports

up

to

30

September2031,andwill

doublethe

fundingand

tax3reliefs

available

in

each

Investment

Zone

from

￡80

million

to

￡160

million

over

the

duration

of

theprogramme.

The

Government

hopes

that

by

extending

the

duration

of

the

programme,

they

willprovidegreatercertainty

to

investors.Fournew

Investment

Zones

were

announced

in

England,

in

Greater

Manchester,the

West

Midlands,the

East

Midlands,and

Wrexham.Investment

Zones

across

the

UK

were

first

introduced

with

the

goal

of

supporting

high-growth,strategic

industries

in

areas

in

need

of

levelling-up

to

increase

productivity

and

growth.

Theincentivesin

each

Zone

include

enhanced

ratesof

Structures

and

BuildingsAllowances;

Stamp

DutyLand

Tax

relief;

Business

Rates

relief;

and

Employer

National

Insurance

Contributions

relief,

alongsideflexiblegrantfunding.The

Government

also

announced

that

it

was

extending

the

duration

of

the

tax

reliefs

available

inFreeports

from

five

to

ten

years

to

maximise

the

programme’s

impact,

and

is

creating

a

new

￡150million

Investment

Opportunity

Fund,

which

will

be

available

over

five

years

to

ensure

thatInvestment

Zones

and

Freeports

can

respond

nimblyasinvestmentopportunitiesarise.4.

Industryspecificmeasures4.1CreativeIndustries

andAudio-Visual

tax

reliefIn

Spring

Budget

2023,

the

Government

announced

a

new

Audio-Visual

Expenditure

Credit,

whichwilloffera

34%

refundable

tax

credit

for

filmandhigh-endTVproduction.

This

replaces

a

numberofpreviously

separate

reliefs.The

Governmentannouncedat

Autumn

Statement

that

it

will

seek

to

further

boostthe

internationalcompetitiveness

of

tax

incentives

by

consulting

with

stakeholders

with

a

view

to

increasing

thegenerosity

of

thisschemeforvisual

effectsexpenditure

from

April

2025.As

previously

announced,

uplifted

relief

for

animated

TV

production

will

be

extended

to

includeanimated

feature

films,

which

will

benefit

from

a

5%

uplift

(up

to

39%)

in

relief

under

the

Audio-VisualExpenditureCredit,

alongwithchildren’s

TV.Separately,

as

announced,

the

Video

Games

Tax

Relief

will

be

replaced

by

the

Video

GamesExpenditure

Credit,also

at

a

rateof34%.The

new

reliefs

will

be

available

to

claim

from

1

January

2024,and

the

Government

intends

that

theywillconstituteQualifiedRefundableTax

Creditsfor

thepurposesofPillar

2

legislation.4.2Investmentfor

other

sectorsThe

Government

continueda

recent

trendofannouncingtargeted

measures

designedto

incentiviseinvestment

in

specific

industries

and

sectors

that

are

considered

to

be

important

to

the

futuresuccessofthe

UKeconomy.At

AutumnStatement,this

includedfundingof

￡4.5bn

to

help

unlockprivateinvestment

in

strategicmanufacturing

sectors,

over

a

five-year

period

starting

in

2025-26,

including

the

UK’s

space

sector,life

sciences,

green

industries,

and

aerospace,

with

an

additional￡500

million

in

funding

for

‘computefor

AI’overthe

next

two

financial

years.45.

EmploymenttaxesandNational

Insurance5.1Changes

toClass

1

employee

NICsThe

Government

has

announcedthat

it

will

cutthe

main

rate

of

Class

1

employee

National

InsuranceContributions

(NICs)

from

12%

to

10%.

Thiswill

provide

a

tax

cutfor

27

million

employeeswiththeaverage

worker

on

￡35,400

receiving

a

tax

cut

in

2024-25

of

￡450.

Following

the

change,

thecombined

rateofUKincome

tax

and

NICsfor

an

employeepayingthe

basicrateoftax

isnow30%

–the

lowest

sincethe

1980s.The

changewilltakeeffectfrom

6

January2024,giving

employers

and

their

payroll

providers

limitedtime

to

administerthechangespart-way

throughtheUK

incometax

year.5.2Reform

ofself-employedNICsIn

an

announcement

which

will

grab

the

headlines

for

the

self-employed,

the

Governmentannounced

that

Class

2

NICs

for

the

self-employed

will

be

abolished

from

6

April

2024.

This

changeis

another

example

of

the

Government

seeking

to

simplify

areas

of

the

UK

tax

system

in

theannouncements.The

Government

will

setout

next

stepsonhowto

implement

this

Class2

reform

inthe

newyear.Themainrate

of

Class

4

self-employed

NICs

will

also

be

reduced

from

9%

to

8%

from

6

April

2024.This

is

expected

tobenefitaround

2

million

UK

individuals.5.3IR35Followingconsultation,the

Government

hasannounced

that

businesses

that

are

subjectto

the

IR35rules

as

a

‘deemed

employer’

will

be

permitted

to

off-set

certain

taxes

paid

in

relation

to

thearrangement

from

anyPAYEobligationsowedin

respect

of

a

deemedemployerliability.Off-set

will

not

be

available

in

relation

to

employer

NICs

paid

by

any

personal

service

companies(PSCs)onsalarypaid

to

theworker,or

for

incometax

or

NIC

paid

by

anyotheremployees,

directors,or

shareholdersof

thePSC.Thechangeswill

providewelcome

relief

toany

public

sector

ormedium/large

privateorganisationswithoff-payrollworkers

whoarefound

to

havebeenincorrectlydetermined

as

self-employed.Legislation

will

be

enacted

in

Autumn

Finance

Bill

2023

to

takeeffect

from

6

April

2024,

and

will

applyto

deemed

direct

payments

made

from6

April

2017,

where

settlement

has

not

already

been

reached.6.

Othertaxmeasures6.1BusinessratesThe

Government

has

announced

further

business

rate

benefits

to

both

small

businesses

and

thoseintheretail,hospitality,and

leisureindustries.Specifically,

theGovernment

announced

that

the

small

business

multiplierinEngland

will

be

frozenfor

a

fourth

consecutive

year

at

49.9p.

Larger

businesses

will

not

benefit

from

this

announcement,asthe

standardmultiplierforlargerbusiness

willbe

upratedin

linewith

inflationto54.6p.5The

current

75%

relief

available

for

eligible

Retail,

Hospitality

and

Leisure

(RHL)

properties

will

beextended

for

tax

year

2024-25.

RHL

properties

inEngland

will

be

eligible

toreceive

support

up

to

acash

cap

of￡110,000

per

business.6.2Promoters

oftax

avoidanceschemesThe

Government

is

legislating

to

introduce

tougher

consequences

for

promoters

of

tax

avoidanceschemes.The

measureswillincludea

new

criminal

offencefor

promoters

who

continueto

promotetax

avoidance

after

having

received

a

notice

tostop,

as

well

as

a

new

power

that

will

enable

HMRCtoapply

to

the

court

to

disqualifydirectorsofcompanies

involvedin

promotingtax

avoidance.6AuthorsReading–

ChristieBuckTel:

+44118

322

2525Reading–

Andrew

SurrellTel:

+44118

322

2021Reading–

Jonny

TathamTel:

+44118

322

2951Email:cbuck@deloitte.co.ukEmail:asurrell@deloitte.co.ukEmail:jptatham@deloitte.co.ukContactsTax

Policy

–

AmandaTickelTel:

+4420

7303

3812London–

Sarah

HeseltonTel:

+441727

88

5833Manchester

–

Stephen

NuttallTel:

+44161

455

8573Email:ajtickel@deloitte.co.ukEmail:sheselton@deloitte.co.ukEmail:

stephennuttall@deloitte.co.ukLondon–

GeoffBrandLondon–

Simon

CooperTel:

+4420

7007

0982Gatwick

–

Tim

MatthewsTel:

+441293

76

1298Tel:

+4420

7007

2251Email:geoffreybrand@deloitte.co.ukEmail:

sjcooper@deloitte.co.ukEmail:timatthews@deloitte.co.ukLondon–

Zubin