(ii) is not a relevant programme for the purposes of Part 15A of
CTA 2009, and

(c) if that part of the straddling period were a separate accounting period,
in that separate accounting period—

(i) 5the programme would be a relevant programme for the
purposes of Part 15A of CTA 2009,

(ii) the company would for those purposes be the television
production company in relation to the programme, and

(iii) the conditions for television tax relief (see section 1216C(2) of
10CTA 2009) would be met in relation to the programme.

(9) For the purposes of calculating for corporation tax purposes the company’s
profits or losses for the straddling period of its activities in relation to the
programme—

(a) so much of the straddling period as falls before 1 April 2015, and

(b) 15so much of that period as falls on or after that date,

are to be treated as separate accounting periods.

(10) Any amounts brought into account for the purposes of calculating for
corporation tax purposes the company’s profits or losses for the straddling
period of its activities in relation to the programme are to be apportioned to the
20two separate accounting periods on such basis as is just and reasonable.

31 Television tax relief

(1) In section 1216CE(1) of CTA 2009 (television tax relief: UK expenditure
condition) for “25%” substitute “10%”.

(2) The amendment made by subsection (1) has effect in relation to relevant
25programmes the principal photography of which is not completed before 1
April 2015.

32 Restrictions applying to certain deductions made by banking companies

Schedule 2 contains provision restricting the amount of deductions which
banking companies may make in respect of certain losses carried forward from
30previous accounting periods.

33 Tax avoidance involving carried-forward losses

Schedule 3 contains provision restricting the circumstances in which
companies may make a deduction in respect of certain losses carried forward
from previous accounting periods.

CHAPTER 4 Other provisions

Pensions

34 Pension flexibility: annuities etc

Schedule 4 contains provision about pension annuities, and other pension,
5paid in respect of deceased members of pension schemes.

Flood and coastal defence

35 Relief for contributions to flood and coastal erosion risk management
projects

Schedule 5 makes provision about relief for contributions to flood and coastal
10erosion risk management projects.

Investment reliefs

36 Investment reliefs: excluded activities

Schedule 6 makes provision about excluded activities for the purposes of the
following provisions of ITA 2007—

(a) 15Part 5 (enterprise investment scheme) and, by virtue of section
257DA(9) of that Act, Part 5A (seed enterprise investment scheme),

(b) Part 5B (tax relief for social investments), and

(c) Part 6 (venture capital trusts).

Capital gains tax

37 20Disposals of UK residential property interests by non-residents etc

Schedule 7 contains provision about capital gains tax on the disposal of UK
residential property interests—

(a) by a person who is not resident in the United Kingdom, or

(b) by an individual, in the overseas part of a split tax year.

38 25Relevant high value disposals: gains and losses

Schedule 8 contains provision about the calculation of relevant high value
disposals within the meaning of section 2C of TCGA 1992.

39 Private residence relief

Schedule 9 contains amendments of TCGA 1992 in connection with private
30residence relief.

40 Wasting assets

(1) In section 45 of TCGA 1992 (exemption for certain wasting assets), after
subsection (3) insert—

“(3A) But subsection (3) does not apply in the case of a disposal in relation to
5which subsection (3B) disapplies subsection (1).

(3B) Subsection (1) does not apply to a disposal of, or of an interest in, an
asset if—

(a) at any time in the period of ownership of the person making the
disposal, the asset is used for the purposes of a trade, profession
10or vocation carried on by another person,

(b) as a result of that use, the asset becomes plant,

(c) but for the asset therefore being regarded under section 44(1)(c)
as having a predictable life of less than 50 years, the disposal
would not be of, or of an interest in, a wasting asset, and

(d) 15the disposal is not within subsection (3C).

(3C) A disposal of, or of an interest in, an asset is within this subsection if the
asset is plant used for the purpose of leasing under a long funding lease
and—

(a) the disposal takes place after the commencement of the term of
20the lease but before the termination of the lease, or

(b) the disposal is the deemed disposal of the asset under section
25A(3)(a) on the termination of the lease.

(3D) Section 25A(5) applies for the purposes of subsection (3C).”

(2) The amendment made by this section has effect—

(a) 25for corporation tax purposes, in relation to disposals on or after 1 April
2015, and

(b) for capital gains tax purposes, in relation to disposals on or after 6 April
2015.

41 Entrepreneurs’ relief: associated disposals

(1) 30Section 169K of TCGA 1992 (disposal associated with relevant material
disposal) is amended as follows.

(2) For subsections (1) and (2) substitute—

“(1) There is a disposal associated with a relevant material disposal if—

(a) condition A1, A2 or A3 is met, and

(b) 35conditions B and C are met.

(1A) Condition A1 is that an individual (“P”) makes a material disposal of
business assets which consists of the disposal of the whole or part of P’s
interest in the assets of a partnership, and—

(a) P’s disposed of interest is at least a 5% interest in the
40partnership’s assets, and

(b) at the date of the disposal, no partnership purchase
arrangements exist.

(1B) Condition A2 is that P makes a material disposal of business assets
which consists of the disposal of shares in a company, all or some of
which are ordinary shares, and at the date of the disposal—

(a) the ordinary shares disposed of—

(i) 5constitute at least 5% of the company’s ordinary share
capital, and

(ii) carry at least 5% of the voting rights in the company, and

(b) no share purchase arrangements exist.

(1C) But condition A2 is not met if the disposal of shares is a disposal by
10virtue of section 122, other than such a disposal treated as made in
consideration of a capital distribution from a company which is made
in the course of dissolving or winding up the company.

(1D) Condition A3 is that P makes a material disposal of business assets
which consists of the disposal of securities of a company, and at the
15date of the disposal—

(a) the securities disposed of constitute at least 5% of the value of
the securities of the company, and

(b) no share purchase arrangements exist.

(1E) For the purposes of conditions A2 and A3, in relation to the disposal of
20shares in or securities of a company (“company A”), “share purchase
arrangements” means arrangements under which P or a person
connected with P is entitled to acquire shares in or securities of—

(a) company A, or

(b) a company which is a member of a trading group of which
25company A is a member.

(2) For the purposes of subsection (1E)(b), a company is treated as a
member of a trading group of which company A is a member if, at the
date of the disposal mentioned in condition A2 or A3, arrangements
exist which it is reasonable to assume will result in the company and
30company A becoming members of the same trading group.”

(3) In subsection (3)—

(a) for “the individual”, in the first place it occurs, substitute “P”, and

(b) for “the withdrawal of the individual” substitute “P’s withdrawal”.

(4) After subsection (3) insert—

“(3A) 35The disposal mentioned in condition B is not treated as part of P’s
withdrawal from participation in the business carried on by a
partnership if at the date of that disposal there exist any partnership
purchase arrangements.

(3B) The disposal mentioned in condition B is not treated as part of P’s
40withdrawal from participation in the business carried on by a company
(“company A”) if at the date of that disposal there exist any
arrangements under which P or a person connected with P is entitled to
acquire shares in or securities of—

(a) company A, or

(b) 45a company which is a member of a trading group of which
company A is a member.

(3C) For the purposes of subsection (3B)(b), a company is treated as a
member of a trading group of which company A is a member if, at the
date of the disposal mentioned in condition B, arrangements exist
which it is reasonable to assume will result in the company and
5company A becoming members of the same trading group.”

(5) After subsection (5) insert—

“(6) In this section, in relation to a partnership, “partnership purchase
arrangements” means arrangements under which P or a person
connected with P is entitled to acquire any interest in, or increase that
10person’s interest in, the partnership (including a share of the profits or
assets of the partnership or an interest in such a share).”

“(7) In this section—

• “arrangements” includes any agreement, understanding, scheme,
  transaction or series of transactions (whether or not legally
  15enforceable);

• “securities” includes an interest in securities, and an “interest in
  securities” includes (in particular) an option to acquire
  securities;

• “shares” includes an interest in shares, and an “interest in shares”
  20includes (in particular) an option to acquire shares.

(8) For the purposes of this section, a person is treated as entitled to acquire
anything which the person—

(a) is entitled to acquire at a future date, or

(b) will at a future date be entitled to acquire.

(9) 25For the purposes of this section the assets of—

(a) a Scottish partnership, or

(b) a partnership under the law of any other country or territory
under which assets of a partnership are regarded as held by or
on behalf of the partnership as such,

30are to be treated as held by the members of the partnership in the
proportions in which they are entitled to share in the profits of the
partnership.

References in this section to an individual’s interest in the partnership’s
assets are to be construed accordingly.”

(6) 35The amendments made by this section have effect in relation to disposals made
on or after 18 March 2015.

42 Entrepreneurs’ relief: exclusion of goodwill in certain circumstances

(1) Chapter 3 of Part 5 of TCGA 1992 (entrepreneurs’ relief) is amended as follows.

(2) In section 169H (introduction), in subsection (3), for “section 169L” substitute
40“sections 169L and 169LA”.

(3) In section 169L (relevant business assets), in subsection (2), after “including”
insert “, subject to section 169LA,”.

(4) After that section insert—

“169LA Relevant business assets: goodwill transferred to a related party etc

(1) Subsection (4) applies if—

(a) as part of a qualifying business disposal, a person (“P”) disposes
5of goodwill directly or indirectly to a close company (“C”),

(b) at the time of the disposal, P is a related party in relation to C,
and

(c) P is not a retiring partner.

(2) P is a related party in relation to C for the purposes of this section if P
10is a related party in relation to C for the purposes of Part 8 of CTA 2009
(intangible fixed assets) (see Chapter 12 of that Part (related parties)
and, in particular, section 835(5) of that Act).

(3) P is a retiring partner if the goodwill is goodwill in a business carried
on, immediately before the disposal, by a partnership of which P is a
15member and at the time of the disposal—

(a) P is not, and no arrangements exist under which P could
become, a participator in C or in a company that has control of,
or holds a major interest in, C (a “relevant participator”),

(b) P is a related party in relation to C because P is an associate of
20one or more relevant participators, and

(c) P is only an associate of each of those relevant participators
because they are also members of the partnership.

(4) For the purposes of this Chapter, the goodwill is not one of the relevant
business assets comprised in the qualifying business disposal.

(5) 25If a company—

(a) is not resident in the United Kingdom, but

(b) would be a close company if it were resident in the United
Kingdom,

the company is to be treated as being a close company for the purposes
30of this section (including for the purposes of determining whether a
person is a related party in relation to the company for the purposes of
this section).

(6) If a person—

(a) disposes of goodwill as part of a qualifying business disposal,
35and

(b) is party to relevant avoidance arrangements,

subsection (4) applies (if it would not otherwise do so).

(7) In subsection (6) “relevant avoidance arrangements” means
arrangements the main purpose, or one of the main purposes, of which
40is to secure—

(a) that subsection (4) does not apply in relation to the goodwill, or

(b) that the person is not a related party (for whatever purposes) in
relation to a company to which the disposal of goodwill is
directly or indirectly made.

(8) 45In this section—

Finance (No. 2) BillPage 46

• “arrangements” includes any agreement, understanding, scheme,
  transaction or series of transactions (whether or not legally
  enforceable);

• “associate”, “control”, “major interest” and “participator” have the
  5same meaning as in Chapter 12 of Part 8 of CTA 2009 (see, in
  particular, sections 836, 837 and 841 of that Act).”

(5) The amendments made by this section have effect in relation to qualifying
business disposals made on or after 3 December 2014.

43 Entrepreneurs’ relief: trading company etc

(1) 10Section 169S of TCGA 1992 (entrepreneurs’ relief - interpretation) is amended
as follows.

(2) After subsection (4) insert—

“(4A) In this Chapter “trading company” and “trading group” have the same
meaning as in section 165 (see section 165A), except that, for the
15purposes of this Chapter—

(a) subsections (7) and (12) of section 165A are to be disregarded;

(b) in determining whether a company which is a member of a
partnership is a trading company, activities carried on by the
company as a member of that partnership are to be treated as
20not being trading activities (see section 165A(4)); and

(c) in determining whether a group of companies is a trading
group in a case where any one or more companies in the group
is a member of a partnership, activities carried on by such a
company as a member of the partnership are to be treated as not
25being trading activities (see section 165A(9)).”

(3) In subsection (5), omit the entry relating to “trading company” and “trading
group” and the “and” preceding that entry.

(4) For the purposes of conditions B and D in section 169I of TCGA 1992 (material
disposal of business assets), any reference to a company ceasing to be a trading
30company or ceasing to be a member of a trading group does not include a case
where a company ceases to be a trading company or ceases to be a member of
a trading group by virtue only of the coming into force of subsections (2) and
(3).

(5) This section comes into force on 18 March 2015.

44 35Deferred entrepreneurs’ relief on invested gains

(1) In Part 5 of TCGA 1992 (transfer of business assets) after Chapter 3
(entrepreneurs’ relief) insert—

“Chapter 4

Entrepreneurs’ relief where held-over gains become chargeable

169T Overview of Chapter

This Chapter makes provision about claiming entrepreneurs’ relief in
40certain cases where, in relation to held-over gains that originally arose
on a business disposal, there is a chargeable event for the purposes of

Schedule 5B or 8B (relief for gains invested under the enterprise
investment scheme or in social enterprises).

169U Eligibility conditions for deferred entrepreneurs’ relief

(1) Section 169V applies if, ignoring the operation of section 169V(2)(b),
5each of the following conditions is met.

(2) The first condition is that a chargeable gain (“the first eventual gain”)
accrues as a result of the operation of—

• paragraph 4 of Schedule 5B (enterprise investment scheme), or

• paragraph 5 of Schedule 8B (investments in social enterprises).

(3) 10If the first condition is met, the paragraph and Schedule mentioned in
subsection (2) that apply in the case are referred to in this section, and
section 169V, as “the relevant paragraph” and “the applicable
Schedule”.

(4) The second condition is—

(a) 15that the first eventual gain accrues in a case in which the original
gain would, but for the operation of the applicable Schedule,
have accrued on a relevant business disposal, or

(b) where the first eventual gain accrues in a case in which the
original gain would, but for the operation of the applicable
20Schedule, have accrued as a result of the operation of either of
the paragraphs mentioned in subsection (2), that the underlying
disposal is a relevant business disposal.

(5) The third condition is that a claim for entrepreneurs’ relief in respect of
the first eventual gain is made, on or before the first anniversary of the
2531 January following the tax year in which the first eventual gain
accrues, by the individual who made the disposal mentioned in
subsection (4)(a) or (b).

(6) The fourth condition is that the first eventual gain is the first gain to
accrue in the case as a result of the operation of the relevant paragraph.

(7) 30In subsection (4) “the underlying disposal” means the disposal (not
being a disposal within paragraph 3 of Schedule 5B or paragraph 6 of
Schedule 8B) by virtue of which Schedule 5B or 8B has effect.

(8) For the purposes of subsection (4), whether the disposal on which the
original gain would have accrued is a relevant business disposal, or
35whether the underlying disposal is a relevant business disposal, is to be
decided according to the law applicable to disposals made at the time
the disposal was made.

(9) In this section—

• “the original gain”, in relation to a particular case, has the same
  40meaning as in the applicable Schedule,

• “relevant business asset” has the meaning given by section 169L,
  and

• “relevant business disposal” means—

  (a)

  a disposal—

  (i)

  45within section 169H(2)(a) or (c) (qualifying
  business disposals), and

  Finance (No. 2) BillPage 48

  (ii)

  consisting of the disposal of (or of interests in)
  shares in or securities of a company, or

  (b)

  a disposal of relevant business assets which is
  comprised in a disposal—

  (i)

  5within section 169H(2)(a) or (c), and

  (ii)

  not consisting of the disposal of (or of interests
  in) shares in or securities of a company.

169V Operation of deferred entrepreneurs’ relief

(1) Where this section applies, the following rules have effect.

(2) 10The gain mentioned in section 169U(2) (“the first eventual gain”)—

(a) is treated for ER purposes as the amount resulting from a
calculation under section 169N(1) carried out—

(i) in respect of a qualifying business disposal made when
the first eventual gain accrues, and

(ii) 15because of the claim mentioned in section 169U(5), and

(b) except for ER purposes, is not to be taken into account under
this Act as a chargeable gain.

(3) If the first eventual gain is a part only of the original gain in the case
concerned, each part of the original gain that subsequently accrues as a
20chargeable gain as a result of the operation of the relevant paragraph—

(a) is treated for ER purposes as the amount resulting from a
calculation under section 169N(1) carried out—

(i) in respect of a qualifying business disposal made when
that chargeable gain so accrues, and

(ii) 25because of the claim mentioned in section 169U(5), and

(b) except for ER purposes, is not to be taken into account under
this Act as a chargeable gain.

(4) If the disposal mentioned in paragraph (a) or (b) of section 169U(4) is a
disposal within section 169H(2)(c) (qualifying business disposal:
30disposal associated with a relevant material disposal)—

(a) a disposal mentioned in subsection (2) or (3) of this section is
treated for the purposes of section 169P(1) as a disposal
associated with a relevant material disposal, but

(b) section 169P applies in relation to that disposal as if the disposal
35referred to in section 169P(4) were the disposal mentioned in
section 169U(4)(a) or (b).

(5) In this section “ER purposes” means the purposes of—

(a) section 169N(2) to (4B), (7) and (8), and

(b) section 169P.”

(2) 40The amendment made by subsection (1) has effect in relation to cases where the
disposal mentioned in the new section 169U(4)(a) or (b) is made on or after 3
December 2014.

Capital allowances

45 Zero-emission goods vehicles

(1) CAA 2001 is amended as follows.

(2) In section 45DA(1)(a) (period during which first-year qualifying expenditure
5may be incurred), for “5 years” substitute “8 years”.

(3) Section 45DB (exclusions from allowances under section 45DA) is amended in
accordance with subsections (4) to (7).

(4) In subsection (7), omit “notified” (in both places).

(5) In subsection (8), omit “to that extent”.

(6) 10In subsection (11), omit the definition of “notified State aid”.

(7) After that subsection insert—

“(11A) Nothing in this section limits references to “State aid” to State aid which
is required to be notified to and approved by the European
Commission.”

(8) 15The amendments made by subsections (3) to (7) have effect—

(a) in relation to a relevant grant or relevant payment made at any time
(whether before or on or after the specified day) towards expenditure
incurred on or after that day, and

(b) in relation to a relevant grant or relevant payment made on or after the
20specified day towards expenditure incurred before that day.

(9) “The specified day” means—

(a) for income tax purposes, 6 April 2015, and

(b) for corporation tax purposes, 1 April 2015.

46 Plant and machinery allowances: anti-avoidance

25Schedule 10 contains provision about plant and machinery allowances.

Oil and gas

47 Extension of ring fence expenditure supplement

Schedule 11 contains provision enabling the ring fence expenditure
supplement to be claimed for an additional 4 accounting periods (and as a
30result repeals provision for the extended ring fence expenditure supplement
for onshore activities).

48 Reduction in rate of supplementary charge

(1) In section 330 of CTA 2010 (supplementary charge in respect of ring fence
trades), in subsection (1), for “32%” substitute “20%”.

(2) 35The amendment made by subsection (1) has effect in relation to accounting
periods beginning on or after 1 January 2015 (but see also subsection (3)).