This Summary covers the key tax changes announced in the Chancellor’s speech
and includes tables of the main rates and allowances.
At the back of the Summary you will find a calendar of the tax year with important
deadline dates shown.
We recommend that you review your financial plans regularly as some aspects
of the Budget will not be implemented until later dates.
We will, of course, be happy to discuss with you any of the points covered in
this report and help you adapt and reassess your plans in the light of any
legislative changes.
Work in progress
The Autumn Budget 2024 was the first delivered by a Labour Chancellor since 2010, and the first ever delivered by a woman.
Some things did not change: the objective of all Chancellors is to build a better Britain, to encourage growth, to support the NHS.
The objectives Rachel Reeves laid out would not have seemed out of place in any of her predecessors’ speeches.
On a change of government, it is also normal to blame the previous administration for the lack of money. This was the Conservative line in 2010; in July, Labour announced that there was a huge undeclared ‘black hole’ in the public finances that would have to be filled. In the weeks leading up to the Budget, there was constant speculation about how Ms Reeves would raise the tax her rebuilding plans would require. In the event, some of the fears proved unfounded – no changes to the tax free lump sum from pension funds, no extension of the freeze on income tax bands beyond the already distant horizon of April 2028. But there were immediate rises in the rates of Capital Gains Tax, confirmation of the VAT charge on private school fees, and abolition of most of the tax advantages of being a ‘non-dom’. The biggest tax increase by far was a substantial increase in Employers’ National
Insurance Contributions: it was a relief that this will only apply from the beginning of
the next tax year, after the complications of in-year changes that previous Budgets
have imposed. It prompted a furious debate about whether this was, in fact, a ‘tax
on working people’, contrary to Labour’s manifesto pledges.
There was, as always, a huge amount of information in the documents that are
released on the internet the moment the Chancellor sits down. It is also possible to
miss the impact of changes that were announced earlier and which are only now
coming into effect. In this document we have summarised the latest proposals and
their impact, and also included reminders of some of those earlier announcements.
If you would like to discuss what it all means for you, we will be happy to help.
Significant Points
Personal tax rates and allowances on income continue to be frozen at current
levels – no increases until 2028/29
No changes to income tax reliefs on pension schemes
Substantial increases in Employers’ National Insurance Contributions from 6 April 2025
Increase in Capital Gains Tax rates from 30 October 2024
Stamp Duty Land Tax surcharge for buying additional dwellings increased from
31 October 2024
Confirmation that VAT will apply to private school fees from January 2025
Major changes to taxation of ‘non-doms’ from April 2025
IHT agricultural and business property reliefs restricted from April 2026
Personal Income Tax
Tax rates and allowances – 2025/26 (Table A)
In 2023, the previous Chancellor announced that the main personal allowance and
the 40% threshold will remain at their 2022/23 levels until the end of 2027/28. This
has been widely criticised as a ‘stealth tax’, in that it increases the tax collected
without apparently increasing rates or reducing allowances. For example, a person
with a salary of £50,270 will pay £7,540 in income tax in 2024/25; if their income
increases by 10% to £55,297 in any of the years to 2027/28, all of the increase will
be taxed at 40%, and they will pay £9,551.
The income level above which the personal allowance is tapered away also remains
£100,000; it will be reduced to zero when income is £125,140, which is also the
threshold for paying 45% tax. In the tapering band, the loss of tax-free allowance
creates an effective marginal rate of 60%. Once again, annual increases in income
will bring more people into these higher rates.
It was suggested that the new Chancellor could exploit this possibility for raising
revenue, while keeping to the letter of Labour’s manifesto promises, by extending
the freeze for another two years. In the event, she declared that the inflation-linked
increases to the main bands and allowances, which applied in most years before
2022/23, will resume for 2028/29 and later years. However, many more people will
move into higher rates in the intervening three and a half years.
High Income Child Benefit Charge (HICBC)
The HICBC continues to apply to the higher earner of a couple where one receives
Child Benefit and either of them has income of more than a set threshold. For 2024/25
the threshold is £60,000; the band of income over which the clawback is calculated is
£20,000 (1% of the total benefit for every £200 of income), so that the whole benefit is
lost when income reaches £80,000. The HICBC is one reason that an individual might
have to register for self-assessment and file a tax return.
In March, Chancellor Jeremy Hunt announced plans to reform the HICBC from April
2026 to take into account the combined income of the household, rather than just
the higher earner. This would reduce the unfairness of clawing back nothing from
a couple each earning £59,000, compared to full clawback where one of the couple
earns £80,000. Chancellor Rachel Reeves has decided not to proceed with this plan.
The charge will therefore remain dependent on the income of the higher earner of
the couple.
Scottish and Welsh rates – 2025/26 (Table A)
The Scottish government has the power to set its own income tax rates for Scottish
taxpayers for non-savings, non-dividend income. Many Scottish taxpayers now pay at
higher rates of income tax than those elsewhere in the UK, although some low earners
pay less. The Scottish Budget, which will confirm the rates for 2025/26, will take place
on 4 December 2024.
The Welsh government has similar powers for Welsh taxpayers but has not yet varied
the main UK rates. The draft Welsh Budget will be published on 10 December 2024
and will be finalised by 25 February 2025.
Dividend
The dividend allowance exempts some dividend income from tax, although that
income still counts towards the higher rate thresholds. For 2025/26, the allowance is
unchanged at £500. As HMRC does not routinely receive information about dividends
received by taxpayers, more people may have to file tax returns to declare tax liabilities
which previously would have been covered by the allowance (which was £2,000 up to
2022/23).
The tax rates on dividend income over £500 remain unchanged. The ordinary rate,
paid by basic rate taxpayers, is 8.75%, the upper rate is 33.75%, and the additional rate
is 39.35%. These rates apply across the UK.
The 33.75% rate also applies to tax payable by close companies (broadly, those under
the control of five or fewer shareholders) on ‘loans to participators’ that are not repaid
to the company within 9 months of the end of the accounting period.
Recent reductions in the dividend allowance and increases in the tax rates on
dividends and capital gains add to the relative attractiveness of holding shares in
a tax-free ISA or in a Venture Capital Trust (VCT). Dividends arising in an ISA or a
qualifying VCT are not taxed and do not count towards the allowance.
Savings Income
The savings allowance remains £1,000 for basic rate taxpayers, £500 for 40%
taxpayers and nil for 45% taxpayers. People with savings income above these limits
may have to declare it in order to pay tax.
The savings rate band remains at £5,000. Non-savings income is treated as the ‘first
slice’ of income, using the tax-free allowance and the savings rate band; if any of the
£5,000 band is not used by this ‘slice’, any savings income falling within that band is
taxed at 0%.
Foreign domiciled individuals
It was the Labour Party’s idea to abolish ‘non-dom’ status, so it is unsurprising that
Rachel Reeves is taking forward (with some modifications) the principal changes
outlined by Jeremy Hunt in the March 2024 Budget. These changes are complex
and can only be briefly summarised here; anyone who is or may be affected by
them should take detailed advice.
Abolition of remittance basis
The Chancellor confirmed that, from 6 April 2025, those who are resident in the UK but
domiciled overseas (broadly, those whose natural or permanent home is outside the
UK) will no longer have access to the ‘remittance basis’ of taxation, which up to now
has allowed them to elect to not be taxed in the UK on foreign income and gains if
they leave the money overseas.
New basis of taxation
The new regime will be known as the FIG (foreign income and gains) regime. UK
residents will be taxable on their worldwide income and gains, regardless of whether
they are remitted to the UK. However, new arrivals will not be taxed on foreign income
and gains for their first 4 years of residence, if they have not been UK resident in the
previous 10 years.
There are transitional rules to deal with people who were taxed on the remittance
basis before 6 April 2025 who have unremitted income and gains, and the removal
of some of the protection from tax that has been available using certain types of trust.
For the first three years of the new rules, a reduced rate will apply to people bringing
previously unremitted income and gains to the UK – they will pay tax, but they will
then have free access to the money.
CGT rebasing
As a transitional provision, those who have claimed remittance basis in the past will,
for CGT purposes, be able to rebase the CGT cost of any foreign assets that they held
on 5 April 2017 to their value at that date. In some cases, this will significantly reduce
the CGT liability on a disposal from 2025/26 onwards.
Other aspects
There are also significant changes to the assets that will be within charge to IHT for
those previously regarded as foreign domiciled, and to Overseas Workday Relief that
can exempt them from UK tax on earnings derived from non-UK duties.
Employees
Company Cars (Table C)
The basis for taxing company cars and fuel provided for private use is set out in the
Table. Annual increases in the rates for use of the car had been set up to 2027/28,
and a further two years have been added (to 2029/30) ‘to provide long-term certainty
for taxpayers and industry’.
The rates will continue to provide a strong incentive to use electric vehicles, while rates for hybrids will be increased to align more closely with the rates for internal combustion engine vehicles. The figure used to calculate the benefit of free use of business fuel for private journeys increases with inflation from £27,800 to £28,200.
The taxable amounts for the availability of a van for more than incidental private
use, and for an employee’s private use of fuel in a company van, increase in line with
inflation: the van benefit will rise in 2025/26 from £3,960 to £4,020, and the fuel benefit
will rise from £757 to £769.
Double Cab Pick Ups
Commercial vehicles are treated more favourably than cars for employees who drive
them and their employers. Following a Court of Appeal judgement, the government will
treat double cab pick-up vehicles with a payload of one tonne or more as cars for the
purposes of employees’ taxable benefits and employers’ capital allowances.
The new treatment will apply to vehicles purchased on or after 1 April 2025 (for
corporation tax) or 6 April 2025 (for income tax). The existing capital allowance rules
will apply to vehicles purchased before those dates; the existing benefit in kind rules
will apply to employers that have purchased, ordered or leased a vehicle of this type
before those dates until the earliest of disposal, lease expiry or 5 April 2029.
National Insurance Contributions (NIC)
Thresholds and rates (Table D)
In his 2023 Autumn Statement, Jeremy Hunt announced a reduction in the main rate
of Employees’ Class 1 NIC from 12% to 10% to take effect from 6 January 2024; in the
Spring Budget he cut the rate further to 8% with effect from 6 April 2024. These were
very substantial tax cuts, which the Labour manifesto promised not to reverse: there
would be no increase in the rates of income tax, NIC or VAT ‘for working people’.
Not surprisingly, then, there has been a great deal of argument about a significant
increase in Employers’ NIC (ERNIC). The Chancellor insists that this is a tax paid by
employers which does not appear on the worker’s payslip; however, it increases the
cost of employing people, so there is undoubtedly an indirect effect on the employee.
If ERNIC were lower, the employer might be able to employ more people, or pay higher
salaries.
The increases from 6 April 2025 are twofold: the rate of ERNIC will rise from 13.8%
to 15%, and the Secondary Threshold – the level of pay above which ERNIC applies
– will fall from £9,100 to £5,000. The amount of additional tax raised is estimated at
between £23.7 and £25.7 billion pounds in each year from 2025/26 to 2029/30. The
measure adds about £5 billion each year to the government’s own costs of employing
civil servants.
Whether or not this is an increase in tax on working people, it will increase the
temptation for businesses to seek to contract with self-employed people rather than
employees. The rules on ‘disguised employment’ (commonly known as IR35) have
been the subject of many HMRC investigations and court cases, and this is likely to
increase their relevance.
Employment Allowance (EA)
EA allows businesses with Class 1 ERNIC of £100,000 or less in the previous tax year
to deduct £5,000 from their Class 1 ERNIC bill (as long as there is more than one
employee earning above the secondary threshold). This allowance will be increased to
£10,500 and the £100,000 cap is removed with effect from 6 April 2025.
Class 2 NIC
Self-employed people have for many years had to pay flat rate Class 2 NIC, which
have conferred entitlement to State pension, as well as profit-related Class 4 NIC.
From 6 April 2024, Class 2 NIC are not required to secure benefits for anyone earning
above the small profits threshold, which will rise in 2025/26 from £6,725 to £6,845.
Anyone earning less than that can still pay Class 2 voluntarily (£182 in 2025/26) in
order to maintain a full contribution record.
Savings & Pensions
Individual Savings Accounts (ISA)
The investment limits for ISA have not changed since 2017/18: they are £20,000 for
a standard adult ISA (within which £4,000 may be in a Lifetime ISA), and £9,000 for
a Junior ISA or Child Trust Fund. These will now remain fixed until 5 April 2030.
Pension contributions (Table B)
In advance of the Budget, there was speculation that the Chancellor could raise
significant tax revenues from pension schemes: she might restrict the tax relief on
pension contributions or change the rules on drawing benefits, or impose Employer
NIC on employer contributions to employees’ funds. On the other hand, this could
also have discouraged pension saving and could have been seen as a tax on
‘working people’. In the event, she made no changes.
The maximum amount that can be withdrawn as a tax-free lump sum remains
£268,275 unless the person is entitled to ‘protection’ in relation to the original
introduction of the Lifetime Allowance or any of the subsequent reductions of
the limit.
The only changes relating to pension funds were a specific change to the rules
involving transfers of UK pension funds to other foreign arrangements, with effect
from 30 October 2024, and the inclusion of unused funds and death benefits in the
IHT estate on death from 6 April 2027, described in the IHT section below.
Capital Gains Tax
Rates and annual exempt amount
Labour made no manifesto commitments on CGT and it was widely anticipated that
there would be significant rises in rates, perhaps even bringing them up to income tax
levels. In the event, a number of changes were announced, but they did not go that far.
From 30 October 2024, the main CGT rate for all assets is now 24% (other than
receipts of carried interest, which remains at 28%). This 24% rate previously only
applied to residential property that was not exempted under principal private
residence (PPR) relief. Where the gain can be matched against the taxpayer’s basic
rate band, the rate is now 18% for all assets. Previously it was 10%, except for
residential property and receipts of carried interest.
From the same date, the CGT rate payable by trustees and personal representatives
increases from 20% to 24% (other than receipts of carried interest, where it remains
28%).
From 2025/26, the rate of CGT on carried interest will increase to a flat rate of 32%
for individuals, estates and trusts. From 2026/27, carried interest will be brought
within income tax, subject to a multiplier of 72.5% in some cases.
The CGT annual exempt amount remains £3,000 for individuals and estates and
£1,500 for most trusts.
Business Asset Disposal Relief (BADR)
The lifetime limit for qualifying gains, which attract a 10% tax rate, remains £1 million.
However, for 2025/26, the BADR rate will rise to 14% and, in 2026/27, it will become
18%.
Another relief, Investors’ Relief, can also give a 10% tax rate to qualifying investors
in qualifying companies for which they do not work. The lifetime limit is cut from
£10 million to £1 million from 30 October 2024 and the rate of tax will rise in line
with BADR.
There are anti-forestalling rules that may prevent taxpayers benefitting from the
previous lower rates, where contracts are entered before the dates of change and
do not complete until afterwards.
Inheritance Tax (IHT)
Rates
The IHT nil rate band has been fixed at £325,000 since 6 April 2009. The Chancellor
extended the freeze on this figure for two further years until the end of 2029/30.
Holding the threshold at the same amount for 21 years from 2009 to 2030 will bring
far more people into the scope of the tax. However, the £175,000 ‘residential nil rate
band enhancement’ on death transfers can reduce the impact where it applies.
A married couple may be able to leave up to £1 million free of IHT to their direct
descendants (£325,000 plus £175,000 from each parent), but the rules are
complicated, and the prospect of the nil rate band being fixed for another 5 years
increases the importance of proper IHT planning.
Reliefs
It was widely predicted that the Chancellor would reform some of the generous
reliefs that can be used to protect the value of an estate from IHT. She announced
two significant changes to apply from 6 April 2026.
Agricultural Property Relief and Business Property Relief can, at present, provide a
100% deduction from the value of qualifying assets. From 6 April 2026, this will only
apply to the first £1 million of total value of agricultural and business property in an
estate. Above that value, the relief will be restricted to 50%.
Shares quoted on certain markets of recognised stock exchanges, such as AIM, have
been eligible for 100% relief once they have been owned for two years (provided the
company is a qualifying trading business). This relief will be restricted to 50% for any
such shares, regardless of total value, from 6 April 2026.
Meanwhile, from 6 April 2025, Agricultural Property Relief will be extended to land
managed under an environmental agreement with, or on behalf of, the UK government
or other approved responsible bodies.
Pension Savings
It was also widely predicted that the Chancellor would end the ability to leave a
pension fund free of IHT on death. She has announced that this change will take effect
from 6 April 2027: unused pension funds and death benefits payable from a pension
into a person’s estate will become chargeable, restoring the position before the 2015
pension reforms.
Business Tax
Business rates
During COVID-19, temporary business rates relief was introduced to support the retail,
hospitality and leisure (RHL) sectors. This short-term measure was extended several
times, but the current 75% relief is due to end on 31 March 2025.
The government plans to bring in permanently lower business rate multipliers from
2026/27 for RHL properties with rateable values under £500,000. For properties over
this rateable value a higher multiplier will apply. This will, for example, affect the
majority of large distribution warehouses used by online companies.
To provide support in the interim, business rates relief will be extended from April
2025 but reduced to 40% and capped at £110,000 per business. Many high street
businesses, pubs, restaurants and shops may see higher business rates as a result.
The small business multiplier will be frozen for 2025/26 at 49.9p, while the standard
multiplier will be uprated by inflation to 55.5p.
Private Schools
As announced on 29 July, private schools will no longer be eligible for charitable
rate relief from April 2025. Private schools which are wholly or mainly concerned
with providing full-time education to pupils with an Education, Health and Care Plan
will remain eligible for relief.
Umbrella Companies
To tackle the significant levels of tax avoidance and fraud in the umbrella company
market, the government will make recruitment agencies responsible for accounting for
PAYE on payments made to workers that are supplied via umbrella companies. Where
there is no agency, this responsibility will fall to the end-client business. This will take
effect from 6 April 2026.
Furnished holiday lettings (FHL)
The March 2024 Budget announced that the tax advantaged treatment of FHL will be
abolished from 6 April 2025. Anyone who has benefited from this treatment up to now,
and who has not yet taken advice about the consequences of the change, should do
so as soon as possible.
Corporation Tax
Rate of Tax
The government has published a Corporation Tax Roadmap in which it is committed
to capping the main rate at 25% and maintaining the small profits rate and thresholds,
as well as key features such as full expensing, Annual Investment Allowance,
Research & Development relief rates, and the Patent Box. This appears to be a
commitment for the whole life of this Parliament.
The main rate of 25% applies to companies with profits over £250,000. The ‘small
profits rate’ remains 19% for companies with profits of up to £50,000. Between
£50,000 and £250,000 there is a tapering calculation that produces an effective
marginal rate of 26.5% on profits between these limits, but an average rate on all
profits of between 19% and 25%. The limits are divided between companies that
have been under common control at any time in the previous 12 months, whether
UK resident or not (subject to certain exceptions, such as dormant companies).
Capital allowances for plant and machinery
In 2023, ‘full expensing’ (100% relief for the cost in the year of purchase) was
introduced for most plant and machinery. It is not currently available to companies
that buy plant to lease out to other businesses. In March 2024, Jeremy Hunt
announced that ‘the government will seek to extend full expensing to leased assets
when fiscal conditions allow’; the October 2024 Budget includes almost identical
wording, but no specific date.
The government will extend for a further year the 100% first year allowances for
qualifying expenditure on zero-emission cars and plant and machinery for electric
vehicle charge points. These will continue to be available to 31 March 2026 for
corporation tax and 5 April 2026 for income tax.
Value Added Tax (VAT)
Registration threshold
The VAT registration and deregistration thresholds increased to £90,000 and £88,000
with effect from 1 April 2024. The March 2024 Budget stated that they will be again
frozen at these new levels, but it does not say for how long. No further details have
been given in October.
Private school fees
Labour made a manifesto pledge to charge VAT on private school fees; it was
expected, up to the election, that this would take effect in September 2025, at the
beginning of an academic year. However, at the end of July it was announced that the
charge would apply from the beginning of January 2025. People running schools and
professional bodies have protested that this imposes a very tight timescale on the
implementation of a complex set of rules on a group of businesses that have never
previously had to be concerned with VAT; nevertheless, the Chancellor has confirmed
that the new rules will not be delayed.
Every private school should be taking advice on how to deal with VAT. The boundaries
between what is chargeable and what remains exempt are not straightforward; the
rules on the recovery of input tax on expenditure are particularly difficult for ‘partially
exempt’ businesses; and the school has to make sure it has registered with HMRC at
the right time, and has the systems in place to record and account for the unfamiliar
tax correctly.
Private hire vehicles
The VAT treatment of private hire vehicles has been thrown into doubt by several court
decisions. The government ran a consultation in 2024 to understand the impact of the
decision, and is considering the responses. In the meantime, further tax cases are due
to be heard in the tax tribunals. Anyone running a taxi firm should pay close attention
to the outcomes.
Property Taxation
Higher Rates on Additional Dwellings (HRAD)
HRAD is a surcharge on the normal rates of Stamp Duty Land Tax (SDLT) that
applies to the purchase of a residential property for more than £40,000 by someone
who already owns an interest in such a property, unless they are replacing their
main residence. From 31 October 2024, the surcharge increases from 3% to 5%. For
example, at present there is no SDLT on the purchase of a single dwelling for up to
£250,000, but if the purchaser already has an interest in a dwelling, the HRAD applies
to make the charge 5%.
Where someone buys a new home before they have sold their existing residence, it is
possible to claim the surcharge back if the sale of the old house is completed within
3 years (as long as that leaves the individual with only one dwelling).
Rate of SDLT
A temporary reduction in the normal SDLT rates expires on 31 March 2025. Up to that
date, the first £250,000 is charged at nil; from 1 April 2025, the band from £125,001 to
£250,000 will once again be charged at 2%. There is also a reduction in the thresholds
for first-time buyer relief: from 1 April 2026, the nil rate will apply to the first £300,000
of a property costing up to £500,000, down from the first £425,000 of a property
costing up to £625,000.
The higher rate of SDLT that applies to certain purchases of residential property
costing over £500,000 by companies increases from 15% to 17% on 31 October 2024.
Annual Tax on Enveloped Dwellings (ATED)
ATED applies to residential property worth above £500,000 that is owned through
companies and other corporate structures, unless the situation qualifies for a relief.
The rates increase automatically each year with inflation and will rise by 1.7% from
1 April 2025, in line with the September 2024 Consumer Prices Index.
Other Measures
Making Tax Digital for Income Tax Self-Assessment (MTD)
The requirement to file tax returns using MTD is due to come into effect from
6 April 2026. Those initially affected by the rules will be those with annual income
from a sole trader business or property, or both together, of £50,000. This will drop
to £30,000 from 6 April 2027. The Budget includes the announcement that the
government is committed to delivering MTD, and will expand the rollout to those with
incomes over £20,000 by the end of the Parliament. Anyone who will be affected
by these rules should make sure they are ready to comply with them in good time:
understanding the requirements and making sure that it is possible to comply with
them is not something that should be done at the last minute.
Compliance and debt management
The Budget includes spending on 5,000 additional HMRC compliance staff and 1,800
additional debt management staff. This is described as an ‘investment’ of £1.662
billion over the next five years that will raise £4.7 billion per year by 2029/30. The
Chancellor described this in her speech as making sure that people pay the tax that
they already owe.
Fuel duty
The March Budget assumed that the 5p cut in fuel duty and the three-year freeze in
duty rates would end in March 2025. The Chancellor decided to maintain the freeze
for another year, and to retain the 5p cut until 22 March 2026. This represents a tax
cut of over £3 billion, by far the largest ‘giveaway’ in this Budget.
National Living Wage (NLW)
From 1 April 2025, the NLW will apply for those aged 21 or over will rise from £11.44
per hour to £12.21, considerably above the rate of inflation. There are also increases
to the rates that apply to workers aged 18 to 20 (£10) and under 18s and apprentices
(£7.55).
Interest on late paid tax
HMRC currently charge interest at 7.5% on tax that is paid late, and credit a taxpayer
with 4% on repayments of tax. These rates rise and fall with the Bank of England
base rate, and the ‘turn’ of 3.5% is built in to the calculation. The Budget includes an
announcement that the rate on late payments will increase by 1.5 percentage points
from 6 April 2025. This appears to be a straightforward increase in HMRC’s turn to 5%.
If you would like to download the whole Autumn Budget Summary 2024, download a copy below.
If you have any questions, please do not hesitate to get in touch with your local branch today.
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