The Chartered Institute of Taxation (CIOT) responded to the Treasury’s consultation on accelerating Land Remediation Relief (LRR) on 24 September 2026, broadly welcoming the proposal to allow companies to claim the enhanced 150% deduction in the year of expenditure rather than over the asset’s life. However, the CIOT raised serious concerns about the proposed linkage of accelerated relief to ‘planning permission status’—requiring that remediation works align with a granted planning permission for the site’s end use. The institute argues this creates a ‘chicken-and-egg’ problem where developers cannot secure planning without demonstrating viability (aided by tax relief), but cannot access relief without planning.
Key Takeaways
- Cash Flow Boost for Developers: Accelerated relief would provide significant upfront cash flow benefits for brownfield development, aligning with the government’s ‘brownfield first’ housing target of 1.5 million homes by 2030.
- Planning Conditionality Risk: The planning link excludes speculative remediation and early-site preparation works, potentially delaying relief until years after expenditure—undermining the acceleration objective.
- Interaction with Corporation Tax Roadmap: With the main rate at 25% and the small profits rate at 19%, the 150% deduction yields an effective 37.5% or 28.5% tax saving respectively; the CIOT urges clarity on how this interacts with the planned ‘Full Expensing’ permanence review.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement