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Draft Finance Bill 2018/19

Draft Finance Bill 2018/19

On Friday 6 July 2018, the draft clauses of Finance (No.3) Bill (which we will refer to as Draft Finance Bill 2018/19) were released, along with explanatory notes and tax information and impact notes (TIINs).

Michelle Quest

Head of Tax and Legal Services

KPMG in the UK


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Finance Bill 2018, Big Ben

Despite expectations that there would be announcements relating to taxation of the digital economy, an expanded royalty withholding tax scope and the corporate intangible fixed assets regime, none of these have materialised. However, some of the key measures in Draft Finance Bill 2018/19 include:

  • Oil and gas;
  • Property;
  • Anti-avoidance;
  • Leasing; and
  • Offshore time limits.

The draft legislation is now available for consultation until 31 August 2018, with the final contents of Finance Bill 2018/19 subject to confirmation at Autumn Budget 2018.

Our analysis of the key measures can be found below. 

Our insights on key measures

Oil & Gas: Transferable Tax History and decommissioning relief for PRT

Finance Bill 2018-19 includes two new measures which amend decommissioning tax relief for corporation tax and Petroleum Revenue Tax purposes.

Extension of time limits for offshore matters

Currently HMRC have four, six or 20 years (for mistake, careless or deliberate behaviour respectively) to assess tax that is due. Draft legislation issued on 6 July 2018 has extended the four and six year time limits such that HMRC will always be able to assess at least 12 years of back taxes for offshore non-compliance.

Draft Finance Bill 2018/19 - Leasing

HMRC reveals the remaining detail of their tax response to IFRS16, including its interaction with CIR.

Draft Finance Bill 2018/19 - Anti-avoidance measures

Draft Finance Bill 2018/19 included several anti-avoidance measures – this article highlights two key points.

Changes for non-resident investors in UK property

New rules for gains on direct and indirect disposals of UK property by non-residents and changes to tax on rental income of non-resident companies

International tax 

On the whole Draft Finance Bill 2018/19 did not contain any big surprises for multinational businesses, with the majority of the measures either implementing previously announced policy changes, or making smaller scale changes.

Other measures

Some other items of note from Draft Finance Bill 2018/19.


For further information please contact:

Sharon Baynham

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KPMG International Cooperative (“KPMG International”) is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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