Change 1 Article Choose an article Title and introductory text 1 Income tax charge for tax year 2026-27 2 Main rates of income tax for tax year 2026-27 3 Default and savings rates of income tax for tax year 2026-27 4 Increase in dividend ordinary and upper rates 5 Savings rates of income tax for tax year 2027-28 6 New rates of income tax on property income 7 Property rates of income tax for tax year 2027-28 8 Scottish and Welsh property rates set by Scottish Parliament and Senedd 9 Freezing starting rate limit for savings for tax years 2026-27 to 2030-31 10 Basic rate limit and personal allowance for tax years 2028-29 to 2030-31 11 Charge and main rate for financial year 2027 12 Standard small profits rate and fraction for financial year 2027 13 Enterprise management incentives: thresholds and period for exercise 14 Enterprise investment scheme: increase in amounts and asset requirements 15 Venture capital trusts: rate of relief and amounts and asset requirements 16 CSOP schemes and EMI: PISCES shares 17 Employee car and van ownership schemes 18 Car or van made available on arm’s length terms 19 CO2 emissions figure for certain cars with an electric range figure 20 Employment income: miscellaneous exemptions 21 Disallowing deduction from earnings for additional household expenses 22 Payment for cancelled shifts etc. 23 Location of duties of employment where duties not performed 24 Umbrella companies 25 Loan charge settlement scheme 26 Loan charge settlement scheme: inheritance tax 27 Loan charge settlement scheme: supplementary 28 Main rate of writing-down allowances for expenditure on plant or machinery 29 First-year allowance for main rate expenditure on plant or machinery 30 Expenditure on zero-emission cars and electric vehicle charging points 31 Payments for surrender of expenditure credits 32 Transition from video games tax relief 33 Special credit for visual effects 34 R&D undertaken abroad: Chapter 2 relief only 35 Restriction of relief on disposals to employee-ownership trusts 36 Anti-avoidance: collective investment scheme reconstructions 37 Anti-avoidance: company reconstructions 38 Anti-avoidance: reconstructions involving transfer of business 39 Incorporation relief: requirement to claim 40 Non-residents: cell companies 41 Non-residents: double taxation relief relating to collective investment vehicles 42 Abolition of notional tax credit on distributions received by non-UK residents 43 Non-resident, and previously non-domiciled individuals 44 Trust protections etc: minor amendments and transitional protection 45 PAYE for treaty non-residents etc. 46 Unassessed transfer pricing profits 47 Transfer pricing reform 48 International controlled transactions 49 Permanent establishments 50 Pillar two 51 Controlled foreign companies: interest on reversal of state aid recovery 52 Offshore income gains 53 Offshore income gains: savings 54 Legacies to charities to be within scope of tax 55 Approved charitable investments: purpose test 56 Tainted charity donations: replacement of purpose test with outcome test 57 Winter fuel payment charge 58 Carried interest 59 Pensions: abolition of the lifetime allowance charge 60 Collective money purchase schemes and Master Trust schemes 61 Corporate interest restriction: reporting companies 62 Corporate interest restriction: capital expenditure and tax-EBITDA calculation 63 Avoidance schemes involving certain non-derecognition liabilities 64 Energy (oil and gas) profits levy: decommissioning relief agreements 65 Agricultural property relief and business property relief etc 66 Tax to be charged on certain pension interests 67 Liability for tax on pension interests 68 Withholding of benefits and payment of tax by pension scheme administrator 69 Connected amendments to IHTA 1984 70 Connected amendments to income tax rules 71 Commencement of sections 66 to 70 72 Rate bands etc for tax year 2030-31 73 Relevant property: disapplication of exemptions from exit charges 74 Relevant property: cap on charges for pre-30 October 2024 excluded property 75 Foreign diplomats etc: periods of UK residence to be disregarded 76 Minor corrections 77 Power to make provision about infected blood compensation payments 78 Scope of exemption for gifts to charities and registered clubs 79 Section 78: transitional protection for existing interests in possession 80 Zero-rating of leases of vehicles to recipients of disability benefits 81 Insurance premium tax relief limited to adapted vehicles 82 Private hire vehicles or taxis 83 Certain charitable donations not to be treated as supplies of goods 84 Refunds of VAT to combined county authorities 85 UK listing relief 86 Rate of remote gaming duty 87 General betting duty on remote bets 88 Abolition of bingo duty 89 Rates of duty 90 Rates of duty effective from 6pm on 26 November 2025 91 Rates of duty effective from 1 October 2026 92 Vehicle excise duty for light passenger or light goods vehicles etc 93 Vehicle excise duty for rigid goods vehicles without trailers and tractive units 94 Vehicle excise duty for rigid goods vehicles with trailers 95 Vehicle excise duty for vehicles with exceptional loads etc 96 Vehicle excise duty for haulage vehicles other than showman’s vehicles 97 Vehicle excise duty: expensive car supplement 98 Rates of HGV road user levy 99 Rates of air passenger duty 100 Rates of climate change levy 101 Rates of landfill tax 102 Rate of aggregates levy 103 Aggregates levy: amendments relating to disapplication of levy to Scotland 104 Rate of plastic packaging tax 105 Chemical recycling: mass balance approach 107 Sections 105 and 106: commencement 108 Rates of levy 109 Amendment of customs tariff power 112 Customs facilities at approved wharves and other places 113 Increases to rates of levy 114 Removal of time limit to claim relief under section 106(3) of FA 2013 115 Excise duty: charge 116 Vaping products 117 Production of vaping products 118 Excise duty point and payment 119 Administration 120 Stamping of vaping products 121 Issue and management of duty stamps 122 Approved stamp holders 123 United Kingdom representatives 124 Forfeiture 125 Dealing in unstamped vaping products 126 Loss and misuse of duty stamps 127 Failure to comply with this Part etc 128 Forfeiture: civil penalties 129 Dealing in duty stamps 132 Offences: penalties 133 Forfeiture: offences 134 Publication of information 135 Information sharing 136 Investigation and enforcement 137 Regulations: further provision 138 Regulations: procedure 139 Amendments of other enactments 140 Interpretation 141 Commencement and transitional provision 142 Introduction to CBAM 143 Charge to CBAM 144 Importation 145 Goods processed under a special customs procedure 146 Person liable: the importer 147 Exemptions 148 Embodied emissions 149 Rate 150 Carbon price relief 151 Administration and enforcement 152 Criminal offences 153 Supplementary amendments 154 Emissions: meaning etc 155 Interpretation 156 Power to make provision for linked emissions trading schemes 157 Regulations and notices 158 Commencement and transitory provision 159 Prohibition of promotion of certain tax avoidance arrangements 160 Meaning of promotion 161 Procedure 162 Civil penalties 163 Criminal offence 164 Criminal liability of responsible persons 165 Interpretation and commencement 166 Certification of promoters 167 Promoter action notices 168 Preliminary notices 169 Disclosure of information by HMRC 170 Appeal against a decision to issue a promoter action notice 171 Civil penalties 172 Publication 173 Reporting to regulators etc 174 Extension of time periods 175 Reasonable excuse 176 Interpretation 177 Connected persons 178 Anti-avoidance enactments 179 Information notices: connected persons 180 Information notices: third parties 181 Information notices: unidentified connected persons 182 Information notices: identification 183 Information notices: financial institutions 184 Content and requirements of notices 185 Restriction on disclosure of notices 186 Excepted information 187 Tribunal approval of notices 188 Withdrawal of notices 189 Offence of failing to comply with a notice 190 Offence of concealing information 191 Criminal liability of responsible persons 192 Criminal liability of responsible persons: no prosecution of recipient 193 Imprisonment or a fine 194 Penalty for failing to comply with a notice 195 Penalty for concealing information 196 Penalty for inaccurate information 197 Penalty for disclosing a notice 198 Penalty based on monies received 199 Increased daily default penalty 200 Extension of time periods 201 Reasonable excuse 202 Double jeopardy 203 Assessment etc of penalties: application of Schedule 36 to FA 2008 204 Appeals against notices 205 Appeals against penalties 206 Interpretation 207 Application of provisions of TMA 1970 208 Repeals 209 Declaration in relation to privileged material 210 Penalties for an incorrect declaration 211 Penalties: procedure, appeals etc 212 Publication following an incorrect declaration 213 Time limits for publication 214 Amendments to existing legislation: removal of privilege exemption 215 Commencement 216 Penalties for non-disclosure of tax avoidance schemes 217 Removal of time limits on publication by HMRC 218 Consequential amendments 219 Commencement 220 Construction industry scheme: amendments 221 Construction industry scheme regulations: amendments 222 Commencement 223 Prohibition against unregistered tax advisers interacting with HMRC 224 Meaning of “tax adviser” and “client” 225 Application for registration 226 Meaning of “relevant individual” and “officer” 227 Registration conditions 228 Registration conditions: interpretation 229 Registration conditions: offences 230 Registration of tax advisers etc 231 Monitoring of registration conditions 232 Suspension of registration 233 Compliance notice 234 Financial penalties for prohibited interaction with HMRC 235 Financial penalties for prohibited interaction with HMRC: liability of relevant individuals 236 Tax advisers: ineligibility orders 237 Relevant individuals: ineligibility orders 238 Requirement for tax adviser to notify clients of suspension or ineligibility orders 239 Reasonable excuse 240 Extension of period for making representations 241 Assessment of financial penalties 242 Time limits and treatment of financial penalties 243 Double jeopardy 244 Reviews and appeals 245 Disclosure of information 246 Power to publish information 247 Power to amend Schedule 20 (exceptions) 248 Interpretation of Chapter 249 Commencement 250 Conduct of tax advisers 251 Power to publish information 252 Power to publish information: change of circumstances 253 Power to publish information: interpretation and commencement 254 Fiscal mandate assessments prepared by the Office for Budget Responsibility 255 Data-gathering 256 Persons on whom digital reporting requirements may be imposed 257 Exemptions from digital reporting requirements 258 Returns to be delivered by electronic communications etc. 259 Penalties: amendments consequential on section 258 etc 260 Powers relating to electronic communications: directions 261 Power to require digital contact details 262 Penalty points and late submission penalties (power to cancel etc) 263 Assessments of late payment penalties etc. 264 Penalties for failure to pay tax due on further appeal 265 Failure to deliver company tax returns 266 Clearances 267 Binding effect 268 Extension 269 Modification 270 Information 271 Misrepresentation 272 Commissioners notice 273 Powers 274 Interpretation 275 Cryptoasset reporting: users and controlling persons resident in the UK 276 International cryptoasset reporting framework: connected matters 277 Stamp duty: piloting of digital service etc 278 Oversight of HMRC tax enforcement functions in Northern Ireland 279 Repeal of obsolete provision in FA 1925 concerning Dominion Governments 280 Repeal of other obsolete provisions and correction of wrong cross-references 281 Interpretation 282 Short title Schedule 1 Property and savings rates of income tax: consequential amendments Schedule 2 Scottish and Welsh property income rates Schedule 3 Non-resident, and previously non-domiciled individuals Schedule 4 PAYE for treaty non-residents etc Schedule 5 Unassessed transfer pricing profits Schedule 6 Transfer pricing Schedule 7 Permanent establishments Schedule 8 Pillar Two Schedule 9 Tainted charity donations Schedule 10 Winter fuel payment charge Schedule 11 Tax treatment of carried interest Schedule 12 Reform of reliefs for business property and agricultural property Schedule 13 Abolition of bingo duty: consequential and transitional provision Schedule 14 Aggregates levy: amendments relating to disapplication of levy to Scotland Schedule 15 Vaping products duty: amendments of other enactments Schedule 16 CBAM Goods Schedule 17 Administration of CBAM Schedule 18 Offences relating to CBAM Schedule 19 Supplementary amendments relating to CBAM Schedule 20 Registration of tax advisers: exceptions Schedule 21 Registration of tax advisers: reviews and appeals Schedule 22 Conduct of tax advisers Schedule 23 Data-gathering
What to do with it
As published
40 Non-residents: cell companies
(1) Part 4 of Schedule 1A to TCGA 1992 (anti-avoidance relating to assets deriving 75% of value from UK land) is amended as follows.
(2) For the heading of the Part substitute “Cell companies and anti-avoidance”.
(3) Before paragraph 11 insert—
Cell companies
10A (1) In the application of this Schedule in relation to the disposal of an asset consisting of a right or an interest in a cell company, each cell of the company is to be treated as if it were an individual company.
(2) For the purposes of this paragraph—
(a) a company is a “cell company” if under the law under which the company is formed, under the company’s articles of association or other document regulating the company or under arrangements entered into by or in relation to the company—
(i) some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and
(ii) some or all of the members of the company, and some or all of its creditors, have rights primarily, or only, in relation to particular assets of the company;
(b) “cell”, in relation a cell company, means an identifiable part of the company that carries on distinct business activities and to which particular assets and liabilities of the company are primarily or wholly attributable.
Anti-avoidance
.
(4) The amendments made by this section have effect in relation to disposals made on or after 26 November 2025.
Your wording
Your change, as a redline
40 Non-residents: cell companies
(1) Part 4 of Schedule 1A to TCGA 1992 (anti-avoidance relating to assets deriving 75% of value from UK land) is amended as follows.
(2) For the heading of the Part substitute “Cell companies and anti-avoidance”.
(3) Before paragraph 11 insert—
Cell companies
10A (1) In the application of this Schedule in relation to the disposal of an asset consisting of a right or an interest in a cell company, each cell of the company is to be treated as if it were an individual company.
(2) For the purposes of this paragraph—
(a) a company is a “cell company” if under the law under which the company is formed, under the company’s articles of association or other document regulating the company or under arrangements entered into by or in relation to the company—
(i) some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and
(ii) some or all of the members of the company, and some or all of its creditors, have rights primarily, or only, in relation to particular assets of the company;
(b) “cell”, in relation a cell company, means an identifiable part of the company that carries on distinct business activities and to which particular assets and liabilities of the company are primarily or wholly attributable.
Anti-avoidance
.
(4) The amendments made by this section have effect in relation to disposals made on or after 26 November 2025.
A proposal here is not law. Support on Solon is evidence that people want the change; the official route says what it takes to make it law.