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1. 27 Jan 2026·Parliament·Jerome Mayhew

   Railways Bill (Sixth sitting)

   Yes, repeatedly, which is great, because my hon. Friend is absolutely fighting for his constituency and his constituents. He has told me of a repeated trouble that communities experience when a level crossing closes very frequently and for long periods with no regard to the economic impact of that on the town in which it is based. That can cause long periods of tailbacks, but there is no consideration of that when the usage of the piece of line is set, and the Bill, as drafted, makes no provision for GBR even to take that problem into account. Amendment 260 would insert clause 15(2A), which states that the “rail strategy must include a strategy for level crossings (“the level crossings strategy”)”, and clause 15(2B), which states: “The level crossing strategy must set out an assessment of the impact of level crossings on the economy and community of the area in which the level crossing is situated, for the purpose of reducing disruption caused by level crossings.” That is actually a very sensible point, because it recognises that the railway does not impact just trains. If a level crossing temporarily closes arterial routes, there is an impact on other modes of transport, so it would be sensible for a strategy to take into account the full impact of the changes that the Secretary of State has in mind. Amendment 261, which my hon. Friend the Member for Runnymede and Weybridge also tabled, would insert an alternative subsection (2A) in clause 15, stating: “The rail strategy must include an assessment” of “the ability of passengers to change between…main line rail services” and from rail services to “other modes of public transport.” The amendment would also provide that the “assessment under subsection (2A) must consider how to reduce delays and disruption to end-to-end journeys involving a change between rail services, or between rail services and other modes of public transport.” This is, again, my hon. Friend the Member for Runnymede and Weybridge standing up for his constituents and the particular issues that they face with the co-ordination of services. Having heard the experience of Mayor Burnham with the Bee Network in Greater Manchester, the Committee could argue that the increased integration of all modes of transport should properly be a focus of GBR, and the amendment would apply that integration to areas that are not mayoral combined authorities. Later in Committee, we will consider an amendment that seeks to extend the same courtesies to local transport authorities as the Bill extends to mayoral combined authorities, and I know that my hon. Friend the Member for South West Devon will be keen to speak to that. Liberal Democrat amendment 135, which was tabled by the hon. Member for Didcot and Wantage, would require the Secretary of State to make an international rail strategy part of the Government’s long-term rail strategy. That would specifically look to support new routes and operators, and increase channel tunnel and London St Pancras high-speed rail capacity.

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2. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   As the Minister says, clause 42 abolishes the notional tax credit that non-residents have historically been able to claim on their UK dividend income. Under the current system, non-domiciled individuals can offset that notional credit against other UK income streams, such as rented income or partnership profits. However, from April, that arrangement will no longer apply. Non-residents will no longer be treated as having already paid UK tax on dividends received from UK companies, meaning that they will lose the ability to reduce their overall UK tax liability from using the credit. It is worth noting that UK residents lost access to the notional dividend tax credit back in April 2016, so in one sense the clause simply removes what is perceived as a potential unfair advantage enjoyed by non-UK residents. The disregarded income regime will continue to operate, providing some limitation on the tax paid by non-residents in specific circumstances. We need to look at the clause, and the ones coming up, in the broader context. It represents a shift in how UK tax dividends flow to foreign investors and, in practice, it will effectively increase the tax rate burden on dividend recipients who are non-UK residents. At a time when the UK needs to attract international capital, we need to look at the measures in the Budget as a whole and whether they strengthen or undermine our competitive position. Attracting capital to be invested was a topic that we discussed this morning. International investors might be forgiven for concluding that the Chancellor is creating a tax and regulatory environment that feels increasingly unpredictable compared with some of our international competitors. Stability and certainty matter enormously in investment decisions. [Interruption.] The Chartered Institute of Taxation has also raised concerns about the figures underlying this policy. The Treasury estimates in the famous tax information and impact note, which was referred to by the Minister, that fewer than 1,000 resident individuals will be affected. The institute has questioned whether that can be accurate, given what its professional members are seeing on the ground. There is particular uncertainty about whether non-resident trust taxpayers have been properly included within those calculations. I welcome a response and assurance from the Minister either way on that. That said, even the institute agrees that those impacted will represent a small minority of the overall non-resident taxpayer population. We concur that this charge brings a welcome simplification to tax calculations.

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3. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   The Minister has skirted over quite a few detailed issues rather briefly. It will reassure the Committee to know that I intend to take a bit more time to go through what are detailed and important principles, and to reflect on questions raised in an earlier clause—how competitive we are, what we want to do, and whether we want to attract wealthy people to the country. I will initially speak to clause 43, schedule 3 and amendments 30 to 35, which were tabled in my name. Clause 43 introduces schedule 3 of the Bill, and members of the Committee will see that the schedule runs to 14 pages of complex detail, so it is important that we properly scrutinise it. Those pages make various changes to the foreign income and gains regime brought into effect by the Finance Act 2025. On the surface, this may look like a simple tidying-up exercise, but on closer inspection it raises some important questions about the coherence of the Government’s overall approach to taxing globally mobile individuals. While we support fair taxation, this Government have once again produced needlessly complex legislation that contains retrospective elements and leaves ordinary people potentially facing unexpected tax bills.

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4. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   Well, indeed. I will come on to the detail. On the broader point, we support the initiative behind these measures—to encourage people to bring more of their money to the UK, precisely so it can help fund our public services. Our concern is about the implementation, and I will come on to some of the comments that representatives of the Chartered Institute of Taxation, who are widely acknowledged as experts in this area, have raised about the complexity and the retrospective elements. As I said, schedule 3 is in three parts. Part 1 relates to relief for new residents on foreign income and gains—FIG. Under the new FIG regime, when someone moves to the UK, they do not pay UK tax on their foreign income for the first four years here. That is very sensible, but the Government have made claiming that relief so complicated that honest taxpayers risk falling into traps simply through lack of awareness. I hope the Government will take account of the following sensible steps suggested by the Chartered Institute of Taxation: first, to remove the requirement to report every possible element of FIG as part of the claim, and instead making relief from UK tax on FIG the default position; similarly, extending the relief to the personal representatives of a deceased individual who themselves qualified; and finally, simplifying the legislation by aligning the income tax position on trust distributions with the capital gains position. I would be grateful for the Minister’s response on those points when she winds up. Part 2 relates to the temporary repatriation facility, clarifies how remittances to the UK under that temporary facility should be matched to their original source. For years, non-domiciled individuals could keep foreign money offshore, paying UK tax only if they brought it here. The TRF offers a window until 2028, precisely to encourage people to bring money to the UK at reduced rates of 12% in the next two years or 15% in ’27-28. That is, as I said to the hon. Member for Burnley, a good idea in principle, but the devil, as ever, is in the detail. Our friends at the Chartered Institute of Taxation pointed out some serious concerns that there are several paragraphs within the schedule—which I see the hon. Member turning to—that do not appear to work as intended or that produce unintended consequences. First, they believe that, as drafted, the new offshore income gains paragraph introduced here leads to an anomaly in the way that trust distributions are matched where a trust has generated offshore income gains. That results in trusts with surplus pre-6 April 2025 capital gains tax being treated differently from those without. We do not believe that to be the Government’s intention; perhaps the Minister can clarify. Secondly, investments clearly fall in value, but under this legislation, if someone invested foreign income overseas and it is now worth less, they will still pay the temporary repatriation facility charge on the original higher amount. That could mean paying 12% tax on £100,000 even though the investment is worth only £60,000. Do Committee members think that is fair? Do they think it will encourage or discourage the repatriation of funds that this facility is designed to encourage, to help support our economy and public services? I would contend that the incentive, as a result, is to keep the money out of the UK, which is not what we on the Opposition side—or, I believe, on the Government side—of the Committee want to see. We therefore tabled amendment 30 to remedy this issue, and I encourage Members to support us on it when the moment comes. Thirdly, the Bill contains retrospective taxation. Let us be clear: retrospective taxation should be reserved for the most egregious tax avoidance, but here, trustees who made payments to beneficiaries in good faith after April, relying on existing law, may now face double taxation because of rules that look backwards. That is not about closing a loophole; it is about changing the rules after people have already acted. Our amendments 31 and 32 would ensure that double taxation does not apply retrospectively. Fourthly, in this clause and schedule the Government have created arbitrary restrictions so that the TRF is available only to UK residents. Why should someone temporarily living abroad not be able to use this facility? The temporary non-residence rule means that they will be paying UK tax when they return anyway, so why not let them use the TRF? The rules create a situation where someone who wants to pay tax voluntarily is not able to do so. Our amendment 33 would ensure that the TRF is available to both UK residents and non-residents. Similar concerns have also been raised regarding offshore trusts. The temporary repatriation facility applies a 12% or 15% rate to the personal FIG of individuals who have previously used the remittance basis as well as certain capital payments from offshore trusts. This was to encourage the winding-up of foreign trust structures. Right now, though, the trusts part works only if the beneficiary getting the capital could have used the remittance basis in their own right. That creates an unfair outcome in families where one beneficiary has used the remittance basis but another has always paid full UK tax on worldwide income, because only the former can benefit from the lower temporary repatriation rate if the trust is wound up. Perhaps I could give the Committee an example to illustrate this point further: a family has an offshore trust for two adult children and one child previously used special tax rules while the other has always paid full UK tax. Under this Bill, only the first child could benefit from the TRF when the trust is wound up. That does not encourage bringing money to the UK but, I would contend, actively discourages it. Amendment 34 would therefore enable offshore trust beneficiaries who have not themselves used the remittance basis to use the TRF. Amendment 35 would enable trustees to pay a temporary repatriation facility charge on the trust’s past FIG while retaining the funds within the trust, without having to make capital payments to the beneficiary. Amendments 1 and 2, in the name of my hon. Friend the Member for Windsor (Jack Rankin), relate to this issue. The Government refer to the temporary repatriation facility as encouraging wealthy people to stay and invest here, and the Treasury is counting on these measures to raise a significant sum for public services, although I note that the OBR suggests there is considerable uncertainty about that. However, we know that the wealthiest people—the wealthiest investors, the people who are supporting our entrepreneurs and the high-growth businesses that we want to see—are leaving the UK as a result of steps that the Chancellor has taken. By some estimates, 10,000 people have already got on a plane and left—those are figures from Oxford Economics. We can debate whether the number is 10,000 or 5,000, but some figures suggest that the equivalent of 750,000 basic rate taxpayers have left the country. So this is not about ideology; it is about giving certainty and addressing the points that the Bill as drafted does not. The TRF could become unusable for some because of the risks it exposes them to. There is the double taxation, which I have talked about, as well as the retrospective elements, but in addition, accusations of tax avoidance could arise from using a scheme that Parliament has itself created and lead to potentially lengthy investigations. People are leaving, and the Chartered Institute of Taxation has said that tax rules under the measure make the UK a less attractive destination for people. It should be easier to understand and apply measures aimed at getting people to bring money back to the UK. There is a risk that, as drafted, these measures drive against the Government’s intention. Amendments 1 and 2 are tabled in a constructive spirit. Amendment 1 would stop the double counting, and amendment 2 is about the retrospective and unfair action. They would provide the certainty that, according to some experts in this field, is currently missing. Without the TRF being attractive, we will not be able to get the money coming into the country. I urge the Minister to respond more fully than she did in her opening remarks and to consider whether, on Report or at a later stage, amendments could be tabled to deliver the clarity that my amendments and those tabled by my hon. Friend the Member for Windsor offer. Without clear guidance, ordinary commercial transactions could inadvertently be caught. The Government must publish comprehensive examples, or businesses and individuals will be left guessing. When Ministers replaced the long-standing non-dom regime last year, they promised a clean, modern and transparent framework, yet within a year we have a schedule of corrective provisions to make the legislation operate “as intended”. That rather suggests that the original drafting was not as watertight as claimed, and that further tweaks along the lines we have suggested might still be needed before the system settles.

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5. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   Clause 45 will extend the PAYE notification process to include treaty non-residents and introduce the 30% cap, to which the Minister referred, on overseas workday relief that can be claimed through PAYE. In simple terms, clause 45 and schedule 4 will change how employers operate PAYE for people who move to the UK but are treated as resident in another country under a tax treaty. The clause will let employers agree with HMRC that the part of the employee’s salary that is expected to be exempt overseas be left out of PAYE during the year, and it will formally limit how much foreign employment relief can be given to 30%. The changes under the clause will require employers to send further notification to HMRC whenever there is a change in the employee’s circumstances that affects the proportion of earnings subject to PAYE. That sounds reasonable in practice, but I want an assurance from the Minister about the potential administrative burden that it will place on employers. It could mean that employers will now be expected to monitor the day-to-day working practices of globally mobile working employees. They will need to track whether individuals are working from home or from a hotel room in Boston, which is not necessarily a simple task. For multinational companies with hundreds of employees, this represents a potentially significant compliance burden at a time when we want to reduce the burdens on business. For smaller businesses venturing into international markets for the first time, it could be a disincentive—indeed, a barrier—to their trying to do so. The Government must provide clear, comprehensive guidance on exactly what level of review and monitoring employers are expected to undertake not to fall foul of the rules. Without that clarity and guidance, we risk creating a compliance minefield in which well-meaning employers inadvertently break rules that they could not reasonably be expected to follow. Guidance can help employers to comply with the law, as we all want them to do. The Government like to talk about making Britain the best place to do business and to champion our competitive advantage in attracting global talent—we have just discussed one area in which that may or may not be the reality—but we should seek to avoid introducing measures that potentially add to the compliance burden without giving guidance to employers. I hope that the Minister can assure the Committee that she will look at the case for publishing clear guidance to ensure that businesses are not adversely impacted.

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6. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   The clause introduces schedule 5, which will repeal the diverted profits tax and replace it with new rules to tax unassessed transfer pricing profits within the corporation tax regime, coming into effect for periods beginning on or after 1 January. The diverted profits tax will continue to apply for prior accounting periods. In effect, the clause creates a higher tax charge on profits that should have been taxed here, but were shifted out of the UK by using non-market prices between groups. Like the DPT, the new transfer pricing profits rules are intended to target structured arrangements that are designed to erode the UK tax base by omitting profits that are subject to transfer pricing. These unassessed transfer pricing profits will be taxed at a rate that is six percentage points higher than corporation tax. In simple terms, if a global business structures its arrangements to shift profits from the UK in a pricing manipulation, HMRC will be able to bring those diverted profits into UK tax at a higher, penalty-style rate. In principle, we support that approach. Moving away from the stand-alone tax and bringing diverted profits under corporation tax provides better treaty access and clarity, and clearly the six percentage point charge works as a deterrent, as countries that play games with their transfer policies will risk paying more tax than if they had priced their UK dealings properly in the first place. However, I would welcome the Minister’s response to the concerns that the Chartered Institute of Taxation has raised about the drafting of the clause. First, the new tax design condition is very broad: it captures transactions designed to reduce, eliminate or delay UK tax liability. There is a question as to whether legitimate commercial decisions made for regulatory compliance or capital requirements could be caught by the condition simply because they are deliberate and happen to reduce tax liability, even when tax planning is not the primary motive. I know that is not the intention behind the drafting, but that point has been raised, so I hope that the Minister will respond in order to avoid any uncertainty as to whether businesses that think they are operating within the law, without seeking to reduce, eliminate or delay tax liability, may be captured. Will the existing arrangements be grandfathered? Can HMRC revisit settled positions under these broader rules? As the Chartered Institute of Taxation rightly says, it is unsatisfactory to pass legislation with a wide definition and simply hope that HMRC guidance and rules will narrow it down later. That is not how we in Parliament should legislate. We discussed the loan charge during this morning’s sitting; HMRC applied rules in a way that most MPs did not consider reasonable, and we have now had to make changes through this Bill to address that historical issue. The law should be made clear in the Bill, not left to administrative interpretation. I would be grateful if the Minister confirmed how many multinational companies HMRC estimates are using pricing manipulation to avoid tax. Can she guarantee that legitimate business structures that have previously been accepted by HMRC under the DPT will not suddenly fall foul of the scope of the new rules? Will she also comment on the main purpose test, to provide clarity and certainty for businesses?

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7. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   Clause 47 and schedule 6 mark an evolution in the UK’s transfer pricing regime. The Opposition recognise the importance of getting this right: it goes to the heart of how multinational profits are attributed and taxed, and therefore how we ensure that companies pay the correct amount of tax in this country. The principle behind transfer pricing is simple, even if it is rarely simple in practice. I believe that these measures flow from a consultation process launched by the last Conservative Government, so they have a good origin. I hope that they will lead to greater certainty and reduce the burden that some companies may face.

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8. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   New clause 4 stands in my name and that of my hon. Friend the Member for Wyre Forest. As the Minister says, clause 48 introduces a power for HMRC to implement a new reporting obligation: the ICTS, which will come into force in 2027. This new power would require businesses engaged in significant cross-border transactions to disclose specified information about their dealings. Rightly, the intention is to give HMRC better tools to identify transfer pricing and international tax risks that could affect the tax take, and to allow it to conduct more efficient and better-targeted compliance activity. I recognise that objective and support it in principle. I agree that the ICTS could help HMRC to identify risk earlier and to avoid wasting the time of the Department and businesses. Chasing down questions and embarking on inquiries can often lead nowhere and can cost businesses time that could be spent on growing their business. However, it is also important that the Government explain how the system will work in practice and how it will be seen to work. Our new clause 4 would therefore require a report on the impact of these changes on cross-border trade and the administrative burden on businesses. During the consultation last year, the Treasury acknowledged that more needed to be said about how the data collected through the ICTS system would be used and how it would fit alongside existing obligations such as master and local files. That remains a crucial point of detail that the industry and advisers will be looking for as this measure is implemented. Can the Minister shed some light on those concerns today? As the Minister rightly says, most major economies already have some equivalent form of reporting, but it should be pointed out that the differences between them are significant. Australia, for example, operates a single transaction-driven disclosure process through its international dealings schedule; the United States of America relies on a more fragmented, relationship-based approach spread across multiple forms. Each system clearly has its benefits and disadvantages. What matters is that each country has a clear, consistent model to which businesses can understand and readily adapt. What the Government seem to be proposing is a hybrid. That might mean that we have the best of both worlds—let us all hope so—but it might also lead to an approach that is inconsistent with the systems that some multinationals already have. The Treasury has said that it will consult on detailed regulations in the spring of this year. We welcome that commitment. Can the Minister give an assurance that she will make sure that businesses and representative bodies will be closely involved in shaping how the system is put into practice? With the planned 2027 start date, there is not a lot of time to get the rules in place or for companies to build or modify systems to provide the new data. Can that be done without causing undue cost and disruption to businesses? Finally, I want to make a slighter broader point on the clause. We clearly understand the importance of robust compliance and the need to protect the UK tax base on behalf of our constituents so that we can deliver public services. However, each new requirement—whether it is the ICTS, pillar two returns or transfer pricing documentation—adds to the cumulative impact on businesses. We need to see these obligations in the round, not as each one being reasonable on its own terms. What is the overall picture of what we are imposing on companies? If that load becomes too great, the UK will be seen as a less attractive place to invest, which is certainly not what we want. Although we support the principle of better risk assessment, we continue to press Ministers to ensure that we have proportionate and workable solutions that add value for HMRC, businesses and our constituents. New clause 4 would simply require a report setting out those impacts. I would add that, according to the Budget costings, the reporting duty would raise around £25 million in 2026-27, growing to £350 million a year, helping HMRC to tackle artificial profit shifting. That is welcome, but we should also consider the one-off and ongoing costs for businesses that have to re-engineer their systems. I would be grateful for the Minister’s response to my points about implementation and whether the hybrid model will actually be the best of both worlds.

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9. 27 Jan 2026·Parliament·James Wild

   Finance (No. 2) Bill (Second sitting)

   Clause 49 and schedule 7 make changes to the rules that decide, where a company has a permanent establishment in the UK, how its profits are then taxed and when they apply. The Minister talked about modernising and simplifying the rules to bring them into line with international best practice. To clarify, in November 2025 the OECD published new guidance on the definition of a “permanent establishment”. Can the Minister confirm whether the UK’s current approach reflects that updated guidance, as I have been advised that it does not? Some expert bodies have pointed out that the OECD changes are generally helpful and would bring more consistency across countries, so does the Minister agree that it would make sense for the UK to broadly adopt them? Is that the Government’s approach, or have they deliberately decided to have a set of UK rules? If so, what is the purpose of that, considering that we might be dealing with multinational companies operating in multiple jurisdictions that would have to follow separate rules when the OECD has brought together a coherent package?

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10. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (Second sitting)

    I rise to speak to clause 50 and to new clause 5, which is in my name. Clause 50 will amend parts of the Finance (No. 2) Act 2023 and implement the multinational top-up tax and domestic top-up tax. As I set out in the last Finance Bill Committee, in October 2021 more than 135 countries signed up to the G20/OECD agreement on reforming international transactions and taxation, which the clause refers to—a major achievement that aims to ensure that multinational groups pay a fair share of tax where they generate profits. Pillar two delivers a minimum global effective tax rate of 15% for large multinational groups in every country they operate in, and the UK has been one of the first jurisdictions to legislate for the changes. New clause 5 would require the Chancellor to review the changes on a six-monthly basis and lay before Parliament a report assessing three key issues: whether other major economies are implementing pillar two on comparable timelines and with comparable scope, whether any competitive disadvantage is arising for UK-based multinationals, and the impact of differentiated treatment for the United States. Crucially, if that review identified a material competitive disadvantage to the UK and UK businesses, the Treasury would be obliged to provide remedial measures within three months. In rejecting new clause 5—another new clause that asks for a review—the Minister says that the Treasury is always conducting regular reviews of measures. If it is conducting this work anyway, why not share it with Parliament, and accept that it is a proportionate step to ensure ongoing parliamentary scrutiny in a very important area—a level playing field for British firms? The Minister referred to the length of the schedule. The sheer volume of amendments, coming less than two years after pillar two was first introduced, highlights the extreme technical complexity of the global minimum tax and the challenges for businesses that have to comply with it to keep up to date. The Government’s aim is to ensure that UK rules remain consistent with the OECD model legislation, and schedule 8 is therefore aligned with the guidance and technical fixes. Those are sensible to maintain international consistency, but throughout last year there was growing international uncertainty about pillar two, the subject of the clause, as political divergence emerged over how it should operate, particularly regarding the treatment of US-parented companies. The Minister referred to the side-by-side agreement made between G7 Governments last summer—and formalised, I think, this month—allowing certain UK and US multinationals to be exempt from parts of the rules while retaining access to the newly defined safe harbours. The agreement might bring some short-term stability, but it raises questions, and clearly we will be scrutinising it when, as the Minister said, it comes forward in future legislation. The US Treasury Secretary has described the side-by-side deal as “a historic victory in preserving US sovereignty and protecting American workers and businesses from extraterritorial overreach.” Will the Minister comment on what pillar two means in that context and on the UK’s position? The impacts that might flow from that are precisely why new clause 5 is needed. The Government say that the UK is aligned with international developments, but the international landscape is shifting. Other major economies have delayed implementation or have adopted narrower regimes; meanwhile, the US has its own agreement and has not legislated for this framework at all. Without scrutiny, the risk is that UK-headquartered multinationals will find themselves complying with complex and burdensome rules, while their competitors operating elsewhere face a lighter regime. I simply note that the Chartered Institute of Taxation pointed out that it thinks the burdens of pillar two “continue to appear disproportionate to the amount of tax that will be raised”. If the Government truly believe that the regime provides a balanced and proportionate approach to a level playing field and that we can be assured that the competitive advantage does not go to other countries, let us have that report, see it set out to Parliament and have the matter resolved. To conclude, international co-operation on tax is essential, but we need to ensure not only that the UK is honouring its commitments, but that other countries are meeting theirs, so that UK companies are not losing out as a result.

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11. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (Second sitting)

    As the Minister said, this is a fairly straightforward measure allowing HMRC to pay interest to companies that have had to hand over money under a now overturned EU state aid ruling relating to the controlled foreign company rules. The 2019 ruling was subsequently annulled. My only question for the Minister is: does the clause mark the final chapter in the UK’s compliance with the EU state aid rules relating to the controlled foreign companies regime, or could other outstanding matters give rise to further issues or payments?

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12. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (Second sitting)

    Charities are a very important topic. We need to ensure that we give it appropriate scrutiny, given the importance of charities in our society and communities. Clause 52 and new clause 6—which I will speak to—relate to extending the definition of attributable income to include legacies left to charities. In practice, that means that when a charity receives a gift left in a person’s will, it could face a tax charge if that money is not spent on its charitable activities. How charities use their funds is a topical subject in the context of the Church of England, which is planning to spend £100 million on its fund for healing, repair and justice—effectively a reparation fund for slavery, which many consider not to be an appropriate use of the funds, or what people gave funds to the Church for. I now turn to the clause. The change will apply to gifts made on or after 6 April this year. New clause 6, in my name—it bears repetition—would require the Chancellor, within six months of the Act becoming law, to publish a report on the impact of the measure on charitable giving through estates and on the wider impact on the charity sector. Concerns have been raised that expanding rules to cover legacies could have unwelcome implications if charities do not apply inherited funds quickly enough to their charitable purposes, leading to them being taxed. The Institute of Chartered Accountants in England and Wales warns that that uncertainty, particularly around the timing, may discourage potential donors from including charities in their wills. Clearly, none of us would wish to see that. HMRC has said that it will not set a deadline for how soon money must be used, although that ambiguity creates issues in itself. If the rules are unclear, HMRC could later decide that a gift has not been applied appropriately and withdraw the tax relief, undermining confidence that legacy gifts to charities will remain tax-free. Perhaps the Minister could give the Committee some clarity on that point, and on how HMRC will determine what counts as timely or appropriate application of funds. There is also a concern about the administrative burden it may place, particularly on smaller charities, which will have to prove that each legacy received has been properly applied to charitable purposes, even when the money is placed in long-term endowments or reserves. The Charity Finance Group warns that the changes could mean more record keeping, compliance checks and bureaucracy, taking money away from frontline charitable activities and towards administration. I do not think that anyone would wish to see that. I do not know whether the Minister has anything more to add on that complexity. Adding complexity could also make life harder for executors and delay the administration of estates, which could affect the timing of cash flows to charities at a time when finances in the sector are under considerable pressure, and income is critical for them to do their job. There is also a risk that wealthier donors might think twice about leaving legacies to smaller charities, if they think that the charity might struggle to comply with HMRC rules. I am really asking for the Minister’s assurance that HMRC will take a sensible and proportionate approach, particularly with smaller charities that are seeking to do the right thing in applying these rules. We all want to avoid the potential risk that this measure could deter charitable giving, when that is clearly not the intention. It is important that the concerns raised by the sector are aired in the Committee, and it is our role to do so.

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13. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (Second sitting)

    I rise to speak clause 53 and new clause 7, which was tabled in my name. My comments will reflect submissions from people involved in the charitable sector and my discussions with them. The clause extends the allowable purpose to all categories of recognisable charitable investment—at present, it applies to only one, but it will cover all 12. The Institute of Chartered Accountants in England and Wales has raised a suggestion that the test be reframed from “for the sole purpose of” to “wholly or mainly” to the benefit of the charity. The concern is that there could be increased obligations for compliance on trustees who have to demonstrate that their every investment in, for example, their portfolio was made for the benefit of the charity rather than an ancillary purpose therein. Was that more flexible approach something that the Government have considered, and if so why did they chose to reject it?

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14. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (Second sitting)

    I rise to speak to clause 54 and to new clauses 8 and 9 tabled in my name. The clause makes significant changes to how tainted donations are treated. At present the donation is considered tainted only if it was made with an improper purpose. This clause replaces the motive-based test with an outcome test. If someone connected to the donor under the new regime receives financial assistance from a charity, such as a grant, guarantee or loan, the donation will be deemed tainted regardless of the donor’s intent. I have tabled new clause 8 to require the Government to publish a report on how the change affects legitimate charitable giving, or genuinely tackles tax abuse. New clause 9 would require a review of the implementation of the new outcome test after two years and would assess whether it proves to be clearer than the existing purpose test. The Minister and the Government said that this measure is about tightening anti-avoidance rules and the challenge of proving intent. But I have been approached by the Charity Finance Group, which represents over 1,400 organisations and manages one third of the sector’s £20 billion annual income, and it has raised concerns around the change. It warned that the outcome test could unfairly penalise both donors and charities for results outwith their control. For example, a donor could make a genuine good faith contribution only for a charity months later to make a routine investment or financial arrangement that inadvertently benefits a linked person. That donor could then find themselves caught by the anti-avoidance rules without ever having done anything wrong. That could cause uncertainty and raise concerns about people leaving legacy gifts that the charity sector relies on. It is not just the charity and that one body. The Institute of Chartered Accountants in England and Wales has warned that donors may have limited influence over the outcome once the donation has been made. It, too, questions the fairness and practicality of shifting from a motive to an outcome test. Indeed, it proposes that the existing rules are not altered for that precise reason. We tabled the two new clauses to introduce proper scrutiny of the measures and ensure Parliament understands the effect on the charitable sector and whether donations continue to be given. Does the Minister consider there is a risk that shifting to such an approach could have the effect that the charitable sector has set out? If so, will she commit to perhaps providing some practical guidance, with examples that charities and their compliance teams could look at so that they can see that charitable giving is not undermined? None of us on this Committee would want to do anything that would undermine the ability of charities to raise money and disincentivise anyone from giving money for fear that they might be caught inadvertently by rules when they have done nothing wrong.

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15. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    It is a pleasure to serve under your chairship, Sir Roger, and on the Committee considering this 536-page doorstop of a Bill. We are grateful for the written contributions and evidence provided to the Committee, but I think the usual channels should consider having oral evidence sessions for future Finance Bills, so that people can make important representations on significant pieces of legislation. I will turn to clause 13 and new clause 24 tabled in my name. We need to have an enterprise economy that incentivises investment. The tax regime clearly has an important role to play in helping to achieve that, and in doing so, backing much needed growth in the economy. Clause 13 amends the Income Tax (Earnings and Pensions) Act 2003 to expand the enterprise management incentives scheme. That scheme helps attract, keep and motivate staff by allowing employees to buy shares in the company with tax advantages. That includes no income tax or national insurance contributions at the time of grant and exercise, with gains eventually being taxed under the more favourable capital gains regime, rather than as income tax. The changes in the clause should make it easier for start-ups and growing companies to use the enterprise management incentives scheme, helping them reward staff and link employees’ success to the company’s growth. That is something that we support and the British Private Equity and Venture Capital Association has also welcomed the change. The clause increases the company options limit from £3 million to £6 million, raises the gross asset limit from £30 million to £120 million, and doubles the employee limit from 250 to 500. It also extends the exercise period to 15 years. These are all welcome changes. However, one important element that is not due to change under these provisions is that the scheme allows qualifying companies to grant employee share options up to a maximum value of £250,000 per individual. Has the Minister considered going further and raising the cap beyond £250,000 to attract the brightest and best to grow businesses? In its report on competitiveness, published yesterday, TheCityUK states that, “the UK’s tax schemes such as…Enterprise Management Incentives (EMI) offer lower relief thresholds and tighter eligibility than international equivalents such as the Qualified Small Business Stock regime in the US, weakening incentives to scale and retain activity domestically.” I have tabled new clause 24, which would require the Government to assess and report to Parliament on the impact that the changes have on the recruitment and retention of skilled employees in qualifying companies, on high-growth and innovative companies and on the Exchequer. The Minister referred to the tax information and impact note, but clearly that is a forecast of what the Government hope will happen, not a review of what has actually happened. I think that will be a debate that we have many times as we consider the Bill: a TIIN is not a review of what has actually happened. The numbers that the Minister gave may be higher or lower, but we need to have a post-implementation review. According to the Budget 2025 policy costings, the objective is to increase eligibility to allow scale-ups, as well as start-ups, to access the scheme. That is, of course, something we support. Will the Minister commit to keeping the scheme under review to ensure it is delivering on its aims to support high-growth firms and to consider whether further action, such as on the individual threshold, is needed? Given the substantial investment, can the Minister clarify what behavioural assumptions underpin these projections? How many companies just above the existing threshold are expected to utilise these expanded limits? The BVCA has said that the enterprise management incentives scheme is “long overdue for reform: high growth companies are often unable to grant EMI options due to the constraints of the £30m gross assets and 250 employee limits.” Does the Minister have figures showing how much these limits have actually restricted growth?

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16. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    Clauses 14 and 15 are a story of two halves. As the Chartered Institute of Taxation rather adeptly put it—we are grateful for its support in scrutinising the Bill—these changes give with one hand and take with the other. We support clause 14, but we have doubts about clause 15. Both clauses deal with our risk capital schemes—the enterprise investment scheme and venture capital trusts. EIS was introduced in the UK in 1994 to stimulate economic growth and, along with VCTs, these Government-backed schemes encourage individuals to invest in smaller high-risk trading companies by offering tax reliefs on their investment. As a former adviser in the Department for Business, Innovation and Skills, I helped to develop these schemes, as well as the seed enterprise investment scheme. I recognise their importance. As the venture capital industry has noted, these are essential tools in unlocking private capital for early-stage, high-growth UK businesses, which we all support, particularly in the knowledge-intensive sectors such as life sciences, clean energy and deep tech; however, companies now routinely require £20 million to £30 million in funding before they start to sell their products. The previous limits had prevented UK investors from following their initial investment with more capital, forcing businesses to turn to overseas capital too early. That is a problem I think we all want to fix. The main difference between the schemes is that with EIS an investor buys shares directly in an eligible company, whereas with VCTs the investor buys shares in a listed fund-like vehicle, which then spreads their money across a portfolio of qualifying companies. These clauses increase the annual and lifetime investment limits for the EIS and VCTs in Great Britain and raise the gross asset thresholds for qualifying companies. Clause 14 increases the annual and lifetime investment limits for the EIS and VCTs, and raises gross asset thresholds. These limits have not been uprated since 2018 for knowledge-intensive companies and 2015 for other companies. Now, all limits are being doubled, which is welcome. As we have heard, for both schemes, the limit will rise from £10 million to £20 million. The total amount that can be raised over time will increase to £40 million for those knowledge-intensive firms. The gross assets yield for qualifying companies will go up to £30 million before a share issue and £35 million thereafter. TheCityUK has said that schemes such as EIS remain vital for crowding in early-stage finance and these changes are welcomed by the industry. Clause 15 heads somewhat in the opposite direction. This clause reduces the rate of income tax relief for investment in VCTs from 30% to 20%. This is where our doubts begin to grow. The 2025 Budget policy costings reveal a calculated trade-off. The increased limits in clause 14 will cost the Exchequer £60 million in 2027-28. Meanwhile, the reduction in VCT income tax relief will raise £125 million in the same year, delivering a net yield of approximately £65 million. The policy costings state that this rate reduction is intended to “better balance the amount of upfront tax relief…and ensure funds are targeting the highest growth companies”, but the costings’ own assumption that “investors alter or reduce the way they invest into VCT” is an acknowledgment that the relief cut will dampen investor appetite. I am concerned by how much that tax increase will reduce investment in these high-growth companies that we all support. The British Private Equity & Venture Capital Association has been explicit about its concerns, warning that this reduction “could lead to a decline in fundraising that would impact the high growth and high-risk investments that the Government is looking to encourage”. VCTs are a key part of the UK’s capital mix, providing one of the few consistent sources of long-term equity for early-stage and scaling companies. Any reduction in their ability to raise funds would directly affect the pipeline of innovative businesses that the UK needs to grow. The reduction in VCT relief to 20% creates a fundamental risk to venture capital funding, precisely when scale-ups face capital constraints. For early-stage companies dependent on VCT funding, the reduced relief translates directly into a higher cost of capital and reduced funding availability. The Budget relies heavily on revenue raising from less visible and more complex parts of the tax system. This VCT change exemplifies that approach, shifting costs to venture investors rather than implementing transparent broad-based taxation. New clause 1 would require the Chancellor to report on the impact of the cuts to VCT allowance on early-stage investment volume, investor participation and international competitiveness. Given the Government’s own admission that this will alter investment behaviour, such reporting is essential, and I reiterate that a TIIN does not review what actually happens in practice. Amendment 29 would simply remove the provision in clause 15(2) that reduces the rate relief from 30% to 20%, keeping the relief at its current level to support investment in high-growth firms. I believe both amendments would be supported by industry and, subject to what the Minister says, I intend to press amendment 29 to a vote. The Government are expanding VCT investment limits while simultaneously cutting the relief to 20%. How would the Minister address the concerns of the investment sector that the combined changes will dampen investor appetite for venture capital trusts at the very moment we need to encourage them?

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17. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    As the Minister says, clause 16 addresses a specific but important matter by permitting employers to amend existing company share option plan and enterprise management incentives option agreements, to allow PISCES trading events to serve as exercisable events without sacrificing the valuable tax advantages. Employers frequently offer share options to employees in recognition of their service and commitment, and to grow their businesses, and when employees exercise such options, they naturally face income tax and national insurance consequences. To encourage this form of employee ownership, successive Governments have introduced tax-advantaged schemes, including CSOP and EMIs, that provide relief from those taxes when certain conditions are satisfied.

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18. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    We will look sympathetically on the hon. Gentleman’s new clauses if he chooses to press them to a vote. I have constituents who were heavily pressured by HMRC and ended up settling, which left them at a considerable financial loss, so I share his concern that those people, who were effectively bullied by HMRC, will now not get the same support as people who held out.

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19. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    In her opening remarks, the Minister referred to promoters of disguised remuneration schemes not being eligible for this settlement scheme, which I welcome. Perhaps she could update the Committee on whether HMRC is proactively pursuing such individuals, who caused such distress to my constituents and, of course, to people across the country who were sold schemes, advised that they were legitimate and had been agreed with HMRC, and then discovered they were not and have lost their homes and their life savings as a result.

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20. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    I want to get on the record that I do not have a problem with TIINs, but they serve a different purpose from reviewing legislation after the event. I would not want any Treasury officials to feel that the Opposition do not value TIINs. I will speak to clauses 28 and 29 as well as new clause 2, which is tabled in my name. Capital allowances are one of the primary mechanisms through which our tax system supports business investment. They enable firms to deduct the cost of purchasing plant and machinery from taxable profits, thereby reducing their tax liability and helping them to invest and grow, which we all support. The annual investment allowance is perhaps the most straightforward example. It allows businesses to deduct the full cost of most plant and machinery up to £1 million annually, in the same the year that the expenditure occurs. Beyond that, there are the first-year allowances with no annual cap. The most generous of those is full expensing, which the Minister referred to, which provides a 100% deduction for qualifying main rate assets and a 50% allowance for certain special rate assets. Those measures were introduced by the previous Conservative Government in order to stimulate faster investment and drive up what have been, I think it is fair to say, historically low levels of business investment throughout all parties’ periods in government. I think that we are all committed to try and address that. Where businesses cannot or choose not to utilise those more generous allowances, they rely on writing-down allowances. They spread tax relief over several years by permitting a set percentage of the remaining pool balance to be written off annually, with assets allocated to either a main rate or special rate pool, depending on their classification. Clause 28 reduces the main rate from 18% to 14% a year, while the special rate remains at 6%. The relevant date is 1 April 2026 for corporation tax purposes, and 6 April 2026 for income tax. For periods straddling that change, a hybrid rate will apply. New clause 2 would require the Chancellor to produce a report that examines the impact of those reductions on business investment levels, capital investment sector employment, the manufacturing sector, small and medium-sized enterprises and public finances. The 2025 Budget policy costing document presents that as a part of capital allowance reform, but the reduction in the main writing-down rate will alter the cash flow position of capital-intensive businesses, slowing the rate at which they can recover investment costs through tax relief. Businesses with substantial brought-forward main pool balances will see their tax relief decelerate, with corresponding impacts on cash flow and the overall tax benefit. For companies planning significant investment, timing has now become more important. This is yet another structural tax increase on businesses with large asset bases, which will now recover their investments more slowly. Make UK has described this Budget as “a case of two steps forward one step back for manufacturers.” The 4% in reduction in the writing-down allowance is undeniably bad news for business. It is little wonder that polling by the Institute of Directors reveals that four in five business leaders view this Budget negatively, and I think that those findings were replicated across the Federation of Small Businesses, the CBI and many other business organisations. The delayed recovery of capital costs will constrain reinvestment in modernisation and automation, precisely when UK manufacturers are already facing strong headwinds, not least from the very high energy costs that they face in this country. The reduction from 18% to 14% will diminish the speed at which businesses can recover these costs. Has the Treasury assessed the impact on business investment intentions, particularly for small and medium-sized enterprises in manufacturing and logistics? If not, I am sure that the Minister looks forward to supporting new clause 2. Clause 29 is an attempt to balance the changes made in clause 28. It introduces a new 40% first-year allowance from 1 January 2026 for new, unused main rate plant and machinery. The new allowance expands relief to unincorporated businesses and firms that buy assets to lease out, which do not qualify for full expensing or the 50% special rate allowance once they go over the £1 million annual investment allowance. The explanatory notes highlight that this new allowance represents an expansion to include leasing, which we welcome—those activities that have traditionally been excluded from such reliefs. The allowance is not available for special rate expenditure, second-hand or used machinery, expenditure under disqualifying regimes or general exclusions. We support the expansion set out in this clause. While these measures may have good aims, introducing an additional rate adds some complexity to the system. There is also the length of the Finance Bill that we are considering—536 pages of dense text—and that we expect businesses and individuals across the country to comply with, else HMRC will come after them. I urge the Government to monitor closely the impact on business investment and to look at options for a more streamlined or neutral capital allowances structure in future. What steps are being taken to tell businesses about these new allowances and freedoms they have to invest in leased assets—for example, by working with business organisations to get the word out? Opposition Members will certainly do that with businesses in our constituencies. The new allowance will provide some up-front support for qualifying new investment, partly offsetting the impact of reducing the main writing-down rate to 14%. Once again, the Government are giving with one hand and taking with the other. The uplift will be of use for unincorporated and leasing businesses, but for most other businesses with historical or non-qualifying assets, there is no uplift at all. They simply face a slower rate of relief, going down to 14%, stretching allowances over a longer period and affecting their cash flow. The Minister referred to Office for Budget Responsibility forecasts that suggest these combined measures will cost businesses more than £1 billion in 2026–27, rising to around £1.5 billion a year thereafter. That is a significant burden at a time when companies are grappling with weak investment and, to put it bluntly, the higher costs imposed in the first Budget. The £20 billion jobs tax has had a big impact, as we saw in the data earlier this week and as we see in the number of graduates who are struggling to find jobs. As I say, the inclusion of leasing is welcome, but we do think there is benefit in reviewing those measures after the event and coming back to Parliament to explain what has happened.

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21. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    As we have heard, clause 30 will extend the 100% first-year allowance for expenditure on zero emission cars, including EVs, and EV charging points. As the Minister said, the extension runs for a year to March 2027 for corporation tax and April 2027 for income tax purposes. Our new clause, consistent with other amendments that we have tabled, would simply ask the Chancellor to come back and report to Parliament, and to the public, on the impact of her measures. I do not really understand this reluctance to understand the actual impact of the measures. As part of the Government’s broader regulatory reform approach, they seem keen on post-implementation reviews, but the Treasury holds out alone against its homework being scored, it would seem. We want to consider whether long-term support should continue to be provided to maintain UK competitiveness in green technology. It is, in essence, a call for evidence that could make a difference to business confidence and investment. The allowance was first introduced in 2002 for low emission cars, and the threshold was tightened over time, reaching zero emissions from April 2021. The extension continues that policy, but only for a year, and the Government’s own costings suggest that the extension will cost £145 million. Businesses planning multi-year fleet transitions and charging infrastructure investments face repeated cliff edges. Each year, a one-year window does not help a company planning to electrify its fleet in two years’ time; it simply rewards those who are able to accelerate the investment within the next 12 months. Does the Minister recognise that it creates a stop-start approach that could discourage investment, undermine industry confidence and, ultimately, slow the UK’s transition to clean, green technology? That is odd when, in many ways, the Government are accelerating full throttle towards 2030 electrification across the grid. Members may have pylons and other pieces of grid infrastructure being dumped in their constituencies, with no public recourse, in the name of the Energy Secretary’s net zero goals. It is worth asking whether their policy is joined up if it includes these incremental extensions. In that spirit, I have tabled new clause 3 so that hon. Members can judge whether the Government have a coherent approach. It would require the Chancellor to assess, transparently and on the record, whether a long-term support system is justified to keep Britain competitive in the global race for green manufacturing. A formal assessment would give Parliament and businesses the information they need to plan ahead. In the debate on clause 11, the Minister referred to the long-term certainty provided by committing to a 25% corporation tax rate for this Parliament. Of course, that is not actually in the legislation, but we welcome that commitment and the greater certainty, and similar certainty could be given in this area. A formal assessment could also ensure that public money is being used wisely and that policy provides the certainty to unlock the investment we all want to see. Given their 2030 obsession, why have the Government again chosen a one-year extension that provides limited certainty for fleet operators or for the charging infrastructure sector? I see that the hon. Member for Banbury is getting ready to dive into the debate. Will the Minister support new clause 3 and commit to a proper assessment of the lasting framework that is needed to secure Britain’s place in the green technology economy of the future?

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22. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    The hon. Member and I agree about the importance of long-term certainty. People who are watching the proceedings may wonder why we did not just table an amendment to extend the scope to 2030, but due to the narrowness of the measures passed by the House, we are unable to do so. As I weigh up whether to push my new clause to a vote in a few weeks’ time, will the hon. Member consider supporting it?

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23. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    As the Minister said, these clauses are mainly technical, tidying-up measures, but they are worthy of debate none the less. Clause 31 clarifies the corporation tax treatment of payments made in return for the surrender of research and development expenditure credit, audiovisual expenditure credit or video games expenditure credit for payments made on or after November 2025. This technical clarification ensures that, when companies sell or surrender tax credits, the accounting treatment is consistent and correct. R&D expenditure credit has been in place since 2013 to support companies carrying out R&D, and these creative industry expenditure credits will fully replace the old film, high-end TV, animation, children’s TV and video games tax reliefs from April 2027. At the moment, there is no agreed approach between tax authorities and companies on how to treat payments received when these credits are surrendered for corporation tax purposes, which has created uncertainty. Clause 31 will hopefully put that beyond doubt by setting out a clear tax treatment in law, and HMRC will update its guidance manuals to reflect the new rules. Does the Minister have any figures—I do not have the TIINs to hand on this one—on whether that uncertainty has cost companies, or cost the Government, in lost revenue? Clause 32 corrects transitional rules between the video games tax relief and the video games expenditure credit to ensure that the new expenditure credit works fairly for games that are moving over from the old relief. It corrects how the expenditure credit is calculated for transitional games—those that already have tax relief claims and then opt into the new scheme—so that companies do not get too much or too little relief, simply because the old regime used European expenditure while the new one uses UK expenditure. In effect, clause 32 ensures that companies switching schemes do not get double relief or under-relief. Can the Minister provide an estimate of how many video games development companies will be affected by this transitional correction, and whether any have suffered financial detriment under the previous rules? Clause 33 makes changes to the special credit for visual effects, which is part of the audiovisual expenditure credit, as the Committee will be aware. It prevents the calculation for additional credit from producing incorrect results, correcting anomalies in the visual effects credit calculation. The explanatory notes explain that, without this fix, certain combinations of expenditure could generate incorrect credit amounts or negative values, so clause 33 ensures that the scheme operates as intended and that the special credit scheme is neither more nor less generous than intended. Does the Minister have any figures on how many production companies have experienced calculation errors as a result of the previous rules?

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24. 27 Jan 2026·Parliament·James Wild

    Finance (No. 2) Bill (First sitting)

    Clause 34 will amend the Corporation Tax Act 2009 to clarify restrictions on relief for overseas R&D applied to companies across the entire United Kingdom, including Northern Ireland and Great Britain. It applies retrospectively on claims made on or after October 2024. It puts beyond doubt that the geographical restriction on R&D expenditure credit relief applies uniformly across all jurisdictions. Can the Minister confirm that, notwithstanding this clarification, exemptions under the enhanced R&D intensive support scheme still apply to firms based in Northern Ireland?

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25. 27 Jan 2026·Parliament·James Wild

    Support for Businesses

    The Chancellor promised hospitality firms that she would lower their taxes, but her business rate raid is hammering every town, village, city and high street. This is not just an attack on pubs; hotels, cafés, music venues and many more are being hit. It is two months since the Budget caused huge worry for these businesses, and we await details of this latest U-turn, but the key question is: does the Chancellor get it? Does she get that it is not just pubs but hospitality, leisure and retail businesses that need support because of her terrible choices?

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26. 27 Jan 2026·Parliament·Gregory Stafford

    Medical Training (Prioritisation) Bill

    The Secretary of State mentioned the need for more medical staff across the world and, of course, in this country as well. At the general election, he pledged to double the number of medical school places by 2030. Is that still a commitment, and how far has he got with it?

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27. 27 Jan 2026·Parliament·Gregory Stafford

    Medical Training (Prioritisation) Bill

    At the heart of the Bill is a simple test: does the Bill improve care for patients? Every delay in training, every cancelled clinic and every rota gap caused by workforce instability ultimately lands on the patient. It means longer waits, greater travel distances and, in too many cases, care that comes too late. I was recently contacted by my Farnham and Bordon constituent, Dr R, as I will call her, who is a UK-trained medical graduate. Like thousands of others, she completed her studies in good faith, expecting a clear and credible pathway into the NHS. Instead, she now finds herself in a system where non-training posts are disappearing, competition ratios for training places are rising sharply and the holding pattern roles that once allowed junior doctors to remain clinically active while reapplying have all but vanished. This is not a niche concern affecting a handful of individuals; it is a systemic failure that directly impacts patients. When trained doctors are unable to progress, fewer reach consultant and GP level in the years ahead. Services become overstretched, continuity of care is lost and waiting lists grow even longer. That is why I support the intention behind the Bill. Prioritising UK medical graduates, ensuring that the UK foundation programme is genuinely delivered in the United Kingdom and restoring confidence in the medical training pipeline are all necessary steps if we are serious about rebuilding NHS capacity for the benefit of patients. I have supported amendments to this Bill because they strengthen those aims. They ensure that UK medical graduates are properly recognised as such, that training programmes are UK-based in substance rather than just name, and that allocation of training places is grounded firmly in merit, clinical knowledge, aptitude and performance. Patients, quite rightly, expect their doctors to be selected on ability and doctors expect fairness, and those principles should command support across this House. I also welcome new clause 2, tabled by my hon. Friend the Member for Runnymede and Weybridge (Dr Spencer), which addresses growing concern among doctors and patients about the erosion of merit-based progression. When merit is undermined, morale suffers; when morale suffers, retention suffers, performance suffers, and ultimately patient safety suffers. As such, the context of this Bill matters. Resident doctors have received cumulative pay rises approaching 30% over recent years—among the highest in the public sector. Despite this, industrial action has continued. It is increasingly clear that the BMA is determined to extract every possible concession from the Government, using sustained disruption as leverage. While I do not align myself with some of the Secretary of State’s more inflammatory language, I do share the realisation he has belatedly reached: that repeated above-inflation pay settlements have not brought this dispute to an end, and that further concessions risk rewarding brinkmanship rather than restoring stability for patients. However, in pressing its case so aggressively, the BMA has inadvertently shone a spotlight on a genuine and serious problem in the system: a broken training and progression pathway that leaves UK doctors without secure routes into the NHS. That problem is real, it affects patients, and it must be addressed regardless of the outcome of pay negotiations. That is precisely why this Bill matters and why it must not be treated as a bargaining chip, yet that is exactly the risk created by the way in which the Bill is drafted. It will come into force only when the Secretary of State gives permission. In theory, that may appear sensible; in practice, it allows a patient-benefiting reform to be delayed, diluted, or deployed as leverage in negotiations. Before Christmas, Ministers openly discussed this legislation in the context of talks with the BMA. The implication was clear: progress on training reform was conditional. Now, months later, with industrial action ongoing, it appears that the same dynamic may be emerging again. That approach undermines confidence among doctors and, far more importantly, undermines care for patients. If a measure will improve the NHS for patients and doctors alike, it should be implemented because it is right, not because it is tactically useful. That leads me to a number of questions for the Minister to answer when she responds, which are all grounded in patient outcomes. Patients need capacity and certainty. They need more doctors progressing through training, not further delays and ambiguity. If the Government genuinely believe that prioritising UK graduates will strengthen the workforce, why is the commencement of this Bill discretionary at all? What assurance can the Minister give patients that these reforms will not be delayed indefinitely while negotiations continue? Patients have already endured significant disruption from industrial action—hundreds of thousands of appointments and operations have been cancelled or rescheduled. Without further pay concessions, can the Minister explain how this Bill will reduce the risk of future disruption, or is she effectively accepting that patients may face continued instability? There is also the question of scale. The BMA itself has said that the Bill does not go far enough to close the gap between applicants and available training posts. What assessment has been made of how many UK graduates will still be unable to access foundation or specialty training even after this legislation is passed, and what will that mean for patient access to care in the coming years? Patients in many parts of the country already struggle to access GPs, psychiatrists and emergency medicine specialists. How will the Secretary of State and the Minister ensure that these reforms do not inadvertently worsen shortages in hard-to-recruit specialties or underserved areas? Finally, there is the question of credibility. If this Bill is genuinely good for patients, good for workforce stability and good for the NHS, why should its implementation depend on a ministerial decision at some undefined point in time? Why not give doctors and patients certainty by bringing it into force immediately on Royal Assent? This House has a responsibility to put patients first, not leave patient care hostage to industrial negotiations. That is why I strongly support amendment 1, which would ensure that the Bill comes into force at the moment of Royal Assent. It removes unnecessary delays, ambiguity, and the risk that these reforms will be postponed indefinitely while workforce and pay disputes continue. UK medical graduates, hospitals and training bodies need certainty that the rules will apply from day one, so that allocations, protections for those trained on military postings, and fairness measures can begin to operate without delay. The amendment would ensure that reforms designed to strengthen transparency, meritocracy and the workforce will take effect when they are needed most. That clarity is particularly important given the absence of a published NHS workforce plan. We need certainty for doctors that delivers stability for services, which in turn delivers better patient care and better outcomes. That is the standard by which this Bill should be judged, and it is the standard it must meet.

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28. 27 Jan 2026·Parliament·Greg Smith

    Women’s Safety: Walking, Wheeling, Cycling and Running

    It is a pleasure to serve under your chairmanship, Ms Jardine. I congratulate the hon. Member for Lowestoft (Jess Asato) not just on securing this important debate, but on the powerful way in which she opened it. It can be described only as a sobering debate that requires the Government’s full attention, and that must come not just from the Department for Transport but, as others said, from other Departments, too. I thank the hon. Members for Bath (Wera Hobhouse), for Bolton North East (Kirith Entwistle) and for North West Leicestershire (Amanda Hack) for sharing their personal experiences. It is completely unacceptable that anyone should have to face what they described on the streets of this country. I equally agree with the hon. Member for Calder Valley (Josh Fenton-Glynn) that so-called low-level offences should be stamped down on incredibly forcibly. He is right—I have long argued along similar lines—that it is essential because so-called low-level crimes lead to more serious and potentially fatal crimes in the future. It is therefore absolutely essential that they are clamped down upon incredibly hard. The method by which anyone, and particularly women, chooses to travel should not be dictated by how safe they feel. Everyone should feel safe walking, running, cycling, wheeling, driving or riding a horse—we had a good debate about horse riding last week, and it should have been added to the title of this debate, because it is incredibly important in rural communities such as mine. It is clear that the challenges of securing women’s safety are an obstacle to an array of activities that women might want to do, but feel unable to do so. It is incredibly concerning that, according to Cycling UK, 23% of women cite harassment or intimidation as a reason not to cycle. The data on running is even starker. Research published in 2023 found that almost three quarters of women in the United Kingdom change their outdoor activity routines during winter, with many doing so because they feel unsafe. Separately, survey data from SportsShoes.com, which is not a website I was particularly familiar with until I began my research for this debate, found that 48% of women had felt unsafe while running, compared with 36% of men. Similarly, 70% of women had experienced an intimidating incident while running, including 22% saying that they had been followed and 21% reporting that they had been beeped at by someone in a car. Such behaviour on the streets of this country is deeply unacceptable. Even though it is challenging to point to a single source, data from a variety of organisations highlight that a considerable number of women experience behaviour that is not acceptable—indeed, it is clearly despicable—in our society. The idea that someone who is merely trying to run or cycle should be followed or harassed is clearly wrong and must be stopped. Therefore, to address both the safety of women while cycling, wheeling, walking or running, and concerns about harassment, we must make sure that we embed enforcement as the underlying principle of safety strategies. That must involve having sufficient numbers of police officers located in the areas where women feel most unsafe. That is a challenge, given that we are currently seeing a reduction in the number of police officers on our streets. The hon. Member for Richmond Park (Sarah Olney) gave a particularly stark example. The thought that a park such as Richmond Park, which is so suited for walking, running, cycling and all sorts of activities, is no longer to be policed should horrify all of us in this House, no matter what political party we belong to. Improving the safety of women should also involve following up on incidents properly. For example, a small minority of drivers demonstrate truly unsafe behaviour and put women at risk. We have strong rules about what constitutes dangerous driving, and those rules must be enforced where people have broken the law. However, the rules for dangerous driving must apply equally to those who behave in an unacceptable way by verbally abusing people, beeping their horn or whatever it might be. To do that, we need effective funding for our police forces, which is why my party has specifically said that we would provide £800 million to deploy 10,000 new police officers in hotspot areas where crime is most likely to occur. I appreciate that hotspot policing might be less impactful for groups such as cyclists, who travel much greater distances than other people, but in urban environments or in places such as Richmond Park, which we have already heard about, there are often particular locations and areas that dissuade people from running and walking. The more we can do to target those locations—where crime, particularly crime against women, is more likely—the more we can instil trust and a sense that such activities are safe. Therefore, can the Minister say what cross-Government work has been conducted by her Department to prioritise the safety of women and girls when they are engaged in active travel and to feed into the Government’s strategy on preventing violence against women and girls? Also, can she make a commitment that her Department will engage with local police forces to ensure that they are monitoring areas where women feel most unsafe? Also, I understand that the consultation for the third cycling and walking investment strategy says that “Investment in well-lit, safe, high-quality walking, wheeling and cycling routes increases feelings of personal safety, as well as improving road safety”. I think we can all agree with the sentiment and the principle that we want particular areas to have improved lighting, in order to improve safety. As with many aspects of road safety, targeted measures that focus on the most dangerous areas will rightly have support from Members across this House. I am aware that issues such as improved lighting form part of the much broader calls for clear targets on what organisations such as Cycling UK describe as high-quality cycling infrastructure, which are made alongside calls for appropriate levels of spending. That is all important. And from our time together on the Transport Committee in the last Parliament, I know the Minister is a long-standing supporter of active travel in general and of cycling in particular. There is always a difficult balance to be drawn between making our roads safe for cyclists and making them too difficult for other modes of transport to use, or even prohibiting other modes of transport. Nevertheless, I hope the Government can find the appropriate balance by making cycling safer for women without making it more difficult for those same women to use their cars for other journeys. One request from Cycling UK and a range of other road safety organisations is to improve understanding of the 2022 changes to the highway code. These organisations have been clear about welcoming the changes as an important step in improving the safety of pedestrians, cyclists and other road users, but the knowledge gap remains in the public’s awareness of these changes. All in all, as I said at the start of my remarks, this needs a whole-Government approach. The safety of women cannot be put on the back-burner or into a footnote; it must take centre stage across multiple Government Departments. I look forward to hearing the Minister’s commitments this afternoon on how she will be leading that in the Department for Transport and across the whole of Government.

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29. 27 Jan 2026·Parliament·Gareth Bacon

    Commonhold and Leasehold Reform

    I thank the Minister for his remarks and for advance sight of his statement. Progress on leasehold reform is to be welcomed. Labour promised that when it stood for election 18 months ago, so it is about time it got on with it, as the previous Conservative Government had started to do. The previous Conservative Government began the process of fundamental reforms to the existing system of leaseholds by making it easier to extend a lease or to buy a freehold, increasing the standard lease extension time to 990 years, and giving leaseholders greater transparency over their service charges. His Majesty’s Opposition remain committed to giving leaseholders a fair deal, want householders to have security for the future and will continue to hold the Government to account on that. The Government made big promises to leaseholders at the last election. Do they believe that the Bill is the summit of their ambitions? What about the Leasehold and Freehold Reform Act 2024? What are their plans to implement secondary legislation? There are opportunities to improve leaseholder situations that are available to the Government now. Why have they not implemented those changes? Surely, if they were serious about reform for leaseholders, they would have picked up the 2024 Act and run with it, rather than doing nothing until now. The Minister just said: “I have made clear to the House on previous occasions, the last Government’s Leasehold and Freehold Reform Act contains a number of specific but serious flaws that prevent certain provisions from operating as intended and that need to be rectified via primary legislation.” He went on to say: “While not included in the draft Bill, our intention is to rectify those flaws in primary legislation.” Perhaps he could tell us what those flaws are. If the Government have already identified them, why are the corrections not included in the forthcoming Bill? Surely now would be the time to rectify them. So if not now, when? I would be remiss not to comment on one of the central principles of housing reform: there actually needs to be some housing in order to reform it. The Labour Mayor of London is delivering the lowest house building in London since 2009, while Labour’s national housing delivery is nowhere near where it needs to be to meet its 1.5 million homes target. What is Labour doing to ensure that there are strong incentives to build more? Where is the second planning Bill that the Government briefed out to the media that they will need to introduce because of their failure to get the planning reform right first time? The Conservative party is pro-development, which is why we have announced both a plan to review the London plan to improve on Labour’s failings in London and to ensure that national development is done on a brownfield-first approach. Now, it is true that ground rent is an additional cost to leaseholders, but it is reported that the Chancellor is against capping ground rents because she believes it will deter pension fund investors. What does the Minister have to say to that? The Government are claiming that these measures will reduce people’s bills, which would of course be welcome, but if leaseholder ground rent bills are simply replaced by soaring council tax bills, with some local councils now facing more than 30% rises in council tax due the Government’s grossly unfair funding review, how will people be better off? In inner London, which has a high proportion of leasehold flats, residents in councils such as Wandsworth, Westminster and Kensington and Chelsea are facing the double whammy of staggering rises in council tax and a council tax surcharge on top. Are the Government in fact claiming to cut a cost on one hand, while knowingly replacing it with even more costs on the other? I would be grateful if the Minister answered those points in his reply. We will scrutinise the Government’s forthcoming commonhold and leasehold reform Bill, and we will hold the Government to account on their promises on leasehold reform and housing. We look forward to studying the details, and to the debates that will follow.

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30. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Fifth sitting)

    I am grateful to the Minister for his clarification. When I asked the question and he, with alacrity, answered, I did catch the expression on one of his official’s faces; I have to say that I have, on occasion, found myself in that position in the past, so I sensed what might have been coming. I have to say that I am deeply disappointed. Although it is important that stakeholders are engaged, this legislation has been some time in the making. The licence is at the heart of how GBR will operate, so the fact that not even a skeleton draft will be made available to hon. and right hon. Members as the Bill continues its passage through this House is deeply concerning. I will speak at greater length when we get to schedule 1, but we are effectively being asked to give the Government a blank cheque, based on assurances of intent, without actually seeing the detail of the legislation.

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31. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Sixth sitting)

    In the context of efficiency and cost, I want briefly to pick up on a point made by my hon. Friend the Member for South West Devon. What assessment have the Government made of the financial cost of bringing together a whole range of diverse terms and conditions and salary structures, from multiple train operating companies, into GBR?

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32. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Sixth sitting)

    The hon. Gentleman is making a very good point, in the context of infrastructure and operating companies coming together—although it also applies more broadly—about the tightness of those diagrams and that scheduling. On East Midlands Railway, although normally the trains are short-formed, we regularly see a 10-car train that is packed in the front five carriages because the back five have to be locked, completely empty, and travel to London with no one sitting in them because there is not a member of staff to staff them. That is because the diagrams are so tight that there is no contingency to put extra staffing in place at short notice when someone does not turn up.

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33. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Sixth sitting)

    Will the Minister confirm that the advice it will be obliged to seek will be published? If it is private advice, it has no teeth whatsoever, because the Secretary of State could accept it or refuse it, as could GBR, and no one would ever know. Would that advice be public?

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34. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Sixth sitting)

    I thank the Minister very much. I cannot imagine where that flash of inspiration and recollection came from, but I am grateful to him for the clarification.

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35. 27 Jan 2026·Parliament·Edward Argar

    Railways Bill (Sixth sitting)

    I will not detain the Committee for long. As ever, I am grateful to the Minister for his succinct explanation. However, I have two concerns; while he may be able to reassure me on these, I certainly think they need an airing. First, how does he propose to ensure that the funding period is properly aligned with a spending review period? I have seen the challenges faced in government when there is a misalignment, or where one period overlaps the other. I was only very briefly Chief Secretary to the Treasury, but I have also been a Minister in a spending Department, and I have seen the challenges that occur when there is a misalignment, because the Treasury is very clear about non-commitment beyond an existing comprehensive spending review period. How will the Minister ensure alignment and certainty? Without alignment, although there is the impression of certainty, we all know the all-powerful hand of the Treasury if one, as a spending Minister, cuts across its bow on such matters. The other challenge has been raised by my hon. Friend the shadow Minister a number of times in various contexts. Although I take the point about the five-year period—and the Minister referenced seeking to bring greater certainty to investment decisions with that—I am still not quite clear. I may have missed it, but I do not think I have heard a clear explanation of what steps are being taken to iron out the peaks and troughs that my hon. Friend the shadow Minister mentioned, because it is still a five-year period. Unless the budget is set for the next five-year period in, say, year two or year three, well ahead of its coming into force—I would posit that the Treasury would be highly unlikely to agree to that—it still does not get around the problem: year one is scaling up, we might see spending in years two and three, and possibly in a bit of year four, but then that spending will drop off again due to a lack of certainty about what is coming in the next year one. I would be grateful if the Minister could clarify how what he sets out in the schedule will help to address the peaks and troughs that my hon. Friend the shadow Minister so ably highlighted to the Committee previously.

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36. 27 Jan 2026·Parliament·Edward Argar

    Topical Questions

    What does the Minister say to childminders in Melton and Syston who are concerned about potentially increased administrative burdens and cash-flow pressures, as a result of changes under Making Tax Digital for businesses with a turnover of at least £50,000? It is scrapping the blanket 10% wear and tear allowance, and replacing it with a requirement for line-by-line item accounting, with childminders having to pay up front and claim back later.

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37. 27 Jan 2026·Parliament·Dr Kieran Mullan

    Commonhold and Leasehold Reform

    I hesitate to add to the Minister’s in-tray, but he will know that we have existing protections of some sort for leaseholders and freeholders, as right as he is to want to go further. Residents in the Cooden area of my constituency have been sent letters by a company called Asset Invest Ltd demanding thousands of pounds, which it says is to regularise covenant breaches. That, to me, seems unjustified and has some of the hallmarks of the unregulated charges that leaseholders have faced in the past. This is probably an issue that affects MPs across the House. Will the Minister be so kind as to meet me to explore how we might address this issue as well?

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38. 27 Jan 2026·Parliament·Dr Kieran Mullan

    Medical Training (Prioritisation) Bill

    The Secretary of State is essentially talking about postgraduate training. I wonder what thought he has given to new clause 2 in the name of my hon. Friend the Member for Runnymede and Weybridge (Dr Spencer). I have spoken to students who worked really hard all the way through medical school to get the best exam results and perform highly but then ended up in an allocation system that pays no attention whatsoever to that. Merit has been entirely removed from the system. I think it was wrong for us to make that change. Does he have any sympathy for returning to a merit-based system?

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39. 27 Jan 2026·Parliament·Dr Caroline Johnson

    Medical Training (Prioritisation) Bill

    I am pleased to respond on behalf of the Opposition, but first I should declare my interest as a consultant paediatrician and member of the British Medical Association. Medicine is a vocation, but it is also an art and a science, and training takes a long time. After, in general, five years as a medical student, new resident doctors need to train further in a specialism such as orthopaedics, ophthalmology or, in my case, paediatrics. Postgraduate training varies in length and structure among the specialties, but in broad principle it is divided into a foundation programme and more specialist training. The foundation programme is two years long and teaches a variety of skills. Specialist training is more specific, and there are well over 60 different specialties that people can choose from. It is those two phrases—the foundation programme and specialist training—that the Bill refers to. We are in a situation where there has been a huge surge in the number of applications per training post. One reason for that is the substantial increase in the number of medical school places. That was caused by action by the previous Conservative Government to improve the number of doctors in the long term. The previous Government opened five medical schools—at Sunderland, Anglia Ruskin, Kent and Medway, Edge Hill and, very close to my constituency, Lincoln. The first students at those universities graduated in 2023, 2024 and 2025, which increased the number of students looking for posts. At the time there was also a widespread expansion of existing medical school places—and, of course, there was the pandemic. During the pandemic, students who had applied for medical school and accepted offers found themselves unable to take their exams, and teacher-assessed grades meant that there was a huge increase in the number of successful applicants who got the grades they needed. There were more compared with the number that was statistically expected. The Government lifted the cap, and there was a huge number of medical students in that period. Many of them qualified last summer. That is why there is a huge increase in the number of local graduates. In response to my hon. Friend the Member for Farnham and Bordon (Gregory Stafford), the Secretary of State talked about his pledge to double medical school places, but there does not appear to have been an increase in the number of medical school places this year, and a statement from the Department for Health and Social Care at the weekend suggests that it is not a Government commitment. When the Secretary of State was asked whether he stands by his pledge, he seemed to say no, so I would appreciate it if the Minister clarified that issue. In 2024 at a visit to the Royal Derby hospital, the Secretary of State said that that site would be part of delivering the doubling of the number of medical school places that Labour is committed to in order to ensure that the NHS has the staff it needs to treat patients on time. He then encouraged people to vote for that in the 4 July general election. Will he clarify whether he stands by his pledge, and if so, when does he expect to start delivering on it? UK factors are not the main cause for the rise in numbers. The BMA has published figures from freedom of information requests that show that the number of UK graduates applying for training programmes went up from 9,273 in 2023 to 12,305 in 2025, which is an increase of about a third. Over the same period, the number of international medical graduates applying for specialist training went from 10,402 in 2023 to 20,803 in 2025, which is a doubling of applications. The surge in numbers has left British graduates facing unemployment. Some may pursue careers overseas and not return. The valuable contributions from international medical graduates are appreciated, but many complete training and return to their home nation, which could leave us with a potential shortage in the long term of consultants and GPs. The Government are right to step in to prioritise local talent. As such, we support the principles behind the Bill. However, there are some issues that we have questions about. First, the foundation programme applications are in progress. An application window closed on 8 October, and pre-allocation outcomes were due in mid-December. Foundation school applications due on 26 February are also to be delayed. The foundation programme website states that allocations can only occur once the Bill receives Royal Assent. That delay in itself, and the uncertainty associated with it, is difficult enough for young doctors and their families. Yet the Secretary of State creates an extra layer of uncertainty by adding clause 8 and the right to withhold activation of the Bill to a day of his choosing. Why is he doing that? What are the foundation programme and the people who run it to do? Should they wait, based on, “Will he, won’t he?” and, “When will he allocate it, when will he not?” Should they allocate places anyway, on the basis, as has been said already, that people need to know where they will live and sort out their arrangements? Or will they have to reallocate if the Secretary of State activates it, after it was allocated on the basis that he had not done that yet? That is not the way to treat professional, hard-working people. As my hon. Friend the Member for Farnham and Bordon said in his speech, this is not just about doctors; it is about patient safety now and in the future. The Conservatives have submitted an amendment that would activate the Bill on Royal Assent. I urge the Secretary of State to do what is right for the country and for patient safety and support it. Secondly, Labour has forgotten the British people—those we represent and should prioritise. I will say more as we consider the specific amendment, but under Labour’s Bill, foreign nationals completing a primary medical degree in Iceland, Norway, Liechtenstein, Switzerland and the UK are in a priority group. Yet a British citizen who trained in the USA, Canada, France or even the Malta campus of a UK medical school are not. The hon. Member for Sunderland Central (Lewis Atkinson) talked about the likelihood of international medical graduates leaving the UK after training, but surely that is an argument to ensure that British trainees are prioritised wherever they have trained—if the degree is suitable. The Conservative amendment ensures that British people are always front and centre, and we urge the other Opposition parties to back it. The issue of British citizens was raised earlier too. I want to clarify for the avoidance of all doubt that when we say “British citizens” we mean those from England, Wales, Scotland and Northern Ireland. There are other clarifications, which I will be grateful if the Minister can address when winding up. On military doctors, what position is in place to ensure that military resident doctors are able to access the posts that they need? What impact will the Bill have on them, particularly if, as the world is more dangerous now, they spend more time overseas in future than at present? As Conservatives, we believe in meritocracy and, as such, I support new clause 2 tabled by my hon. Friend the Member for Runnymede and Weybridge (Dr Spencer). We all want excellent doctors and—I will say more about this in Committee—a random allocation does not encourage excellence. It produces stress and uncertainty, it does not encourage excellence, so I support the amendment. We agree with the principle of the Bill, but we encourage the Government to accept amendments that encourage excellence, to think through the detail, to put politics aside and do what is right for the country, to prioritise British citizens and to activate the Bill immediately on Royal Assent.

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40. 27 Jan 2026·Parliament·Dr Caroline Johnson

    Medical Training (Prioritisation) Bill

    I will speak to the amendments tabled by the Opposition. First, amendment 9 would require that from 2027, priority is given to British citizens on UK foundation programmes, and that they are prioritised for interviews and places on specialty training programmes. Clause 4 defines a UK medical graduate as a “a person who holds a primary United Kingdom qualification within the meaning of the Medical Act 1983 (see section 4(3) of that Act)”. However, it does not include “a person who spent all or a majority of their time training for that qualification outside the British Islands.” The Secretary of State has stated his intention to prioritise UK medical graduates, but he has failed to protect all British citizens in doing so. Our amendment would ensure that British citizens who study on an eligible medical course overseas were still prioritised in the Bill. There are many scenarios in which we may need to ensure that we protect British citizens. Consider, for example, a spouse, partner or child of a serving member of the UK armed forces who completes relevant training overseas while their relative is posted in Cyprus; a student at Queen Mary University of London who has completed the bachelor of medicine and bachelor of surgery course at its Malta campus but received a UK medical degree; a young British citizen who has studied in the US or France, owing to a family relocation; or, given that the largest bottleneck is not in training places but in getting a place in medical school at all in some cases, a British student who has gone to study overseas because of their fervent desire to become a doctor. Those are all entirely possible and plausible scenarios in which British citizens have completed their relevant training, and wish to bring their skills back and to relocate in their homeland for the rest of their career, but may not be covered by the Government’s prioritisation model. The Government’s prioritisation model is based on where the degree was taken, rather than also considering who did it. The Secretary of State must ensure that we do not overlook our own citizens if we are to fairly address the competitive landscape for training posts. The Opposition therefore urge the Government to accept amendment 9. Amendment 10 is a probing amendment to explore the effects of the Bill on military personnel. As a Member of Parliament representing an area with a large armed forces community, I know that medical trainees are an integral part of our serving community. The world is becoming an increasingly dangerous place, and junior trainees may be sent abroad earlier in their career than is currently the case. It is clearly wrong to penalise people who are doing brave work caring for our armed forces. They ought to be provided with optimal opportunities, and the Secretary of State has a duty to ensure that they are not overlooked. I would be grateful if the Minister covered that in her response. New clause 3 would require the Government to make an annual report to Parliament about the Bill’s impact on the number of international students at UK medical schools, and the financial impact on UK medical schools. We talked about the bottleneck, and the balance between UK and international students training at UK medical schools; clearly, becoming a UK graduate will now come with a significant premium. What impact will that have on British children getting to make their choices and become doctors if they want to? What incentives does it provide to universities to increase the number of international students, and what effect will that have overall on UK medical schools? New clause 2, tabled by my hon. Friend the Member for Runnymede and Weybridge (Dr Spencer), is about places for UK foundation and speciality training programmes, and the importance of allocation on merit, because we all want the very best doctors. When I became a doctor—believe it or not, it was 25 years ago this year, Madam Deputy Speaker—I applied for a job as a junior house officer, as it was called then. I applied for the jobs I wanted, I was interviewed by the consultants who would have been supervising my training, and then I was offered the jobs. The experience of students today is very different. They are allowed to put in a preference and say which deanery or foundation area they would like to work in, but that is all. After that, the application goes into a computer system, which gives them a single rank that is not based not on anything they have done at university, or on whether they got good results or worked hard, or anything like that. The computer system will do a first pass, and if the first choice is available, it will give the student their first choice. If it is not available because by the time its gets to that student those places have gone, the computer system will miss the student and go on to the next one. When it has completed its full pass of the list, it will start again, and when it comes to that student next time, it will give them the highest preference that is still available. Once the student has been allocated a foundation deanery, the process starts again within the locality, and I mean “locality” in the loosest possible sense. Take those applying for the Trent rotation; they could be posted in Lincoln, Boston, Nottingham, Derby or Burton. The doctor has no control over where they will go, and very little ability to express a preference. My hon. Friend the Member for Weald of Kent (Katie Lam) spoke about a student in her locality who had not been able to get a place, despite being at the top—third, I think—of their university class. It is clearly not fair to give people no opportunity to control their future. By the way, there is no right of appeal, so having been given their place, the choice for the student is: that place or no place. The hon. Member for Sunderland Central (Lewis Atkinson) spoke about ordinary children from the north-east. Having once been an ordinary child from the north-east, I agree that it is important that people have opportunity, but it is equality of opportunity, not equality of outcome, that matters. I worry that the system creates equality of outcome. We therefore support new clause 2, tabled by my hon. Friend the Member for Runnymede and Weybridge. Amendment 1 would require the Bill to take effect on the date of Royal Assent, as opposed to a date at the discretion of the Secretary of State for Health and Social Care. The Bill is deemed necessary emergency Government legislation to prioritise medical graduates in the United Kingdom for places on medical training programmes. When he announced the Bill in an attempt to avert industrial action by resident doctors in December, the Secretary of State told the House that he had been working intensively with his team to “to see how quickly we could introduce legislation”—[Official Report, 10 December 2025; Vol. 777, c. 430.] However, the Bill does not commit to a date when these measures will be enacted. Instead, the power lies in the hands of the Secretary of State, giving him a clear bargaining chip for future negotiations. It is clear that the Government intend to pass this legislation urgently, as they have said. However, without a commencement date, there are clear concerns that the Bill is just a negotiating tactic to prevent industrial action by resident doctors, and can be scrapped at a later date. There remains the prospect of further industrial action, despite the legislation being introduced. The Secretary of State should not be asking Parliament to pass a Bill that he has no intention of enacting if the British Medical Association plays ball and holds off on strikes. Either the Secretary of State thinks that this is emergency legislation that we need to get on with and enact, or he does not. It is vital that the legislation is enacted straight away, because students are due to be given their training programme places now, and they need to decide where they are going to live. They cannot put their life on hold, and measures to prioritise UK doctors cannot be held off, until the Secretary of State has finished dangling a carrot in front of the British Medical Association. The Opposition are clear: while we are supportive of the principles of the Bill, it must be used for offers made this year. Amendment 8 would clarify that under clause 5, a UK foundation programme is a programme where the majority of training takes place inside the United Kingdom. A foundation programme is defined as “an acceptable programme for provisionally registered doctors” in section 10A of the Medical Act 1983. It is vital to clarify that a UK foundation programme is a programme where a majority of training takes place inside the United Kingdom. That is because the General Medical Council can approve foundation programmes overseas. If it is not explicit that a foundation programme needs to be in the United Kingdom, a loophole is created whereby a foundation programme could be approved overseas, creating a back way into the system and circumventing the measures that the Government have tried to put in place. I encourage the Minister to look at that carefully as the Bill progresses. In summary, we support the Bill, but we have concerns about some of the clauses, so we have tabled amendments that we hope the Government will look at carefully.

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