** Spring Budget 2024 ** Summary

An interesting budget that does have some implications for non UK residents, particularly those that own UK property. Furnished holiday let rules are being abolished which will mean the 10% business asset disposal relief will be removed and normal CGT will apply but there has been a reduction in CGT for residential property sales. Also what can be expensed will be reduced giving rise to more gains from rental incomes.

You should consider the implications of this if you plan to dispose of a UK property in the coming years. That said UK property does allow you to use your personal allowance x2 if joint owned so carful thought needed.

Also for those who have been in France for a long time and have changed their domicile of origin that return to UK assets overseas may need to be restructured or changed.

For pensions it is unlikely anyone will be adding to this from overseas but the focus of tax relief will be centred to encourage investment into UK markets/assets. Also there may be larger pooled investment pension funds that allow better growth but may be limited to focusing on investment into the UK economy. This is something that is working well in Australia so may be a positive move. It raises concerns over diversification of portfolios but the potential for lower charges and more return for risk taken. Most UK pensions are in with profits or smoothed funds that don’t perform in line with everyone’s attitude to investment risk so reviewing this with an adviser could be beneficial.

More detail below…

Changes to UK resident / non dom rules:
Widely expected reforms to the UK resident / non domiciled rules announced for income tax and CGT. Future changes to IHT liabilities for non doms, post April 2025, will be a game changer and perhaps introduce a huge planning requirement over the coming 12 months:
• The Res/Non Dom rules announced are income tax and CGT related
o Currently, for the first 7 years on UK residency, a non dom can claim remittance basis of taxation
o This means tax can be avoided on non UK income and gains unless remitted to the UK
o Even if remitted many years later, it would be taxed on remittance if income or gain was generated whilst claiming the remittance basis of taxation
o After 7 years, and up to 12 years, it is possible to continue on the remittance basis, subject to a £30,000 levy
o After 12 years, and up to 15 years, it is possible to continue on the remittance basis, subject to a £60,000 levy
o After 15 years, the benefit of the remittance basis of taxation is lost

• From April 2025, these rules will be replaced by a residency basis of taxation
o For the first 4 years of UK residency, foreign income and gains will not be taxed in the UK, provided the individual has been non-tax resident for the previous 10 years
 This will be the case whether remitted to the UK or left abroad
o After 4 years, foreign income and gains will be taxed in the UK in the hands of a UK resident non dom, irrespective of whether it is remitted or not
 Double taxation treaties will prevent tax in both the country it arises and the UK
o Non Doms already in the UK on the current system will have some transitional relief including:
 an option to rebase the value of capital assets to 5 April 2019
 a 50% exemption for the taxation of foreign income for the first year of the new regime (2025-26)
o In addition, Non Doms already in the UK on the current system will have a 2 year period to bring previously untaxed income and gains to the UK with tax at a flat rate of 12%
• These changes are expected to raise £2.7bn in additional taxation and encourage non doms to bring money into the UK economy
• Very importantly, an intention to move to a residence based regime for Inheritance Tax has been announced
o The Government announced a future consultation on the best way to achieve this with no changes to take effect before 6 April 2025
o There is a proposal for a 10 year exemption period for non dom new arrivals and a 10-year ‘tail-provision’ for those who leave the UK and become non-resident
 There is likely to be a worldwide IHT liability in the intervening period, even for those currently considered non dom
 Although perhaps likely, there is no clear indication whether this will apply only to non doms
 It raises the question whether UK doms, including those domiciled by origin, leaving the UK may qualify for any future 10 year ’tail-provision’
 The Chancellor did say there was an intention to “abolish the concept of domicile”
 See Section 5.29, page 71, of this pdf for more detail
o The current planning opportunity for Excluded Property Trusts may now have a short shelf life and requires urgent planning for non doms intending to reside in the UK

Capital Gains Tax on Property
• The higher rate of CGT on property is going to be reduced from 28% to 24%
• Both the Treasury and the OBR agree this measure should increase transactions and increase the total tax take, even at the lower rate of taxation

National Insurance
• A further cut to Class 1 National Insurance Contributions for employees. The current rate of 10% will reduce to 8% (it was cut from 12% to 10% in the Autumn Statement 2023)
• National Insurance Contributions for the self-employed cut from 8% to 6%
• OBR project this to increase GDP by 0.4% and encourage 200,000 people back to work

ISA Allowances – a new ‘British ISA’
• Reforms to ISAs to encourage people to save more in UK listed companies
• Introduction of a British ISA – extra £5,000 ISA Allowance for investing in UK equities

Abolish Furnished Holiday Lettings Relief
• Tax breaks for owners of holiday let properties scrapped, to increase supply of rental properties to longer-term residents

Pension Funds
• The Government intends to bring forward requirements for DC pensions to publicly disclose the breakdown of their asset allocations, including UK equities. The FCA will consult in the spring
• The Government has confirmed that it remains committed to exploring a lifetime provider model for DC pension schemes in the long-term

Other Announcements:

• Public sector productivity plan to digitally transform the NHS and other public services to boost productivity
• Alcohol duty was frozen in the last statement until August 2024, this has been extended until February 2025
• The 5p cut to fuel duty from the last statement will be extended for another 12 months
• From April 2024, High Income Child Benefit Charge threshold increases from £50,000 to £60,000 and partial child benefit to be paid where highest earner earns up to £80,000, and from April 2026 planned reforms to make it a household-based charge.
• The energy profits levy will be extended by an additional year to March 2029


Thanks for the clear summary Dave! Lots of “rearranging the deckchairs on the Titanic” there! :slight_smile:

Probably all a bit academic as well, as there will in all probability be a new UK government within a year, possibly within three months.

The Institute for Fiscal Studies has pointed out that despite Hunt’s “tax cuts”, UK residents will still be worse off than at the start of this Parliament, and that the changes mostly benefit people on middle or above average incomes - pensioners and the poor will be worse of in real terms:

Yes although its reduced the trajectory line its still more tax in general… I have tried to pick out the parts that could impact us in France with a few of the general headlines.

In terms of cuts or freezes he could make within the headroom of not spending over GDP he is at the limit now… so unless there is some substantial growth he can play with in an Autumn statement I think they will dissolve parliament in October… If there is some more cuts he can make they will probably dissolve after the autumn statement and take it to the last day i think sometime the end of January for the election… its going to be interesting. They aren’t stupid so if the polls get closer they could go sooner and hit Labour when they least expect it but the long game will suit them here I think…

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I’m not sure… there could easily be more economic bad news over the summer - for example the effects of standards checks on food imports are yet to be felt and they are supposed to be in full swing by October - despite there not being enough veterinary inspectors to carry them out. This will most likely feed through into shortages of some products and increased prices.

And although mortgage rates are supposed to be coming down, there are still plenty of people who will have a fixed rate coming to an end this year who will have to refinance at a noticeably higher rate than they have been paying, which also doesn’t contribute to a pro-Tory “feelgood factor”.

There is also the punishment the Tories are likely to receive in the May local elections, if they wait until the autumn or (God forbid) next January.

And I don’t see any way for them to climb back up into a winning position - they might mitigate their losses a bit if they are lucky, but the longer they go on the more sick the public will become of them clinging on to power.

We’ll see.

I actually think Rishi and Hunt haven’t done the worst job and seem to have some good ideas…

The worst case for the UK is if they continue to chip away the lead at the polls to a point where Labour only get a marginal majority or need a coalition. Then it’s a few years of struggling to get reform through.

I’m glad I’m watching from afar but it will be interesting to see what happens!

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“Not the worst” is setting a fairly low bar though, when you compare them to Truss & Kwarteng, or Boris.

The Tories have had 14 years to get the economy, public services, and the national debt on a sound footing. On all those metrics they have left the country worse off than when they took over - and that was in the aftermath of the 2008 financial crash.

They haven’t even succeeded on the signature Tory promise of reducing taxes.

Okay we had Covid, Ukraine, etc but Brexit was a completely self-inflicted disaster, brought to us by a bunch of liars whose primary motivation was to get their rich mates out from under EU offshore tax avoidance measures.

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Childish perhaps, but I refuse to use Johnson’s stage name.


Alexander DePfeffel then. :slight_smile:

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or 'im!

Also works well as an alternative to T_____

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