Looking ahead


The Chancellor has announced various consultations and publications on possible future changes. These included:

NICs Employment Allowance draft regulations

Following the announcement in the Autumn Budget of reform of the national insurance contributions (NICs) Employment Allowance to restrict it to businesses with an employer NICs bill below £100,000, the government will invite technical comments on the draft regulations.

CGT private residence relief

In the Autumn Budget it was announced that from April 2020 the government will make two changes to private residence relief. The final period exemption will be reduced from 18 months to nine months, and lettings relief will be reformed so that it only applies in circumstances where the owner of the property is in ‘shared occupancy’ with a tenant. In the Spring Statement the Chancellor announced a consultation on these changes.

Anti-avoidance: R&D tax relief

The government will publish a consultation on the measure announced at the Autumn Budget aimed at preventing abuse of the R&D tax relief for SMEs, focusing on the application of the measure to minimise any impact on genuine businesses.

Insurance Premium Tax (IPT)

There will be a call for evidence on where improvements can be made to ensure that IPT operates fairly and efficiently.

Child Trust Funds (CTFs)

The government will publish draft regulations to ensure that CTF accounts can retain their tax-free status after maturity.

Off-payroll working in the private sector

The changes to the off-payroll rules (commonly known as IR35) that came into effect in April 2017 for the public sector will be extended to the private sector from April 2020. A consultation paper has now been issued on the proposed operation of the rules. The consultation is intended to provide businesses and off-payroll workers with greater certainty around how the off-payroll working rules will operate and help businesses make the correct determination of a worker’s status.

VAT fraud in labour provision in the construction sector

The government will pursue legislation to shift responsibility for paying VAT along the supply chain with the introduction of a domestic VAT reverse charge for supplies of construction services with effect from 1 October 2019. Draft legislation and guidance has been issued.

Aggregates Levy review

A discussion paper has been published launching a review of the Aggregates Levy, including the Terms of Reference, information on timing and scope of the review as well as membership of an expert working group.

Clean growth

The Chancellor announced a range of initiatives aimed at tackling climate change and delivering ‘clean growth’. These included: a call for evidence on a business energy efficiency scheme; mandating net gains for biodiversity on new developments in England to deliver an overall increase in biodiversity; increasing the proportion of green gas in the grid; and introducing a Future Homes Standard by 2025, so that new build homes are future-proofed with low carbon heating and greater energy efficiency.

Tax simplification

Following on from the recommendations of the Office of Tax Simplification, the government will publish a call for evidence on potential simplification and improvement of the VAT Partial Exemption regime and the Capital Goods Scheme.

Enterprise Investment Scheme (EIS)

Draft guidelines stating HMRC’s proposed policy and practice for approving funds will be published in the coming months.

International Research and Innovation Strategy

The government will publish a strategy setting out its stated ambition to ‘ensure the UK retains its place as a global partner of choice for science and innovation collaboration’. An independent review has been launched to assess and make recommendations on future frameworks for international collaboration.

Consultation on SDLT charge for non-residents

The government recently published a consultation on the introduction of an SDLT (Stamp Duty Land Tax) surcharge for non-UK residents. The surcharge will apply to purchases of residential property made by non-UK resident individuals and certain non-natural persons. The surcharge will apply to freehold and leasehold purchases of residential property and will be at a rate of 1% on top of existing SDLT rates, including the rates applicable to the rental element of leasehold property. No date has been set for the introduction of the surcharge.


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