Tax Matters: Ready, Steady, Growth – Business tax implications of the UK Spring Budget 2023

The Freshfields Podcast

The UK Chancellor of the Exchequer, Jeremy Hunt, has delivered the Spring Budget 2023.

Following the instability experienced in the UK in recent months, it was a relief to many to see the Office for Budget Responsibility (OBR) confirm that ‘the economic and fiscal outlook in the UK has brightened somewhat’ since the Autumn Statement 2022 was delivered last November. That is not to say, though, that the UK economy was given a clean bill of health: the OBR also recognised that ‘weak underlying momentum’ remained, fuelled by high gas prices, stagnating business investment, rising labour market inactivity and slowing productivity growth. Against that background, it is perhaps no surprise that the Chancellor used this Spring Budget to introduce a range of measures – some headline-grabbing, others more subtle – designed to bring about ‘long term, sustainable, healthy growth’.

In our latest podcast, London Tax partners Helen Buchanan and Paul Davison and London Tax senior associate Josh Critchlow discuss some of the business tax measures they found the most noteworthy in the Spring Budget 2023, including:

• Confirmation that the increase in the main rate of corporation tax from 19% to 25% from 1 April 2023 will go ahead as planned;
• The introduction of new full expensing capital allowance rules giving companies a 100% first-year allowance for capital expenditure on main rate assets over the next three years;
• Further changes to the research and development (R&D) tax relief regime, including additional relief for R&D intensive SMEs and a delay to previously-announced restrictions on R&D relief for overseas expenditure;
• Confirmation that proposed changes to the scope of sovereign immunity from direct tax will not go ahead;
• A range of amendments designed to ‘fix’ elements of key UK business tax regimes, including the corporate interest restriction and the qualifying asset holding companies regime;
• Various steps aimed at supporting the energy transition, including proceeding with the previously-announced decarbonisation allowance in the Energy Profits Levy and bringing forward new measures on carbon capture, usage and storage; and
• Reforms to pension tax thresholds, including the unexpected abolition of the Lifetime Allowance.