- the Finance Bill 2017-19 would reintroduce the provisions withdrawn from the Finance Act 2017, with some minor amendments contained in draft legislation published in July; and
- those provisions that had not made it into the Finance Bill, which were published immediately after the Spring Budget 2017, would be re-introduced in a subsequent Finance Bill to introduced after this Autumn’s Budget.
The Bill has been published today with the anticipated changes and the provisions applying retrospectively from 6 April 2017 are therefore also included. The provisions which were dropped in March due to time constraints do not appear. However, further transitional provisions have been added in relation to IHT on overseas property with value attributable to UK property. Broadly speaking, the taxpayer will not be penalised for late payment of the tax due as a result of these retrospective changes because the date on which the tax will become payable is being brought forward.
Yesterday we also said that we expected this legislation to be given a swift passage, but this will be no mean feat given that the Bill, which is divided into 72 sections and 18 schedules, is a document 665 pages in length.
We now look forward to seeing how the further draft legislation to be published on 13 September will interact with the Bill published today.
There are various planning options available to mitigate the impact of these changes.