Crown Immunity: repeal of section 25 Finance Act 1925
Published 26 November 2025
© Crown copyright 2025
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Who is likely to be affected
This measure will not affect any individuals, businesses, civil society organisations, or any other third parties as it removes an obsolete provision from the Finance Act 1925.
General description of the measure
The measure repeals s.25 Finance Act 1925. That section subjected to tax the trading income of overseas Dominion Governments.
Policy objective
The measure removes an obsolete provision, thereby modernising the legislation and giving certainty to taxpayers.
Background to the measure
On 4 July 2022 the government published a consultation on whether to reform sovereign immunity from direct taxation. The consultation included a proposal to repeal s.25, which attracted no comments. The meaning of “Dominion governments” is uncertain and it is arguable that it no longer applies to any states. This legislation addresses any residual uncertainty.
Detailed proposal
Operative date
The measure will have effect from the date of Royal Assent to Finance Bill 2025-26.
Current law
The current law is contained in s.25 Finance Act 1925.
Proposed revisions
The measure repeals s.25 Finance Act 1925.
Summary of impacts
Exchequer impact (£ million)
| 2025 to 2026 | 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 |
|---|---|---|---|---|---|
| nil | nil | nil | nil | nil | nil |
This measure is not expected to have an Exchequer impact.
Macroeconomic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
The measure has no impact on individuals or households. The measure is not expected to impact on family formation, stability or breakdown.
Equalities impacts
It is not anticipated that there will be disproportionate impacts on those in groups sharing protected characteristics.
Administrative impact on business including civil society organisations
It has no impact on businesses and civil society.
Operational impact (£ million) (HMRC or other)
There are no operational or delivery impacts.
Other impacts
Other impacts have been considered and none have been identified.
Monitoring and evaluation
Once repealed, no further monitoring or evaluation of this measure will be required.
Further advice
If you have any questions about this change, contact international.immunitiesprivileges@hmrc.gov.uk.