30 OCTOBER 2024
The below summarises the key points arising from the Budget today:
Non-Dom Changes
• Removal of Remittance Basis (RB) from April 2025
• 4 years foreign income and gains (FIG) tax-free and ability to bring to the UK
• Overseas Workday Relief extended to 4 years, but limited to lower of £300,000 or 30% of pay. Can remit to the UK
• Temporary Repatriation Facility (TRF) will allow anyone who has claimed the RB to remit FIG to the UK at a reduced rate of 12%, from 6 April 2025 to 5 April 2027. Increasing to 15% for 2027/28. Includes benefits received from offshore structures
• Removal of “protected trusts” for income tax and capital gains. Once a settlor in a settlor-interested trust is resident for 4/10 years all income and gains within the trust will be taxed on the settlor on an arising basis
Capital Gains Tax
• Rate increase to 18% for basic rate taxpayers and 24% for higher and additional rate taxpayers
• Carried interest rate increased to 32%
• Current and past remittance basis users can rebase assets to April 2017
• Business Asset Disposal relief remains at £1m, but the rate will increase from 10% to 14% from 5 April 2025 and to 18% from 5 April 2026.
Inheritance Tax
• Move from a domicile based system to a residency based one from 6 April 2025
• Once resident in the UK for 10 years out of the previous 20 an individual will be subject to UK IHT on their worldwide estate
• “IHT tail” – 10 years, but reduced for those who are leaving between years 10-19 of residence
• Offshore assets in excluded property trusts will be subject to UK IHT based on settlors residence
Other
• Pensions will now be subject to inheritance tax
• Employer National Insurance Increase: employer National Insurance contributions will increase by 1.2% to 15%
• VAT on private school fees
• SDLT increase on “second homes” from 3% to 5%
The updates arising from the UK Chancellor’s Budget may have impacted your financial strategy.
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.
Read our high-level summary of the Autumn Budget
2026 Reforms to BPR and APR
Read our high level summary of the October UK budget changes
