Finance (No. 2) Act 2023

The Finance (No. 2) Act 2023 was published on legislation.gov.uk, the official website of the UK government for publicizing legal texts. The Act only covers income tax related issues, ranging from corporation tax for the tax year 2023/2024, to the new multinational top-up tax, to environmental taxes and taxes on alcohol.
While we expect most provisions to be non-relevant to our clients, we would like to make aware of some provisions that may be worth looking into:
(1) Part 1 Income tax, corporation tax and capital gains tax
– certain provisions as regards the Qualifying Asset Holding Company (QAHC) tax regime are being revised which is particularly relevant for institutional investors and investment funds, including funds in funds schemes (schedule 4);
– certain provisions as regards (collective) pension schemes are introduced (sections 18 through 25);
– a provision relating to the taxation of interest income is stipulated in section 3; and
– several provisions relating to the taxation of insurance companies, including provisions on the tax treatment of insurers in difficulties: „write-down orders in case of pension schemes“ are outlined in sections 30 through 33.
(2) Part 3 Multinational top-up tax
– the Act introduces provisions to transpose the OECD Pillar Two model rules for the implementation of the 15% global minimum tax for multinational corporations, including provisions as to the computation of income for purposes of the minimum tax.