Tax Matters: Spring Budget 2024 – The Hunt for Blue October

The Freshfields Podcast

The UK Chancellor of the Exchequer, Jeremy Hunt, has delivered the Spring Budget 2024.

In a rowdy House of Commons, the Chancellor delivered what will be his last Spring Budget before a UK general election widely expected to take place in autumn this year. Further details on some of these measures are expected to follow on Tax Administration and Maintenance Day 2024 – confirmed as taking place on 18 April – but there were plenty of interesting points (and politics) in the tax policies included in this wave of announcements.

In our latest podcast Jill Gatehouse, Emily Szasz, Josh Critchlow and David Haughey from our London tax team discuss some of the tax measures they found the most noteworthy in the Spring Budget 2024, including:

• Replacing the current tax rules for non-UK domiciled individuals (so-called ‘non doms’) with a new residence-based regime;
• Changes to the transfer of assets abroad rules following the Supreme Court decision in Fisher to ensure this anti-avoidance regime cannot be bypassed by individuals transferring assets offshore via a UK company;
• The introduction of Reserved Investor Funds (RIFs), a new type of UK investment fund in the form of an unauthorised contractual scheme; and
• Other changes to the UK’s tax code, including:
  • Further reductions to NICs, benefitting both employed and self-employed workers;
  • On stamp duty/SDRT, new guidance on recently-enacted legislation restricting the application of the higher rate charge on the issue and certain transfers of UK shares and securities into clearance services or depositary receipt systems – but nothing further on the Stamp Taxes on Shares Modernisation proposal;
  • Delaying the sunsetting of the Energy Profits Levy, so that it will end in 2029 (or earlier if energy prices fall below levels set by the previously-announced Energy Security Investment Mechanism);
  • Establishing a new R&D tax relief expert panel tasked with ensuring relevant HMRC guidance remains up-to-date as industry develops; and
  • Consulting on the introduction a new UK ISA, giving individuals a £5,000 annual allowance to invest in certain UK-focussed assets on a tax-free basis.