House of Commons – June 10, 2026 – b.397.0.3

I beg to move, That the clause be read a Second time.

Clause text:

New Clause 48 - Tax consequences of transfer schemes “(1) The Treasury may by regulations make provision for varying the way in which a relevant tax has effect in relation to— (a) anything transferred under a scheme made under section 86, 87, 88 or 90, or (b) anything done for the purposes of, or in relation to, such a transfer. (2) The provision that may be made under subsection (1)(a) includes, in particular, provision for— (a) a tax provision not to apply, or to apply with modifications, in relation to anything transferred;

(b) anything transferred to be treated in a specified way for the purposes of a tax provision;

(c) the Secretary of State, the Welsh Ministers or the Scottish Ministers to be required or permitted, with the consent of the Treasury, to determine, or to specify the method for determining, anything which needs to be determined for the purposes of any tax provision so far as relating to anything transferred. (3) The provision that may be made under subsection (1)(b) includes, in particular, provision for— (a) a tax provision not to apply, or to apply with modifications, in relation to anything done for the purposes of or in relation to the transfer;

(b) anything done for the purposes of, or in relation to, the transfer to have or not to have a specified consequence or to be treated in a specified way;

(c) the Secretary of State, the Welsh Ministers or the Scottish Ministers to be required or permitted, with the consent of the Treasury, to determine, or to specify the method for determining, anything which needs to be determined for the purposes of any tax provision so far as relating to anything done for the purposes of, or in relation to, the transfer. (4) In this section— ‘relevant tax’ means income tax, corporation tax, capital gains tax, value added tax, stamp duty, stamp duty reserve tax or stamp duty land tax;

‘tax provision’ means provision about a relevant tax made by or under an Act. (5) References in this section to things transferred under a scheme include references to— (a) the creation of interests, rights or liabilities under the scheme, and (b) the modification of interests, rights or liabilities under the scheme, and ‘transferred’ is to be read accordingly.”—(Keir Mather.)