UK Chancellor’s Spring Budget Would Abolish Tax Regime for Non-Domiciled Individuals

The Chancellor proposed that the present regime, whereby the overseas income and gains of non-domiciled individuals are not subject to UK tax for a period if they are not remitted to the United Kingdom, will be abolished. This will be replaced by a simpler system exempting such receipts for a 4-year period after an individual becomes resident in the UK. There will be transitional arrangements for a 2-year period.

The other significant measures announced in the Chancellor's speech are as follows:

Business Taxes

• The primary rate of Class 1 National Insurance on employees' earnings will be reduced from 10% to 8% from 6 April 2024.
• The rate of Class 4 National Insurance on the earnings of self-employed individuals and partners will be reduced from 8% to 6% from 6 April 2024.
• Full expensing – the ability to deduct expenditure in full in the year in which it is incurred – will be extended to leased assets.
• The income threshold at which a business must register for value added tax (VAT) will increase from GBP 85,000 to GBP 90,000 from 1 April 2024.
• The furnished holiday letting regime will be abolished with the aim of improving the availability of property for long-term letting.
• Higher tax reliefs will apply to the cost of producing visual effects in high-end TV and film.
• Eligible film studios will receive a 40% relief on gross business rates until 2034.
• A new tax credit will apply to independent British films with a budget of less than GBP 15 million.
• The audiovisual expenditure credit for film, high-end TV and video games will be increased by 5% and the 80% cap for visual effects costs will be removed.
• The tax reliefs for theatres, orchestras, museums and galleries will be made permanent at rates of 45% for touring and 40% for non-touring productions.
• Air passenger duty will be increased on non-economy flights.
• The energy profits levy will be extended from March 2028 to March 2029, but could be abolished if market prices fall to historic levels sooner than expected.

Individual Income Tax

• The 28% higher rate of capital gains tax on real property will be reduced to 24%.
• The child benefit higher income charge – which currently applies to individuals – will be changed to a system based on household income from April 2026. From 2024, the income threshold will rise from GBP 50,000 to GBP 60,000. From that limit, the benefit will be gradually withdrawn at a rate of 1% for every GBP 200 of income up to an upper limit of GBP 80,000.
• A new individual savings account (ISA) – the "British ISA" – will allow investors to save up to GBP 5,000 a year into UK equities, with the usual ISA tax exemptions. This will be in addition to the existing GBP 20,000 limit for existing ISAs.

More information on the UK spring budget 2024 is available here.