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Is it retrospective tho?
It's retrospective in the legal sense as the tax laws that would apply haven't been enacted yet.
https://hallamsolicitors.co.uk/news/retrospective-legislation/
Of course Labour could enact laws that say it is retrospective, but then it'll be challenged in the courts and it is expensive either way that case goes.
Is it retrospective tho? it's for a service in the future that is usually paid for at the time and is being offered just for the chance it will be exempt.