The Finance Bill has now been published and contains no material changes from what we had expected.
The change reflects industry representations on time limits for the making of elections in respect of the proposed onshore allowance. The Finance Bill permits elections for unattributed expenditure or transferring allowances between sites no earlier than the beginning of the 3rd accounting period of the company after that in which the expenditure was incurred or the allowance was generated. The original draft legislation delayed the elections until the 4th accounting period at the earliest. Furthermore the Finance Bill rules treat the transferred allowance as if it were generated at the beginning of the accounting period in which the election is made rather than in the accounting period following the election, as originally proposed.
We shall continue to monitor the progress of the relevant issues for the industry as the Bill progresses.