Chapter 79 – Investment Intermediaries. Advisory services fees relating to the
proposed sale of a subsidiary qualified as management expenses, but were non-deductible

because the expenditure was capital in nature: see HMRC v Centrica
Overseas Holdings Ltd [2022] EWCA Civ 1520. Note at the time of writing this case
was under appeal to the UKSC.

Chapter 80 – Pensions. The lifetime allowance tax charge was abolished for the tax

year 2023-24 and subsequent tax years. For 2023-24 and subsequent tax years the annual

allowance is increased from £40,000 to £60,000. The annual allowance is reduced by £1

for every £2 of adjusted income in excess of £260,000, to a minimum of £10,000.

Chapter 81 – Charities. The Finance (No 2) Act 2023 restricts income tax and
corporation tax reliefs for charities and community amateur sports clubs to UK
charities and community amateur sports clubs, in relation to the 2024-25 and
subsequent tax years and accounting periods beginning on or after 1 April 2024.
Similarly, CGT relief is restricted to UK charities in relation to disposals made on or
after 6 April 2024, and IHT relief to UK charities in relation to transfers of value
made on or after 1 April 2024. Similar restrictions apply to stamp duties.