The Autumn Budget - Big Announcements
Jacob Cork
Partner at TLT - Helping families understand UK tax and plan for it, particularly where foreign assets or foreign laws are involved. I advise families on Wills, family trusts, and cross-border tax issues.
My experience is that Budget Day never lives up to the ‘hype’, but today is an exception: Rachel Reeves announced important changes to IHT, CGT and SDLT.
Capital Gains Tax
CGT rates have not gone up as much as many feared, but they have gone up with immediate effect today.
·?????? The new rates for CGT have been increased to the rates applicable to properties: 18% or 24% depending on the tax-payer’s total income and gains. Those who feared it would be matched to income tax rates will be relieved, but an increased tax of 4% on the sale of a business could have an impact on that market.
·?????? On the other hand, the relief available on the sale of a business will be of increased value in the short-term: Business Asset Disposal Relief (BADR, or maybe ‘BAD relief’?) will remain at current rates until April 2025. Seller’s who qualify will be saving £140k on the sale of a business now, dropping back to £100k in April 2025, and then down to £60k in April 2026. Whether these savings will encourage sales now is not clear.
Inheritance Tax
IHT had some major announcements, covering Business Relief, Agricultural Relief, and Pensions.
·?????? Pensions will lose their IHT exemption from April 2027, bringing them within IHT for the first time. This is likely to impact the pension industry, and increase people’s willingness to withdraw from their pensions during lifetime.
·?????? Business Relief (BR) and Agricultural Relief (AR) are being reduced significantly from April 2026. A new £1m cap is being introduced with any relief over that threshold being reduced down to 50% effectiveness (20% IHT instead of 0% IHT). AIM shares (and other related investments) will not qualify for the £1m cap, and will lose 50% of the IHT relief.
·?????? Notably, there has been no announcement of any change to lifetime gifting (unless it is of BR or AR assets after April 2026).
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Stamp Duty Land Tax
SDLT is also subject to an immediate increase for all purchases of ‘2nd homes’ -? applicable to any purchase where at least one of the buyers has another property (unless they are selling their home to buy a replacement).
·?????? The additional tax on these purchases is increasing from 3% on the total purchase price up to 5% on the total purchase price. On a £500k property, that is an increase in tax of £10k.
·?????? This means the top rate of tax on a property purchase will be 19% in some cases for non-UK based purchasers.
Non-doms
The Budget also included confirmation of the expected changes to the tax regime applicable to people who move to the UK from other jurisdictions, so called ‘UK-resident non-doms’. The Budget did not include any significant details on this, but it did re-iterate the plan of ‘ending the use of offshore trusts to shelter assets from IHT’, suggesting that they may maintain their plan to remove all IHT benefits of certain offshore trusts. Please see my recent article on how these changes are likely to apply.
We are anticipating more detail in the coming days, weeks and months.
What is certain is that ‘wealthy families’, by which I mean any family that has assets over £1m, should be taking advice on how these changes will affect them and what steps they can take to preserve their family wealth.
Jacob Cork - 30 October 2024
Legal Director at TLT LLP specialising in pensions, incentives and employee tax (including IR35 / Off-Payroll Rules)
4 个月Lots to consider on the pension scheme side about the payment mechanics for the IHT.
Tax Terminator and Financial Architect | Wealth Coach for Senior Executives and Company Directors | Dental and Medical Professionals | Securing Retirement | Supercharging Investment Returns
4 个月Very helpful! Thanks Jacob, we should have a chat soon.