UK Autumn Statement 2023 - Corporate

On 22 November, Jeremy Hunt, the Chancellor of the Exchequer, delivered the UK Autumn Statement 2023.

Capital Allowances – “full expensing” made permanent

The 2023 Spring Statement saw the temporary “super-deduction” replaced by a three year “full expensing” to 2026, allowing companies to write off the full cost of qualifying plant and machinery expenditure on assets such as machines, computers, tools, vehicles (excluding cars) and office, construction and warehouse equipment in the year of investment. Full expensing will now become permanent, so that investments made by companies in such qualifying plant and machinery will continue to qualify for a 100% first-year allowance for main rate assets and a 50% first year allowance for special rate (including long life) assets. 

Research and Development Reliefs

The Chancellor confirmed major reforms to go ahead from 1 April 2024, with some adjustments to previous announcements.  The R&D expenditure credit (RDEC) regime will be largely merged with the SME regime so as to have a single set of qualifying rules.  The relief will be based on a taxable “above the line” 20% tax credit, so that, after 25% corporation tax it is worth 15% of the qualifying expenditure.  However, for SMEs there will remain additional relief (86% of expenditure) for “R&D intensive” SMEs where the relevant R&D expenditure exceeds 30% of total relevant expenditure (this threshold is reduced from the 40% previously set out in draft legislation).

Investment Zones

Five new investment zones were announced, with tax reliefs across the zones extended, the business rates relief scheme for the retail, hospitality and leisure sectors has been extended to 2024/25.

Enterprise investment scheme and Venture Capital Trust extension

The government has confirmed that it will legislate in the Autumn Finance Bill 2023 to extend the existing sunset clauses for the EIS and VCT scheme from 6 April 2025 to 6 April 2035.

Stamp duty and stamp duty reserve tax: widening access to the Growth Market Exemption

The government will introduce legislation in the Autumn Finance Bill to extend the Growth Market Exemption, a relief from stamp duty and SDRT to include smaller innovative growth markets.  The change will allow multilateral trading facilities regulated by the Financial Conduct Authority and operated by investment firms to access the exemption.  The government will also legislate to increase the company market capitalisation cap condition within the growth market exemption from GBP170 million to GBP450 million.  The changes will take effect from 1 January 2024.

Finally…

The potential impact next year of the global minimum 15% tax rate under OECD Pillar II may need to be taken into account by large multinationals (EUR750m plus revenue) when evaluating the benefit of special corporation tax reliefs.

Should you have any queries on the Autumn Statement, please reach out to your usual UK tax contact.