On the 6th of March 2024, the Chancellor Jeremy Hunt announced the Spring Budget for the financial year 2023/2024.

Although the priorities are still to reduce inflation below the 2% target, grow the economy and get debt falling, the Government confirmed that inflation has fallen from last year, growth has been more resilient than expected, and debt is forecast to fall.

The economy is now beginning to turn a corner and because the government is sticking to the plan it can now make further tax cuts for working people, boosting growth whilst keeping the public finances on a sustainable path.

Please find herewith below our summary of the main tax related announcements.

PRIVATE CLIENT

Capital Gain Tax

Higher rate on residential property disposals reduced: from 6 April 2024 the higher rate of CGT for residential property gains will be reduced from 28% to 24% for individuals, trustees and personal representatives. The lower rate will remain at 18%. The 18% and 28% rates of CGT that apply to gains in respect of carried interest will remain unchanged.

Non-domiciled individuals

Non-domiciled tax status to be replaced with a residence-based regime: from 6 April 2025 taxpayers coming to the UK who have not been UK-resident in the previous 10 tax years will not pay income tax or CGT on any foreign income or gains arising in their first four years of residence and will be able to remit these funds to the UK tax free.

The regime will also apply to individuals who have been tax resident in the UK for less than four years on 6 April 2025 and will be able to use it for any tax year of UK residence in the remainder of those four years.

After their first four years of UK tax residence taxpayers will pay tax on their foreign income and gains on the arising basis.

Overseas workday relief will be retained and simplified.

Transitional measures for existing non-UK domiciled individuals will be in place including:

  • A temporary 50% reduction in the personal foreign income subject to tax in tax year 2025-26 for non-domiciled individuals who will lose access to the remittance basis on 6 April 2025 and are not eligible for the new regime;
  • Individuals who have claimed the remittance basis will, for disposals on or after 6 April 2025 be able to elect to rebase that asset to its value as at 5th April 2019;
  • Non-domiciled individuals will be able to remit foreign income and gains that arose before 6 April 2025 to the UK at a rate of 12% under a new temporary repatriation facility (TRF) in the tax years 2025-26 and 2026-27. The TRF will not apply to pre-6th April 2025 foreign income and gains generated within trusts. There will be some relaxation of the mixed fund ordering rules to make it easier for individuals to take advantage of the TRF.

Abolition of protection from tax on income and gains for settlor-interested trusts

The government has announced that, from 6th April 2025, the protection from tax on income and gains arising within settlor-interested trust structures will no longer be available for non-domiciled and deemed domiciled individuals who do not qualify for the regime.

Consultation on moving Inheritance Tax (IHT) to a residence-based regime

The government intends to move IHT to a residence-based regime from 6 April 2025 and will consult on the best way to do so. It envisages that the new rules will involve charging IHT on worldwide assets owned outright when an individual has been resident in the UK for 10 years.

Abolition of the furnished holiday lettings regime

The furnished holiday lettings regime will be abolished with effect from 6 April 2025.

Main rates of employee class 1 NICs and self-employed class 4 NICs reduced by 2%

From 6 April 2024:

  • The main rate of employee class 1 NICs will reduce from 10% to 8%;
  • The main rate of self-employed class 4 NICs would reduce to 6% from 6 April 2024.

CORPORATE

Corporation tax rates to be maintained at 25% and 19% for FY 2025

The government confirmed that the main rate of corporation tax will be maintained at 25%, and the small profits rate will be maintained at 19%, for the financial year beginning on 1 April 2025.

Introduction of a new Independent Film Tax Credit (IFTC)

A new Independent Film Tax Credit (IFTC) will allow qualifying British films with a production budget of £15 million or less to claim the Audio-Visual Expenditure Credit (AVEC) at an enhanced rate of 53%, rather than the standard 34%.

OTHER MEASURES

VAT registration and deregistration thresholds increased

The compulsory VAT registration threshold will be increased to £90,000 (currently, £85,000) with effect from 1st April 2024.

High Income Child Benefit Charge (HIBC)

From April 2024 the government will raise the threshold for the High Income Child Benefit Charge to £60,000. The rate of the charge will also be halved so that Child Benefit is not repaid in full until an individual earns £80,000.

New UK ISA

A new UK ISA account for individuals with a £5,000 allowance in addition to the existing ISA allowance will be a new tax-free product for people to invest in UK-focused assets.

If you have any question please contact a member of our staff.