NEWS & VIEWS
In what is likely to be the last fiscal event before a general election, the Chancellor delivered a budget that may be seen as more of a political statement than an economic one.
As readers will no doubt know, the Chancellor confirmed a further 2 pence cut to the main employee rate of National Insurance, severely curtailed the non-dom regime, and increased the thresholds of the High Income Child Benefit Charge.
Let’s look at today’s key announcements and what they mean.
At a glance:
- National Insurance: the main rate of employees National Insurance will be reduced from 10% to 8% from 6 April 2024. This is already down from the 12% rate at the start of the current 2023-24 tax year.
- Non-doms: from April 2025, non-domiciled individuals will not pay tax on overseas income and gains for the first four years of UK residence. After that, they will pay the same tax as UK domiciled individuals. Transitional arrangements will be in place to ease current UK residents into the new regime.
- UK ISAs: a new ‘UK ISA’ will be created with a £5,000 allowance. The allowance may be used in addition to the existing ISA allowances of £20,000 for adults and £4,000 for children.
- RIFs: a new type of investment fund called a Reserved Investor Fund will be created.
- CGT: the higher rate of CGT on property disposals will be reduced from 28% to 24% from 6 April 2024.
- FHL: the Furnished Holiday Lettings (FHL) tax regime will be abolished from April 2025, with a CGT anti-avoidance rule effective from 6 March 2024.
- Savings Income: the starting rate for savings income will be kept at £5,000 for 2024-25.
- Crypto reporting: a Cryptoasset Reporting Framework will be implemented from 1 January 2026, with information exchanges taking place from 2027.
A closer look…
Non-doms – a big shake-up
Significant for those involved, though relatively speaking not a huge revenue raiser for the government – with the policy summary estimating that it will raise £2.7 billion per year by 2028-29.
Strictly speaking, the government has announced it will abolish the remittance basis of taxation:
The remittance basis of taxation allows someone who is not ‘domiciled’ in the UK to ignore all income and gains from overseas which they do not bring into the UK when completing their UK tax return. See our handy explainer here on the difference between residence and domicile.
Non-domiciled individuals – or ‘non doms’- can claim the remittance basis for all years they live in the UK up to 15 years out of the past 20. After 15 years they are deemed to be domiciled in the UK and are treated like any other UK individual.
Today’s announcement by the Chancellor is that any foreign income and gains made by a new arrival are not taxable in the UK, even if they are remitted to the UK, and that the period of 15 years has been reduced to 4.
For those individuals already resident here, there will be transitional arrangements in place, including allowing them to set the book cost of overseas capital assets to their 5 April 2019 market value if they so choose. A similar arrangement was put in place in 2017 and allowed affected individuals to go asset-by-asset to see whether an election was suitable. This required building up the book cost of overseas assets.
If you need help building up the book cost of your overseas assets, enquire with us about our award-winning CGiX software.
UK ISA
An Individual Savings Account, or ISA, is a tax-free wrapper allowing the individual to save cash or invest into stocks and shares. The maximum amounts that can be saved into an ISA each year are £20,000 for adults and £4,000 for children. These allowances have been frozen since 2017.
In last year’s Autumn Statement, it was announced that fractional shares were permitted investments in ISAs and that multiple ISA products could be opened by an individual (provided that the total amount saved across all an individual’s ISAs did not exceed their allowance).
Today, a new type of ISA product has been announced: the UK ISA. The intention appears to be to encourage investment in UK companies, however it is unclear from the details we know so far how well this measure will work. The government has announced it will consult on the details, so watch this space.
National Insurance
This has been covered extensively by the media and there isn’t a whole lot we can add. The main point for our readers is that National Insurance is a tax on employment and self-employment. The persons liable to National Insurance are employees, their employers, and the self-employed. Income and gains derived from investments are therefore not affected.
Reserved Investor Fund
This was the point in the Budget where your correspondent looked at the policy document and thought, “oh no, lots of work!”. But it may be a good move for investors.
The purpose of the Reserved Investor Fund (RIF) is to provide a “flexible, low-cost unauthorised fund vehicle”. For tax reporting purposes, the important point is that it is intended to replicate the tax rules which apply to authorised unit trusts and open-ended investment companies. As with these vehicles, the intention of the tax rules governing the new RIF is to treat the investor in a similar way to if they held the underlying assets directly.
The new Finance Bill will come out soon and will detail how the new regime will work. We will be reviewing the wording and sharing our thoughts.
Cryptoasset reporting framework
This is the UK government’s implementation of the OECD cryptoasset reporting framework under the Common Reporting Standard, a framework for countries to share individuals’ financial information across borders.
Whilst at a glance this is just an information-gathering and -sharing exercise, the bigger point for HMRC is that this ensures they can track people who invest in cryptoassets and owe UK tax on their income and gains. The biggest problem HMRC has with regards to cryptoassets is non-compliance, though consensus is that this is due to lack of knowledge among young or casual investors as opposed to deliberate evasion.
At FSL, we have been concerned that those who do not realise they owe tax on their cryptoasset investments will be caught out, particularly AS the annual exempt amount on gains halves to £6,000 for 2023-24, and again to £3,000 for 2024-25.
We foresee a lot of people getting letters through their door from HMRC in the coming years. The most important thing HMRC can do is continue to educate people so they are aware of their tax responsibilities.
Looking ahead
FSL will continue to review the policies announced at the Spring Budget 2024.
Join our webinar from 1pm on Friday where we will go through the Budget in further detail and discuss what it means for you and your clients.