Individual Savings Accounts (ISAs)
Although some proposals remain subject to finalisation, the Chancellor announced that the tax advantages of ISAs are to become permanent.
Proposals also include:
UK Real Estate Investment Trusts (UK-REITs)
The Government has announced changes to the proposed UK-REIT scheme, which is due to come into effect in January 2007.
UK-REITs will operate as stock exchange-quoted companies which directly own property, providing an easier and lower-cost way for people to invest in real estate.
UK-REITs are free of corporation tax.
The measures announced in the Pre-Budget Report will make changes to the UK-REIT regime that exempt income from, and gains made on, property from tax, provided the company or group meets certain conditions. The conditions to be met when giving notice and on joining the regime will be relaxed, to make it easier for newly-established companies to become UK-REITs.
More details about the changes are available here: http://www.hmrc.gov.uk/pbr2006/pbrn3.pdf
Registered pension schemes which hold “taxable property” (which includes residential property) are, in certain circumstances, subject to a tax charge of up to 70% on the value of that property, under provisions introduced in Finance Act 2006 to discourage the use of tax-relieved pension funds for investing in residential property or other tangible assets primarily for the personal use of scheme members. This charge may apply where the pension scheme is “investment-regulated” and where the property is held directly or indirectly through an interest in some other vehicle.
Investment-regulated pension schemes that, from 1 January 2007, invest in UK-REITS are not subject to this tax charge unless the investment is made to enable a member of the pension scheme or a connected person to occupy or use taxable property.
The tax charge will also apply if the holding in the UK-REIT by the pension scheme and associated persons is 10% or more.
The European Commission has now given final state aid clearance for the cultural test, which acts as the gateway to the new film tax relief. To ensure continuity in film tax relief during the transition to the new system, the Government has announced it will extend Section 42 relief for films until 31 December 2006. The new film tax relief will commence from 1 January 2007.
Proposals were announced to introduce a range of technical improvements designed to ensure that:
These will include measures relating to transitional protection from the lifetime allowance charge, ill-health pensions, special situation lump sums, unsecured pension funds and the establishment of schemes. Operative dates will depend on the particular measure involved.
HM Revenue & Customs (HMRC) will consult on the way in which the rules around the Lifetime Allowance operate for pension increases and for the dependants’ scheme pension. They will discuss concerns raised by the pensions industry over the administration involved in the checks they are required to make when paying trivial commutation lump sums. These are paid as wholly or partly taxed lump sums in respect of small pension funds that it would be disproportionately expensive to turn into pensions income. They will also discuss with interested parties concerns raised over the tax charge and the administrative burden involved in the non-cash benefits that former employers provide to pensioners.
More details are here: http://www.hmrc.gov.uk/pbr2006/pbrn14.pdf
The Government has become aware that, as a result of the flexibilities that the new pensions tax regime has brought in, life insurance policies that provide lump sum death benefits alone are being offered as personal pension arrangements eligible for pensions tax relief. The Government will therefore work with the pensions industry to explore in time for the Budget, how its principles can be applied to pensions term assurance contracts. Any changes the Government decides to make will not affect either personal arrangements entered into before 6 December 2006 or existing types of employer arrangements.