Consultation on reform to taxation of UK-resident members of US LLCs

Question 1

Summary

Accepted Answer

Subject of this consultation

The government intends to address the taxation of UK resident individuals who are members of reverse hybrid entities, such as United States Limited Liability Companies (US LLCs). These individuals can suffer unintended high effective tax rates on income from these entities.

Scope of this consultation

This consultation sets out the current tax position for UK resident individuals who are members of reverse hybrids such as LLCs and identifies where high effective tax rates may arise for these individuals due to entity classification mismatches between the UK and other jurisdictions.

The consultation then seeks to understand the effect of this issue on individuals and businesses. It asks for views on proposals for changes to legislation to mitigate this issue.

Who should read this

The government is open to receiving representations from all interested parties and stakeholders and is especially interested in responses from:

individuals who are members of LLCs or other reverse hybrids
other taxpayers, investors and businesses potentially impacted by this issue
tax advisory, accountancy and legal firms
representative bodies
industry bodies

Duration

This consultation will run for 7 weeks from 10 June to 31 July 2026.

Lead official

The lead officials are E Warner and A Compton of HM Revenue and Customs (HMRC).

Question 2

How to respond or enquire about this consultation

Accepted Answer

Responses to or queries about this consultation can be sent by email to: entityclassificationmailbox@hmrc.gov.uk or by post to:

Base Protection Policy Team
HM Revenue and Customs
Floor 7, 3 Arena Central
Birmingham
B1 2AX

When responding to questions please indicate the number of the question you are responding to.

You do not need to provide answers to all the questions in order to submit a response.

For all questions, please submit any relevant supporting data alongside the response, even if it is aggregated and/or anonymised.

If there are any questions on aspects of this document, please contact us at the email above.

Additional ways to be involved

If you would like to engage in more depth on this issue, please contact us at the email above before 31 July 2026.

If you would like to request an accessible version of this document (for example, in large print, easy-read format or Braille) please contact us at the email above.

After the consultation

The government will publish a response to the consultation in due course. All respondents will be listed within that document.

Getting to this stage

This is a new consultation. This consultation has been developed in line with the principles set out in the government’s Tax Policy Principles, in particular the government’s commitment to providing further predictability and stability within the tax system.

Previous engagement

This is a new engagement with stakeholders on this subject.

Question 3

1. Introduction

Accepted Answer

Global talent and the UK tax system

The government is committed to ensuring that the UK continues to be a place where individuals choose to live, work, and invest. As part of this, the government continues to consider how the UK’s tax system can be improved and simplified to support growth and competitiveness.

At Budget 2025, following technical amendments to the foreign income and gains (FIG) regime, the government set out a commitment to explore how to further develop its tax offer for talented globally mobile individuals, to build on the success of the existing regime.

In this context, the government is concerned about the high effective tax rates that can arise where there is inconsistency in how the tax systems of different jurisdictions view the tax status (‘classification’) of certain types of entity and we are committed to remove this barrier to relocating into the UK.

Entity classification

Entities may be classified as either ‘transparent’ or ‘opaque’ for the tax purposes of a specific jurisdiction. This classification can determine not only how the entity and its members are charged to personal and corporate taxes in that jurisdiction, but also where an entity is deemed to be resident, any access to benefits under double taxation agreements, and the application of rules such as Pillar 2.

If an entity is transparent, it is not itself subject to taxation on business profits, income or gains. These are instead chargeable on the members of the entity, even where undistributed (for example, the entity is ‘looked through’ to the underlying members for the purposes of charging tax).

By contrast, if an entity is opaque, it is itself subject to tax on business profits, income and gains. Members will be taxed on dividends and other distributions that are made to them.

If an entity is opaque in its jurisdiction of establishment, but transparent in another jurisdiction, it is a ‘hybrid’. Conversely, if an entity is transparent in its jurisdiction of establishment but opaque in another jurisdiction, it is a ‘reverse hybrid’.

Different jurisdictions approach the question of entity classification in different ways. For foreign entities, HMRC’s approach is to examine the entity from first principles in order to classify it within the UK legal framework. An analysis is undertaken of the foreign law that created the entity, its constitutional documents, and other relevant facts and circumstances to determine how UK tax provisions should apply to the entity and its members. Close attention is paid to the specific wording of those provisions and the factors set out in the case of Memec (Memec Plc v Inland Revenue and Commissioners [1998] S.T.C. 754).

Unlike some other jurisdictions, the UK tax system does not generally permit elections in relation to whether a domestic or foreign entity is taxed transparently or opaquely, nor for the classification applied to a foreign entity in a foreign jurisdiction to be copied. There are some narrow exceptions to this, such as, the possibility to electively treat certain collective investment vehicles as transparent under Schedule 5AAA of the Taxation of Chargeable Gains Act 1992 (TCGA).

Reverse hybrid example: United States Limited Liability Companies (US LLCs)

LLCs are one of the most popular business vehicles in the US, used for trading as well as asset holding. An LLC may be formed under the statutes of any US state or inhabited territory. Vehicles modelled on US LLCs have also been introduced in other jurisdictions (a recent example being Jersey LLCs).

Owners of an interest in an LLC are called ‘members’ and may include individuals, corporations, other LLCs, and foreign entities. An LLC may have one or more members; there is no maximum number of members. Individual members do not need to be US resident and do not need to be a US citizen or ‘green card’ holder.

Whilst LLCs have certain protective characteristics of a corporation — such as limited liability for members — they also offer wide-ranging operational flexibility, including the choice as to whether or not to be treated as transparent (either as a partnership or disregarded entity) for the purposes of US federal taxation.

LLCs will generally be taxed transparently in the US unless a ‘check-the-box’ entity classification election has been made with the Internal Revenue Service (IRS), whereby the LLC specifically elects to be taxed as an opaque corporation.

By contrast, HMRC has historically found that most US LLCs are opaque entities for UK tax purposes. US LLCs can therefore be seen as an example of a reverse hybrid entity taxed transparently in the US, and opaquely in the UK. This position is not without uncertainty, in particular following the 2015 Supreme Court case of Anson — the outcome of which has been analysed in depth by HMRC ^{[footnote 1]} with reference to expert US legal advice.

The result of the different views on the opacity of LLCs is that individual members of an LLC who are tax resident in the UK can face a high effective tax rate, potentially as high as 75%: they will be chargeable directly on profits, income and gains as these arise in the US, and taxable again in the UK on any distributions of the LLC’s pre-tax profits. These tax charges being on a different basis prevents the provisions of the UK/USA Double Taxation Convention (DTC) from providing double taxation relief.

Purpose and scope of this consultation

The government recognises the issue of high effective tax rates for UK resident individual members of reverse hybrids and is committed to finding a solution which is effective and robust in providing a fair outcome with long-term certainty.

The government is at the same time mindful of the need to avoid unnecessary disruption to the established tax position for corporate members of hybrids. This consultation does not represent an intention to change the position for corporates.

This consultation seeks to explore the impact of the current position and put forward solutions for individuals. It asks a range of questions about how well these solutions might address the issue, possible problems with the proposed solutions, implications for different types of investors, and details of technical implementation such as timeframes and practical scope.

We are also interested in hearing your thoughts on any other legislative approaches through which this issue could be addressed which are not mentioned within this consultation.

This consultation presents a key opportunity for stakeholders to contribute to the government’s thinking, ahead of proceeding with reform.

Question 4

2. Current tax position for individual members

Accepted Answer

Summary of the existing tax position

It is useful to here set out the details of how high effective tax rates can often arise for UK resident individual members of reverse hybrids, taking US LLCs as an illustrative example due to their prevalence.

In brief, high effective tax rates arise where a member is charged to tax on a different basis in the UK and the foreign jurisdiction, which prevents the UK and the other jurisdiction from providing treaty or unilateral relief from double taxation.

United States

Stakeholders have shared the following insight into the operation and implications of the US approach to taxing these vehicles.

Subject to taxpayer election, the IRS may treat an LLC as a corporation, partnership, or ‘disregarded entity’ (inseparable from its single owner) for US federal tax purposes. The treatment depends on the number of members and whether a ‘check-the-box’ election has been made.

Specifically, an LLC with at least 2 members is by default treated as a partnership, unless it elects to be treated as a corporation. An LLC with only one member is by default treated as a disregarded entity, unless it elects to be treated as a corporation. Taxation as a partnership or disregarded entity is on a transparent (or ‘flow-through’) basis.

UK resident members of a transparent LLC with an active US business are chargeable to federal income tax in the US on arising profits. Members may also be chargeable to federal taxes where an LLC has investment income and gains (for example, property income, interest, dividends, royalties, capital gains). Further taxes on profits, income and gains may then also be chargeable at a state level.

UK resident members of a ‘checked’ opaque LLC will not be taxed on the arising profits, income and gains of the LLC. Individual members may instead be chargeable to federal income tax in the US on distributions they have received. Taxes may also be chargeable at a state level. However, in practice, it is common for LLCs to be ‘unchecked’ and retain their default transparent tax treatment.

United Kingdom

For UK tax purposes, a UK resident member of an LLC must determine whether that LLC should be considered transparent or opaque in the context of the UK tax provisions relevant to the income of the LLC and the member. This determination is to be made by reference to the LLC’s constitutional documents (for example, its operating agreements, certificate of formation) and the state law under which it was created.

In 1997, HMRC published a view that US LLCs are generally to be classified as opaque for UK tax purposes. This view is now within HMRC guidance at INTM180030: ‘List of classifications of foreign entities for UK tax purposes’.

HMRC’s view that most LLCs are opaque for UK tax purposes is based on the findings that LLCs have separate legal personality from their members (who generally have a transferable interest in the LLC itself rather than in its underlying assets), and conduct their own businesses, over whose debts and assets they have responsibility and ownership. As a consequence of these features, HMRC’s view is that LLCs earn profits, income and gains in their own right; members then typically become indefeasibly entitled to receive a return from an LLC only once the LLC formally makes a distribution, after the profits have been measured.

This view means that HMRC usually expects UK resident individual members of a US LLC to report only the distributions that they have received from the LLC in the relevant UK tax year. Any such distributions are normally chargeable to Income Tax as dividends from a non-UK resident company under s402 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA).

HMRC does not usually expect UK resident individuals to directly report their share of the underlying business profits, income or gains of the LLC on a transparent basis. This would be the appropriate treatment for income from an LLC classified as transparent in the UK; in practice, HMRC has found such cases to be rare.

Note that if an LLC is UK resident due to its central management and control being located in the UK, or where an LLC has a UK permanent establishment, it will itself be within the charge to Corporation Tax. Members of an LLC centrally managed and controlled from the UK would be in receipt of income from a UK resident company for UK tax purposes.

Double Taxation Relief

Article 24 of the UK/US DTC works alongside other articles of the DTC to provide relief from double taxation. Other articles allocate taxing rights between the contracting states. Article 24 may then provide for remaining double taxation to be relieved.

Where the US has primary taxing rights, a UK resident may receive a credit against UK tax for US tax payable. Relief is only available where tax is charged with reference to the ‘same profits, income or chargeable gains’ in both states. Conversely, where the UK has primary taxing rights, a US citizen may receive credit against US tax for UK tax.

Where an individual is taxed in relation to business profits, income and gains in one state, but in relation to distributions in the other state, this does not meet the ‘same profits, income or chargeable gains’ requirement for relief to be available against UK tax under Article 24(4)(a).

Double Taxation Relief is therefore not available in the UK under the UK/US DTC in the situation where a member is charged on underlying profits, income and gains in the US but on distributions in the UK. Unilateral relief under s9 of the Taxation (International and Other Provisions) Act 2010 (TIOPA) is also not available, as tax is not calculated by reference to the same profits, income or gains in both states.

The denial of relief stems from a broader principle that the UK does not generally give relief for ‘underlying tax’ — for example, that tax incurred on profits out of which a distribution is paid is not creditable against tax payable on that distribution.

After the UK/US DTC was updated in March 2003, HMRC issued Tax Bulletin SE6 to confirm that despite provision within the DTC for UK companies to receive some relief for underlying tax, there remained no authority to give relief for underlying tax to an individual UK member of a US LLC or other vehicle.

Challenges of the current position

Effective Tax Rate

Where an entity’s members pay tax on a transparent basis in a foreign jurisdiction, but that entity is classified as opaque in the UK, the lack of availability of Double Taxation Relief can result in any UK resident individual member’s share of income suffering an unintended high effective tax rate.

For example, a member of a transparent US LLC chargeable on profits could be subject to a US federal income tax rate of up to 37% (the current highest marginal rate). Further taxes may also be chargeable at a state level.

If the profit share were to then be fully distributed, the member would then be chargeable to UK Income Tax on the gross distribution at dividend rates, with the upper dividend rate currently being 39.35%.

Assuming significant other income and applying the marginal rates, the member could end up suffering an effective tax rate in excess of 75%. In practice, effective tax rates may be lower than this but are nevertheless still substantial — stakeholders have shared experiences of rates in excess of 60%.

Economic equivalence of amounts charged in each state

Although underlying profits, income and gains are legally distinct from distributions, there is often a very close economic equivalence between a member’s profit share in a given year and the amount that that member will receive in distributions from the relevant entity in that year.

Without regular distributions it can become more difficult for some individuals to meet their tax obligations in the foreign jurisdiction with respect to the underlying profits, income and gains of the foreign entity. Where a member is subject to UK tax on a gross distribution, they will indeed often have already relinquished a significant proportion of that gross distribution to settle their foreign tax liabilities on the equivalent amount of profits.

Where profits are fully distributed, this means that the same monetary amount derived from the same economic activity will be taxed at marginal personal rates in 2 jurisdictions. This is an uncommon outcome even where Double Taxation Relief is not in point — for example, the profits of a UK company, when distributed to a UK shareholder, are net of Corporation Tax paid by the company itself.

The case of Anson

Although issues with high effective tax rates and lack of availability of double taxation relief can arise with respect to multiple types of foreign hybrid, the government recognises that US LLCs can present additional complexity and uncertainty for individual taxpayers.

This is because HMRC’s view of LLCs as generally opaque was challenged by the outcome of the case of a Delaware LLC member (Anson v Commissioners for HM Revenue and Customs [2015] UKSC 44). Some UK individual members of LLCs seek to apply the decision to their own circumstances.

On the facts found by the First-tier Tribunal, the Supreme Court held that the member had an interest in the profits of the Delaware LLC, arising at the point that the profits were allocated to his capital account within the LLC. He was therefore found to be chargeable to UK Income Tax on a transparent basis — on profits, income and gains rather than on distributions. Accordingly, the member was determined to be entitled to Double Taxation Relief, due to the ‘same income’ being chargeable in both states.

However, HMRC’s analysis of almost all Delaware (and other US) LLCs — most recently expressed in guidance at INTM180050 published in 2023 — has continued to be that the profits of the LLC belong to that LLC in the first instance; that it is distributions and not the allocation of profits to a capital account that create a liability to a member; and that members should not thereby be charged to UK tax on the undistributed profits of the LLC.

Applying the findings of Anson more widely to any taxpayer with an interest in a US LLC (without specific analysis of the LLC in question) would itself create uncertainty for individual and corporate taxpayers who rely on HMRC’s existing position. This reliance is particularly relevant for members of LLCs with operating agreements drafted in a manner similar to a corporation, or which have ‘checked’ opaque US tax status.

Difficulty thereby arises for some individual taxpayers, who in seeking to apply the principles of the Supreme Court decision to their own interest in an LLC risk entering into dispute with HMRC over the extent to which their own circumstances are comparable to those of Anson. The government recognises this uncertainty and considers that change for these individuals can be achieved legislatively.

Question 5

3. Impact of current tax position

Accepted Answer

We are keen to fully understand the impact that issues with reverse hybrids have had and continue to have on individuals’ decisions on how to structure their affairs, whether to move to the UK, and whether to remain in the UK.

We also appreciate that this issue can have a wider range of effects on business and investment in the UK, affecting decisions on how to structure and locate resources.

Question 1: Have you or your clients faced a high effective tax rate (ETR) on income from reverse hybrids? If so, please provide details about the circumstances, including the ETR, the type of entity and income it related to, and what kind of member you or your clients were.

Question 2: Have you ever taken steps to mitigate a high ETR related to a reverse hybrid? If so, please provide details. If you were not able to take steps to mitigate a high ETR, please explain what the barriers were.

Question 3: Have you or your clients ever sought Double Taxation Relief from a foreign jurisdiction with respect to UK tax paid on income from a reverse hybrid entity? If you were granted relief, on what basis was this given? If you were not granted relief, why not?

Question 4: Has the UK tax treatment of income from reverse hybrids affected your or your clients’ personal decisions about where to live and work? If so, please give details.

Question 5: Has the UK tax treatment of income from reverse hybrids affected your or your clients’ commercial decisions such as where to locate offices and staff, do business and make investments? If so, please give details.

Question 6: Do other jurisdictions offer more favourable treatment for your or your clients’ income from reverse hybrids? If so, which jurisdictions are these? What makes the treatment more favourable than the UK?

Question 6

4. Proposals for changes to legislation

Accepted Answer

Overview

The government is seeking to resolve the issue of high ETRs in relation to certain reverse hybrid entities like US LLCs. The purpose of this chapter is to present proposed approaches and to invite views from stakeholders on their merits, risks, and practical impacts.

UK matching of transparent treatment

Outline

To deliver a solution, the government is minded to introduce legislation to allow UK resident individual members in specific eligible reverse hybrids to treat their holding on a transparent basis for the purposes of Income Tax and Capital Gains Tax.

No equivalent legislation would be introduced for UK resident corporates.

The objective of this solution would be to charge individual members to UK tax on the underlying profits, income and gains of the foreign entity in a way that matches the tax treatment in the relevant foreign jurisdiction. Individuals would not be chargeable to Income Tax on distributions from the entity. This would then allow individuals more certainty over their UK tax and the extent to which Double Taxation Relief would be available. The effective tax rate on these individuals’ income would reduce to the higher of the domestic effective tax rates applicable to the individual in each state.

For instance, a UK resident individual entitled to trading profits from a US LLC would pay US taxes on these profits (for illustrative purposes — assume effective rate of 37%). UK Income Tax would then also be chargeable on trading profits (for illustrative purposes — assume effective rate of 45%). The UK would be able to give Double Taxation Relief for US taxes paid on the same profits, giving an effective rate of 45%.

Conversely, a UK resident individual with an interest in a debt-fund constituted as a US LLC would be chargeable to UK Income Tax on the fund’s interest income. To the extent that the income is also taxable in the US, we would expect credit to be given for UK tax in accordance with the UK/US DTC.

This solution should seek not to increase administrative burdens and should not create opportunities for avoidance or harmful planning.

Scope

The specific foreign entities within scope would be those which are taxed on a transparent basis in their jurisdiction of establishment, but which are treated as opaque for UK tax purposes.

Question 7: Do you see any issues with defining the scope in the way stated above? Can you identify any potential boundary issues with any specific entity types?

This treatment would be limited to holdings in those entities which are not themselves resident in the UK (or considered resident by any other foreign jurisdiction), or trading in the UK via a permanent establishment. This treatment would not be limited to holdings of any specific size or to eligible entities with a specific number of members.

Question 8: Do you think that these conditions are reasonable? Do you see any potential issues with these conditions? Should further conditions be imposed to limit the holdings to which this treatment would apply?

UK resident individual members of a foreign entity meeting the eligibility conditions would automatically receive matching transparent treatment for UK tax purposes. If the foreign entity began to be taxed on an opaque basis in its home jurisdiction, it would cease to be an eligible entity and transparent UK treatment would cease to apply to UK individual members.

Question 9: Do you see any advantages or disadvantages to transparent treatment applying automatically, rather than by irrevocable election?

Transparent UK treatment would apply prospectively for tax years following the date of introduction of new legislation.

UK transparent treatment

Individual members of an eligible foreign entity would be deemed to be carrying on any trade or business of the entity in partnership (or as a sole trader for single member entities). This would bring the member’s share of profits into charge, allow relief for their share of losses, and give access to allowances and reliefs. A member’s share of profits and losses would need to be computed using UK Income Tax rules.

Question 10: Do you see any issues with deeming the trade or business of eligible foreign entities to be carried on in partnership (or as a sole trade), and profits/losses being computed in accordance with UK Income Tax rules? If so, what are they?

Individual members would also be deemed to have such proportion of the beneficial ownership of the entity’s assets as corresponds to their proportional membership interest in the entity. This would allow for the attribution of a proportion of investment income (interest, dividends, royalties) to the member. A member’s tax liability with respect to investment income would need to be computed using UK Income Tax rules.

Question 11: Do you see any issues with attributing investment income to members in line with their proportional membership interest, and tax liability being computed in accordance with UK Income Tax rules? If so, what are they?

This attribution of asset ownership would also allow for the calculation of capital gains in line with the partnership principles in HMRC Statement of Practice D12. Individual members would be treated as owning a fractional share of each of the entity’s assets and not as owning an interest in the entity itself.

Upon a disposal of an asset, members would be treated as disposing of their fractional share of the asset, with proceeds allocated to members in the ratio of their interests in the entity (or in accordance with specific different ownership ratios set out in the entity’s constitutional documents, for example, its operating agreement). A member’s capital gain or loss would need to be computed using UK Capital Gains Tax rules.

Question 12: Do you see any issues with applying Statement of Practice D12 to individual members, and capital gains/losses being computed in accordance with UK Capital Gains Tax rules? If so, what are they?

Question 13: Do you see any issues specifically with respect to establishing each member’s fractional interest in the assets of the entity? If so, how could these problems be overcome?

Question 14: Do you see any other issues with the transparent treatment outlined above in respect of the application of any other UK tax rules (or reliefs/exemptions)? If so, which UK tax rules (or reliefs/exemptions) are these? What are the issues that arise? How might these be mitigated?

Transitions

Under the above proposal, an individual member would be required to make an initial transition from opaque to transparent treatment for their holding in an eligible foreign entity. An individual member’s holding might also cease to be eligible for transparent treatment if the foreign entity ceases to be taxed on a transparent basis overseas, causing the individual to transition out of the new regime.

Question 15: Do you see any issues that might arise upon these transitions, in respect of tax rules (or reliefs/exemptions) applicable to a holding that begins or ceases to be treated on a transparent basis? What are the issues that arise? How might these be mitigated?

Effect of approach

We are keen to understand whether this approach would achieve its aims, and also any potential unintended consequences that might result from it.

Question 16: Do you believe that the approach set out above would solve the issue of high effective tax rates for individual members of reverse hybrids? Please explain why/why not.

Question 17: Do you see any issues with this approach, including any unintended outcomes for individual or non-individual taxpayers? If so, what are these?

Question 18: Do you have any comments on the potential impacts of these changes on tax receipts or taxpayer behaviour? How might individuals and businesses respond to these changes? For instance, would these changes increase UK tax receipts overall? Conversely, are there specific tax planning techniques which these changes would incentivise or otherwise fail to capture?

Alternative forms of relief

We are also interested in your views on alternative forms of relief that could be provided for in legislation.

Deduction for foreign tax

Another potential solution identified could be to provide for deduction for foreign tax: for example, that where a UK resident individual member of an eligible foreign entity is chargeable to UK Income Tax on distributions from the entity, the UK tax could be calculated on the distributions net of foreign tax already paid by the individual on the distributed profits.

Credit for foreign tax

A further potential solution could be to provide a form of credit for foreign tax on underlying profits against an individual’s UK Income Tax on distributions, to reduce the overall effective tax rate applicable to that individual’s income from an eligible entity.

Question 19: What are your views on the deduction for foreign tax and credit relief options outlined above? Do these approaches have advantages or disadvantages in comparison to UK matching of transparent treatment? Please give details.

Question 20: Do you see any issues with either of these approaches, including any unintended outcomes for individual or non-individual taxpayers? If so, what are these?

International comparison

Other jurisdictions take differing approaches to the taxation of individuals in receipt of income from entities treated as reverse hybrids in the UK.

Question 21: Do you have experience of the rules applied by other jurisdictions? What jurisdictions are these, and what are the rules? What advantages and challenges have you encountered when applying these rules?

General questions

Question 22: Are there any other options or ideas for reforming the taxation of individual members of reverse hybrids that you believe the government should consider? This could include forms of treatment or relief not mentioned above.

Question 23: In relation to any of the proposals above, apart from change to UK liabilities, what would be the other impacts on you or your clients? For example, would there be impacts on time spent managing tax compliance, fees, cashflow, certainty, foreign tax expenses?

Question 24: How might any of the proposed changes to the tax treatment of income from reverse hybrids impact your or your clients’ view of the UK as a place to live, work, do business and make investments?

Question 7

5. Assessment of impacts

Accepted Answer

Summary of impacts

Year	2026 to 2027	2027 to 2028	2028 to 2029	2029 to 2030	2030 to 2031	2031 to 2032
Exchequer impact (£m)	+/-	+/-	+/-	+/-	+/-	+/-

Exchequer Impact Assessment

Any Exchequer impact will be estimated following the consultation, which would provide the final scope and design of the measure, and it will be subject to scrutiny by the Office for Budget Responsibility.

Impacts	Comment
Economic impact	Publication of this consultation is not expected to have any significant macroeconomic impact. Any economic impact will be estimated following the consultation, which would provide the final scope and design of the measure, and it will be subject to scrutiny by the Office for Budget Responsibility.
Impact on individuals, households and families	Publication of the consultation document is not expected to have any impact on individuals, households or families. The options presented in this consultation would impact individuals. Any impacts of subsequent policy measures will be fully examined and detailed.
Equalities impacts	It is not anticipated that there will be impacts on those in groups sharing protected characteristics from publishing the consultation document. Any impacts of subsequent policy measures will be fully examined. A full equality impact assessment is not recommended at this stage.
Impact on businesses and Civil Society Organisations	Publication of the consultation document is not expected to have any impact on businesses or civil society organisations. The proposals outlined in the consultation may have an impact on businesses, though the nature of any impacts would depend on subsequent decisions. Any future impacts of subsequent policy measures will be fully examined and detailed.
Impact on HMRC or other public sector delivery organisations	Publication of the consultation document is not expected to have any impact on HMRC. Any future impacts of subsequent policy measures will be fully examined and detailed.
Other impacts	No other impacts have been identified.

Question 8

6. Summary of consultation questions

Accepted Answer