Likely to be the last major fiscal event before the next general election later in the year, UK chancellor, Jeremy Hunt has delivered his Spring Budget setting out the Treasury’s taxation and spending plans for the next financial year.
With an impetus on “more investment, more jobs, and lower taxes”, Hunt put tax cuts at the heart of his Budget in an attempt to lower the tax burden on individuals and boost long-term economic growth. Key announcements include cuts to national insurance, the introduction of a UK ISA, and the abolishment of the UK ‘non-dom’ tax system.
Hunt also provided updates on the outlook for UK inflation, with the Office for Budget Responsibility (OBR) forecasting inflation to fall below the government’s target of 2% by the end of May 2024[1].
The Spring Budget builds upon the 2023 Autumn Statement, in which Hunt announced cuts to national insurance, rises to the minimum and living wage, and a triple-lock boost to the state pension, among other measures. You can find a breakdown of the key changes in our 2023 Autumn Statement response.
Here, we dissect the key announcements of the Spring Budget relevant to personal finance and investments, before giving the views of Guy Foster, our Chief Strategist, on the implications for the UK economy.
Key highlights
Cuts to National Insurance (NI)
Announcements:
- Class 1 National Insurance contributions (NICs) will be cut from 10% to 8% from 6 April 2024.
- In the Autumn Statement 2023, the government announced the removal of the requirement to pay Class 2 NICs from 6 April 2024 and committed to abolishing Class 2 entirely. The government will consult later in 2024 on how it will deliver Class 2 abolition.
Impact:
- National Insurance contributions are paid by employees and the self-employed on their earnings, as well as employers. Currently, employees pay NI at 10% on earnings over £12,570 and at 2% on earnings over £50,268. Today’s announcement will see the headline rate of 10% lowered to 8%. This will result in anyone earning above £50,268 saving £754 in NI contributions each year.
Planning opportunities:
Your NI saving is money that was previously taxed, and so a ‘net new’ regular income. Placing it into a pension (where it benefits from tax relief) may increase your overall tax savings without affecting your current income.
Where possible you could consider deferring the extraction of income subject to NI (such as salary from a company) until the lower rate takes effect.
UK ISA introduced
Announcement:
- The chancellor introduced a tax-free £5,000 UK ISA that can be used to invest in UK investments (a consultation has been launched to determine which investments would qualify).
Impact:
- In an effort to revitalise the UK stock market, the UK ISA would likely enable investors to buy UK company shares without paying tax on income and gains. Savers will benefit from an extra £5,000 tax-free allowance per year.
Planning opportunities:
- Many stocks and shares ISA holders will already invest in UK equities as part of their overall portfolio. Investors who hold UK equities outside of an ISA could (subject to eligibility and CGT considerations) move these into the new UK ISA to be held more tax efficiently, without committing additional sums to the markets.
- ISAs remain a great tool for tax-efficient investing. Making full use of annual ISA allowances can be an effective way to build tax-efficient savings and while the details are to be confirmed, the UK ISA will provide another vehicle and additional allowance.
British savings bonds
Announcement:
- Launch of a new NS&I product – British savings bonds. This product will be launched in April 2024 and will offer a guaranteed rate of interest which is fixed for three years.
Impact
- This will increase the range of government backed savings products available under National Savings & Investments, which currently offers four ways to save (premium bonds, direct saver, income bonds and green savings bonds) as well as adult and child cash ISAs.
- They will offer savers a guaranteed rate over three years for investments between £500 and £1million.
Planning opportunity:
- NS&I savings products can offer attractive lower-risk returns (owing to the government backing) and should be considered as part of your plan, just as the existing NS&I products will. The British savings bond interest rate has not yet been announced and will be a key determining factor in the attractiveness of this product.
Capital gains tax on residential property
Announcement:
- With effect from 6 April 2024, the higher rate of CGT for residential property disposals will be cut from 28% to 24%.
Impact:
- This reduction in CGT rate aims to encourage landlords and second home-owners to sell their properties, thereby increasing housing availability for other potential homebuyers. The government estimates this will increase revenue by £690 million over the next five tax years.
Planning opportunity:
- If you’re about to sell a second home, completing the transaction after 6 April 2024 could save you up to 4% of the taxable gain.
Furnished holiday lettings regime abolished
Announcement:
- From 6 April 2025, the tax regime around furnished holiday lets will be abolished and they will be treated the same as long term lets for tax purposes.
Impact: Furnished holiday lets benefit from more generous tax treatment in comparison to other let properties, such as:
- Profits are treated as relevant earnings for pension contribution relief (i.e. treated the same way as employment and self-employment income).
- There are more generous deductions in arriving at taxable profit, including 100% of interest on mortgages and capital allowances.
- Potential 10% capital gains tax (CGT) rate on the property’s sale through business asset disposal relief (known as entrepreneurs’ relief before 2020).
- Rollover relief if you are reinvesting the proceeds to buy a new holiday home or investing in certain qualifying properties (or the replacement of business assets) for CGT purposes.
- Holdover relief (on gifts) for CGT purposes, which result in the recipient paying CGT only when the property was sold in future.
- Losses can be offset against future furnished holiday let profits and in certain circumstances, against other types of income.
Planning opportunities:
- This is a large change in the tax treatment of short-term furnished lets and could tilt the scales on whether the property is profit or loss making. It is important to understand how these changes will affect the tax amount due and to assess the profitability of such investments going forwards.
- Many individuals looked to transfer properties into companies following changes to tax on longer-term lettings and this may be worth exploring on furnished holiday lets too. Depending on the position, it may even be worth considering whether funds should be redeployed in other investment classes.
UK non-dom tax status abolished and replaced with a new regime
Announcements:
- From 6 April 2025, the current remittance basis of taxation will be abolished for UK resident non-domiciled individuals (non-doms).
- From 6 April 2025, this method of taxation will be replaced by a new regime for individuals who become a UK tax resident (after a period of 10 tax years of non-residence). Eligible individuals will not pay tax on foreign income or gains in the first four tax years of UK residency and will be able to bring these funds to the UK free from any additional charges.
- Overseas Workday Relief (OWR) for the first three tax years of UK residence will be retained for income from employment duties carried out overseas, whether or not these earnings are brought to the UK.
- The government has announced the intention to move to a residence-based regime for inheritance tax (IHT) and will consult in due course on the best way to achieve this. No changes to IHT will take effect before 6 April 2025.
Impact:
- UK residents whose permanent home (domicile) is outside of the UK currently only pay UK tax on income and gains generated in the UK, not outside the UK (unless they bring it into the UK). In addition, non-UK assets are outside the UK IHT net.
- There were 68,800 non-doms in the UK for the tax year ending 2022 according to HMRC[2], and these individuals will have to pay UK tax on their overseas income and gains from 6 April 2025 if they arrived in the UK before 6 April 2022.
- The new regime will offer a simpler albeit shorter “tax holiday” on foreign income or gains. Importantly, in a large shift from the current regime, these gains or income will be able to be brought into the UK free from tax.
Planning opportunities:
Those looking to move to the UK should seek professional tax advice prior to moving to ensure they understand the tax implications.
For those currently in the UK, the planning window within the current regime is limited. Understanding the impact of the changes alongside your options with an appropriate professional could help you make proactive choices to navigate and take advantage of the upcoming changes. In this regard, the transitional arrangements may provide opportunities.
Transitional arrangements for existing “non-doms”
Announcement:
- Non-doms who will lose access to the remittance basis on 6 April 2025 and are not eligible for the new four-year regime, will receive a single-tax-year (6 April 2025 to 5 April 2026) exemption of 50% on the taxation of foreign income.
- Current non-doms who have claimed the remittance basis will be able to re-base capital assets to 5 April 2019 levels for disposals that take place after 6 April 2025. This means that when foreign assets are disposed of, affected individuals can elect to be taxed only on capital gains since that date.
- Non-doms will be able to remit foreign income and gains that arose before 6 April 2025 to the UK at a flat rate of 12% under a new Temporary Repatriation Facility in the tax years 2025/26 and 2026/27.
- From 6 April 2025, all foreign income and gains arising within a settlor interested trust (where the settlor is also a named beneficiary) will be taxable on the settlor, unless the settlor is able to benefit from the new four-year regime. Pre-6 April 2025 income and gains will not be taxed unless distributions or benefits are paid to UK residents who have been here for more than four years.
Impact:
- For current non-doms who will stay in the UK, the transitional arrangements offer some significant, albeit time-limited, potential benefits. Taking advantage of these may help lessen the future impact of the upcoming changes.
Planning opportunities:
- Those wishing to spend foreign income or gains in the UK should look to take advantage of the time-limited opportunity to bring these in at a 12% tax rate. The amount brought into the UK should reflect what is required and take into account wider planning.
- Individuals able to control the timing of their income may wish to consider realising foreign income in the 2025/26 tax year. Those that are eligible for rebasing will likely want to obtain valuations of assets as at 5 April 2019 in order to compare to the original base cost.
- When a similar transitional relief was introduced in 2017 an opportunity for creating additional clean capital arose. Those considering a trust may wish to take these changes into account. Those with existing trusts should review the suitability of these and consider whether additional structuring may be required, such as international bonds, private funds and companies.
Crypto assets
Announcement: The government will launch a consultation on crypto-asset reporting.
Impact
- A consultation will be launched on crypto-asset reporting and amendments to the Common Reporting Standard (the system whereby financial institutions share information directly with tax authorities). This intends to close gaps in the tax transparency system that have emerged as a result of recent developments in financial technology and the global crypto-asset market.
- The announcement follows the recent (November 2023) launch of a campaign and specific facility to report previously unpaid taxes on crypto assets.
Planning opportunity:
- If you are unsure of how your crypto assets should be taxed, please speak with your tax adviser and ensure that all tax is reported and paid.
Child benefit threshold raised
Announcement:
- From April 2024, the £50,000 high-income child benefit charge threshold will be raised to £60,000 and the taper will extend up to £80,000.
- A consultation will be launched to extend the charge to a household basis (from the current individual basis) by April 2026.
Impact:
- At £50,000, an individual starts to pay a higher rate tax of 40% but is also subject to a high-income child benefit charge (effectively a claw back of child benefit). This threshold has been static since 2013 and so its increase will help individuals who have been affected by fiscal drag.
- Currently, if one partner earns more than £50,000, child benefit is gradually withdrawn and where earnings are £60,000 or more, they do not receive any child benefit at all. This means two parents earning, say £49,000 a year each, would receive child benefit in full. In comparison, a household with one working parent or a single-income household earning more than £50,000 would have their benefit cut. The change to a household basis being consulted on will look to end the unfairness by looking at the household rather than individual level.
Planning opportunities
- As the charge is currently based on each individual’s income rather than household income, it may be possible to reduce the impact by distributing income between spouses differently. However, this may change in future following the consultation to look at the household level.
- The timing of gifts to charity or the quantity of pension contributions can also impact the level of charge and should be considered.
- The individual registering for child benefit should also be carefully considered as NI contribution credits (i.e. state pension accrual where there is little/no income) will be awarded to the person registered for child benefit.
- Following the introduction of the household basis it may be appropriate to consider planning for both partners (such as pension contributions) to reduce the overall household income and maximise child benefits.
Stamp duty
Announcement:
- From 1 June 2024, the government is abolishing multiple dwellings relief for stamp duty land tax (SDLT).
Impact
- Multiple Dwellings Relief (MDR) is a tax relief that can be claimed against Stamp Duty Land Tax (SDLT) when a purchaser buys more than one residential dwelling in a single, or linked, transaction. When claimed, MDR causes the SDLT owed to broadly align with what would have been payable had the properties been purchased individually in separate transactions.
- Property transactions with contracts that were exchanged on or before 6 March 2024 will continue to benefit from the relief regardless of when they complete, as will any other purchases that are completed before 1 June 2024. This follows an external evaluation which showed no strong evidence the relief is meeting its original objectives of supporting investment in the private rented sector. This change is expected to be worth £385m a year from 2028/29.
Planning opportunity
- There is a time limited window to take advantage of Multiple Dwellings Relief so it is worth considering expediting any qualifying transactions where possible and working with your tax adviser to understand the implications of the upcoming removal of the relief.
The economy
Commenting on the outlook for the UK economy, Guy Foster, chief strategist at RBC Brewin Dolphin, said:
“The Office of Budget Responsibility (OBR) forecast that UK GDP growth is expected to recover modestly in 2024 and more significantly in 2025. This follows two years of economic activity weighed down by inflation and rising interest rates. The economy entered recession, but it was a technical recession, which may yet be revised away as inflation has fallen faster than had been anticipated whilst employment remains strong.
Against this backdrop, the political necessity of cutting taxes ahead of an election met the economic reality of having relatively little scope to do so. Signs of largesse in this budget could be self-defeating if markets feared a return of inflation, as it would cause mortgage rates to rise.
A reduction in national insurance will boost the incomes of the vast majority of employees, albeit quite modestly for many. However, those giveaways should be seen in the context of frozen tax thresholds that have pushed many taxpayers into higher tax rates.”
Looking to the future
The Spring Budget could be the Conservatives’ last fiscal event before an election and were there to be a change in government later this year, the new ruling party would surely set about putting their own stamp on the country’s finances.
For individuals navigating the impact of these ever-changing rules on their financial plans, diversity in the structures in which they hold wealth is important. As we’ve seen with ISAs this year and pensions in 2022, changes in rules may favour one structure over another, so remaining diverse in your allocation allows for an adaptable plan.
For those seeking to manage this impact, there remains a range of tools available; from ISAs and pensions to international bonds and family investment vehicles, as well as a number of schemes that reduce tax liabilities such as Enterprise Investment Schemes and Venture Capital Trusts.
Please note: The information provided should not be mistaken for formal planning advice; it is imperative that you seek relevant advice for your own personal circumstances. RBC does not provide tax or legal advice and we would recommend that you seek appropriate advice in these areas. Rates of tax will be based on individual circumstances and tax rules are subject to change.
The value of investments, and any income from them, can fall and you may get back less than you invested. Forecasts are not a reliable indicator of future performance and investment values may increase or decrease as a result of currency fluctuations. This does not constitute tax or legal advice. Tax treatment depends on the individual circumstances of each client and may be subject to change in the future. Information is provided only as an example and is not a recommendation to pursue a particular strategy. Information contained in this document is believed to be reliable and accurate, but without further investigation cannot be warranted as to accuracy or completeness.
[1] Office for Budgetary Responsibility
[2] https://www.gov.uk/government/statistics/statistics-on-non-domiciled-taxpayers-in-the-uk/statistical-commentary-on-non-domiciled-taxpayers-in-the-uk–2
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