Tax Matters: Autumn Statement 2023 – tax cuts in the NIC of time?

The Freshfields Podcast

The UK Chancellor of the Exchequer, Jeremy Hunt, has delivered the Autumn Statement 2023.

The Office for Budget Responsibility (OBR) reports that the UK economy has proved to be more resilient to the shocks of the pandemic and energy crisis than anticipated, but with growth forecasts for the next two years reduced and the UK inflation rate expected to be more persistently high, the Chancellor had only modest fiscal firepower at his disposal. That headroom was used to send a political message about the Conservative Party’s priorities, with tax cuts for both businesses and workers announced.

In our latest podcast, London Tax partners Peter Clements and May Smith and London Tax senior associates Josh Critchlow and Chris Gotch discuss some of the business tax measures they found the most noteworthy in the Autumn Statement 2023, including:

• Making full expensing capital allowance rules permanent, giving companies a 100% first-year allowance for capital expenditure on main rate assets;
• Further changes to the research and development (R&D) tax relief regime, including merging the existing R&D expenditure credit and SME R&D tax relief schemes, and expanding the scope of the previously-announced additional relief for loss-making R&D-intensive SMEs;
• Various steps aimed at supporting the energy transition and encouraging oil and gas investment, including introducing an exemption from the Electricity Generator Levy for new projects or extensions, confirmation the Energy Profits Levy will end in 2028 (or earlier if energy prices fall below levels set by the Energy Security Investment Mechanism), and bringing forward new measures to incentivise carbon capture, utilisation and storage;
• Reductions to various classes of NICs, benefitting both employed and self-employed workers;
• Announcements relating to the UK’s implementation of the OECD’s global minimum tax reforms, including that the Under-Taxed Profits Rule (UTPR) will apply from January 2025 and the Offshore Receipts in respect of Intangible Property (ORIP) rules will be abolished from that date; and
• On stamp duty/SDRT, the expansion of the growth market exemption, and an update on the government’s proposal to legislate to ensure the higher rate charge on the issue and certain transfers of UK shares and securities into clearance services or depositary receipt systems is not reintroduced from January 2024.