Budget 2021 Update – Eight new Freeports announced – to benefit from significant tax breaks

Update

Rishi Sunak MP, Chancellor of the Exchequer announced in today’s Budget Statement eight new Freeports in England

• East Midlands Airport,
• Felixstowe & Harwich,
• Humber,
• Liverpool City Region,
• Plymouth and South Devon,
• Solent,
• Teesside and
• Thames

Subject to agreeing their governance arrangements and successfully completing their business cases, these Freeports will begin operations from late 2021. The Freeports will contain areas where businesses will benefit from more generous tax reliefs, customs benefits and wider government support, bringing investment, trade and jobs to regenerate regions across the country that need it most.

The Freeports in Scotland, Wales and Northern Ireland – are still subject to on-going discussions continue between the UK Government and the devolved administrations to ensure the delivery of Freeports in Scotland, Wales and Northern Ireland as soon as possible.

Tax sites in Freeports – The government will legislate for powers to create ‘tax sites’ in Freeports in Great Britain; it will bring forward legislation to apply in Northern Ireland at a later date. Tax sites within Freeports will need to be approved and confirmed by the government. Businesses in these tax sites will be able to benefit from a number of tax reliefs.

▪ An enhanced 10% rate of Structures and Buildings Allowance for constructing or renovating non-residential structures and buildings within Freeport tax sites in Great Britain, once designated. This means firms’ investments will be fully relieved after 10 years compared with the standard 33¹/³ years at the 3% rate available nationwide. This will be made available for corporation tax and income tax purposes. To qualify, the structure or building must be brought into use on or before 30 September 2026.

▪ An enhanced capital allowance of 100% for companies investing in plant and machinery for use in Freeport tax sites in Great Britain, once designated. This will apply to both main and special rate assets, allowing firms to reduce their taxable profits by the full cost of the qualifying investment in the year it is made, and will remain available until 30 September 2026.

▪ Full relief from Stamp Duty Land Tax on the purchase of land or property within Freeport tax sites in England, once designated. Land or property must be purchased and used for a qualifying commercial purpose. The relief will be available until 30 September 2026.

▪ Full Business Rates relief in Freeport tax sites in England, once designated. Relief will be available to all new businesses, and certain existing businesses where they expand, until 30 September 2026. Relief will apply for five years from the point at which each beneficiary first receives relief.

▪ Subject to Parliamentary process and approval, the government also intends to make an employer National Insurance contributions relief available for eligible employees in all Freeport tax sites from April 2022 or when a tax site is designated if after this date. This would be available until at least April 2026 with the intention to extend for up to a further five years to April 2031, subject to a review of the relief.

E3 Consulting View

Alun Oliver, Managing Director of Property Taxation Specialists E3 Consulting, said “Further to our previous coverage of the proposed Freeports initiative, these measures are very welcome to boost the economic activities across the various Freeport locations. Whilst the packages of tax and wider incentives are generous, we have real concerns that the timescale is far too short to drive new investment and innovation and more likely to only be a boost for schemes already in the development pipeline. Government must be more ambitious and decree more appropriate timescales to really drive new investment into these locations”.