Main Budget coverage 

ICAEW’s analysis of, and comments on Autumn Budget 2024 can be found on the Budget hub. This includes articles published on the day of the Budget explaining key tax measures, such as: 

• the changes to employers’ national insurance contributions;
• the increases in rates of capital gains tax and stamp duty land tax; and
• the reform of key inheritance tax reliefs. 

Double cab pick-up vehicles 

At the Autumn Budget 2024, the government announced that HMRC will change the way in which it determines whether a double cab pick-up (DCPU) is a car for the purposes of: 

• the benefit in kind (BIK) rules;
• capital allowances; and 
• some deductions from business profits.  

The previous government had indicated that it would introduce legislation to maintain the treatment of DCPUs with a payload of one tonne or more as goods vehicles.  However, the current government has now said that it will follow the outcome of the Court of Appeal decision in Payne & Ors v HMRC [2020] EWCA Civ 889. This means that HMRC will consider the vehicle’s primary suitability at the time it was made, with reference to the vehicle as a whole.  

This applies from 1 April 2025 for corporation tax and 6 April 2025 for income tax. However, transitional arrangements apply to preserve the previous tax treatment for: 

• vehicles purchased, leased or ordered before 6 April 2025 for the purpose of the BIK rules. In this case, the transitional arrangements will apply until the earlier of either the disposal/lease expiry or 5 April 2029; and
• expenditure incurred before 1 October 2025 as a result of a contract entered into before 1/6 April 2025 for the purposes of the capital allowances rules. 

HMRC’s new approach is set out in EIM23151 (BIK rules) and CA23511 (capital allowances). HMRC says that, as a result of its change in approach, most DCPUs are expected to be treated as cars for tax purposes. 

No changes have been made to the VAT treatment. Therefore, it is understood that HMRC will continue to treat a DCPU with a payload of one tonne or more as a goods vehicle for VAT purposes (VAT Notice 700/57).  

Company cars  

Company car tax rates for 2028/29 and 2029/30 were set as follows at the Autumn Budget 2024:  

• for zero emission and electric vehicles: 7% for 2028/29 and 9% for 2029/30; 
• for cars with emissions of 1g to 50g of CO2 per kilometre, including hybrid vehicles: 18% for 2028/29 and 19% for 2029/30. This a significant change for users of some vehicles as for the current tax year, the appropriate percentage is as low as 2%; and 
• for all other vehicles: the appropriate percentage will increase by 1 percentage point for each of 2028/29 and 2029/30. The maximum percentage will be 38% for 2028/29 and 39% for 2029/30 for all other vehicle bands.   

Related announcements include that the government will: 

• act to close a perceived loophole in the rules for employee car ownership schemes; and
• extend the 100% first year capital allowances for zero-emission cars and electric vehicle charge-points to 31 March 2026 for corporation tax and to 5 April 2026 for income tax. 

Further information  

• Policy paper: Taxation of company cars: The appropriate percentage for tax years 2028 to 2029 and 2029 to 2030
• Autumn Budget 2024: Overview of tax legislation and rates (OOTLAR), paragraphs 1.20 (capital allowances) and 2.14 (anti-avoidance) 

Employee ownership trusts 

Following a consultation in summer 2023, the government has announced that it will make a number of changes to the tax rules for employee ownership trusts (EOTs), including: 

amending the conditions for obtaining capital gains tax (CGT) relief on the disposal of a controlling shareholding in a company to the trustees of an EOT on or after 30 October 2024. The changes will: 

• amending the conditions for obtaining capital gains tax (CGT) relief on the disposal of a controlling shareholding in a company to the trustees of an EOT on or after 30 October 2024. The changes will:
  • prevent the former owners retaining control of the company by having control of the EOT
  • ensure that the trustees of the EOT are UK resident as a single body of persons; and
  • require that reasonable steps are taken to ensure that the consideration for the shares does not exceed market value;
• requiring individuals to provide additional information to HMRC at the point of claiming CGT relief with effect for claims made on or after 6 April 2025;
• increasing the period of time within which CGT relief can be withdrawn if the EOT conditions are breached after the disposal of the shares. The measure will apply for disposals taking place on or after 30 October 2024; and
• introducing a relief from the charge to tax on distributions for contributions paid on or after 30 October 2024 to the trustees of an EOT in order to repay the former owners for their shares.  

Further information 

• Policy paper: Changes to the taxation of EOTs and employee benefit trusts
• Draft legislation

Business rates 

The government has announced permanently lower multipliers for the retail, hospitality and leisure (RHL) sectors for properties with a rateable value (RV) under £500,000 from 2026/27. This will be funded by a higher multiplier on all properties with an RV of £500,000 and above. 

In the shorter term, a 40% relief will be available to RHL businesses on their rates in 2025/26, up to a cash cap of £110,000 per business. In addition, the small business multiplier will be frozen in 2025/26. 

Looking forward, the government is aiming to make further improvements to the business rates system over the course of this parliament through a process of consultation with businesses, representative bodies and local authorities. 

Any further reform will be based around the three key objectives of: 

• protecting the high street;
• encouraging investment; and
• creating a fairer system 

The government has also reiterated its commitment to proceeding with the delivery of digitalising business rates by March 2028.

On 29 July 2024, the government announced that private schools in England will no longer be eligible for charitable rate relief. At the Autumn Budget 2024, the government confirmed that the measure will take effect from April 2025, and that legislation will be published in due course.

Further information

• Discussion paper Transforming business rates
• Autumn Budget 2024, paragraph 5.69