Last week’s Autumn Budget and the first for new Chancellor of the Exchequer Rachel Reeves featured £40 billion in tax rises and was announced with the objective of repairing public finances because of £22 billion of “in-year pressures” whilst at the same time establishing a robust foundation for economic growth. However, the April 2025 changes in employer National Insurance Contributions (NICs) will increase the cost of employment for many businesses when combined with the increase in the national minimum and living wage. Smaller employers will be somewhat protected as a result of changes from the same date to the employer NICs employment allowance. The rates of capital gains tax were also increased from Budget Day with the Office for Budget Responsibility (OBR) estimating that this will raise an additional £2.5 billion. And buried in the Budget publications was the news that Making Tax Digital (MTD) for income tax will be extended to unincorporated businesses and landlords with turnover over £20,000 by the end of the current Parliament the precise timing for which will be set out at a future fiscal event. Chartered Accountants Ireland will be challenging the Government on this reduction in the MTD exemption limit. A range of changes to inheritance tax (IHT) were also announced with the aim of ensuring that the wealthiest estates will bear the greatest burden with the scope of agricultural and business property relief to be limited and the news that unused pension funds and death benefits payable from a pension into a person’s estate will be within the scope of IHT in future. The rate of stamp duty land tax on acquisitions of certain residential property in England and Northern Ireland was also increased from 31 October 2024. On the business side, the publication of the previously announced Corporate Tax Roadmap should provide businesses with more certainty and once again confirms that no changes will be made to the current rates of corporation tax, amongst other business taxes areas. The UK’s CT rate is currently the lowest in the G7. A response was also published to the consultation on potential regulation of tax advisers which the Institute responded to earlier this year. The consultation response sets out that from April 2026 the Government will mandate registration of tax advisers who interact with HMRC on behalf of clients. A further consultation will also be published on tackling rogue tax advisers. However, the consultation response is silent on any new measures to regulate the UK tax agent market. HMRC has sent a more detailed email setting out information on the consultation response and is planning a round table meeting later this month to discuss the way forward in more detail. Chartered Accountants Ireland will be in attendance. And finally, the Northern Ireland Executive will receive an additional £1.5 billion in funding in 2025/26 through the operation of the Barnett formula. Read the Institute’s Press Release reacting to the Autumn Budget 2024. The analysis herein is based on the publications of HMRC and HM Treasury. A more detailed analysis of the tax announcements features in the remainder of today’s UK section and will continue in next Monday’s edition of Chartered Accountants Tax News. The Institute’s UK Autumn Budget 2024 page also contains a range of resources. HMRC has also sent an email on the Budget announcements and one specifically for agents. An overview of all the tax legislation and rates announced has also been published.

Some capital gains tax (CGT) rates were increased from Budget Day and the rate of both Business Asset Disposal Relief (BADR), and Investors’ Relief (IR) will be increased in two stages starting from April 2025. A range of significant changes will also be made to inheritance tax (IHT) which will see IHT extended to death benefits payable from a pension into a deceased’s estate, in addition to changes to both business property relief (BPR) and agricultural property relief (APR). Previously announced changes, including the abolition of the CGT and income tax non-domicile regime from 6 April 2025 which will be replaced with a new residence-based regime, were also confirmed.  The territoriality of IHT will also move to a residence-based regime as planned. CGT rate increases For disposals made on or after 30 October 2024, the lower rate of CGT increased from 10 percent to 18 percent, whilst the higher rate increased from 20 percent to 24 percent.  These new rates align with the residential property CGT rates which remain unchanged. Carried interest is a performance-related reward received by a small population of fund management executives. From April 2026, carried interest will be taxed fully within the income tax framework, with bespoke rules to reflect its unique characteristics and a 72.5 percent multiplier applied to qualifying carried interest that is brought within charge. As an interim step, the two CGT rates for carried interest will both increase to 32 percent from 6 April 2025. The Government will also consult on introducing further conditions of access into the regime. CGT BADR and IR As a result of the newly increased rates of CGT, BADR and IR will both increase from 10 percent to 14 percent from 6 April 2025 and to 18 percent from 6 April 2026 to allow business owners time to adjust to the changes. The lifetime limit (LL) for BADR will remain at £1 million. In contrast, the LL for IR reduced from £10 million to £1 million for all qualifying disposals made on or after 30 October 2024. Chartered Accountants Ireland has previously questioned the policy need for IR and its high lifetime limit. The Government has also stated that it is committed to creating a positive environment for entrepreneurship and will work with leading entrepreneurs and venture capital firms on how policy supports that, including the role of existing tax schemes. A commitment was also made to make it easier for start‑ups and scale‑ups to access external sources of financial support. This includes, as already legislated for, extending the Enterprise Investment Scheme and Venture Capital Trust schemes to 2035. Non-UK domiciled status As previously announced, the non-UK domiciled regime, and thus the remittance basis of taxation for CGT and income tax, is being abolished from 6 April 2025. The remittance basis will be replaced with a residence-based regime. Individuals who opt-in to the regime will not pay UK tax on foreign income and gains (FIG) for the first four years of tax residence. Current and past remittance basis users will be able to rebase personally held foreign assets to the assets 5 April 2017 market value on a disposal, subject to certain conditions. Overseas Workday Relief will be retained and reformed, with the relief extended to a four-year period and the need to keep the income offshore removed. The amount claimed annually will be limited to the lower of £300,000 or 30 percent of the employee’s net employment income. The Temporary Repatriation Facility (TRF) is being extended from two to three years until 5 April 2028, expanding the scope to offshore structures, and simplifying the mixed fund rules to encourage individuals to spend and invest their FIG in the UK. The TRF will enable the individual to designate and remit at a reduced rate of tax any foreign income and gains which arose prior to 6 April 2025. This includes unattributed foreign income and gains held within trust structures IHT measures and reliefs IHT thresholds (£325,000 nil rate band, £175,000 residence nil rate band, and the £2 million residence nil rate band taper) will remain frozen at their current levels for a further two years beyond April 2028 until April 2030. Significant reforms to both APR and BPR were also announced. From April 2026, the first £1 million of combined qualifying agricultural and business assets will be entitled to 100 percent relief from IHT with the rate of relief reduced to 50 percent for amounts in excess of £1 million. The rate of BPR will also be reduced to 50 percent for shares designated as “not listed” on the markets of a recognised stock exchange, such as AIM. However, from 6 April 2025 the scope of APR will be extended to land managed under an environmental agreement with, or on behalf of, the UK government, devolved governments, public bodies, local authorities, or approved responsible bodies. As previously announced, the new IHT residence-based regime will commence from 6 April 2025. This includes ending the use of offshore trusts to shelter assets from IHT and scrapping the planned 50 percent tax reduction for foreign income in the first year of the new regime. From 6 April 2027 unused pension funds and death benefits payable from a pension into a person’s estate will be subject to IHT purposes. In doing so the Government aims to restore the principle that pensions should not be a vehicle for the accumulation of capital sums for the purposes of inheritance. £52 million is also being invested to digitalise the IHT service from 2027/28 with the aim of providing a modern, easy-to-use system for making returns and paying IHT.

Last week, the European Commission and the UK concluded technical discussions on a competition agreement between the EU and the UK. The agreement will supplement the EU-UK Trade and Cooperation Agreement. Commenting on the agreement, Margrethe Vestager noted that “with this agreement, the EU and the UK will work together on competition matters in a predictable and transparent framework”. 

It was again confirmed that there will not be any increases in the basic, higher, or additional rates of income tax, or employee National Insurance Contributions (NICs). The freeze on certain personal tax thresholds will also end from 6 April 2028. The treatment of some double cab pick-ups will change from vans to cars and the proposed household income system to assess the high-income child benefit charge will not proceed. Some tax thresholds to be defrosted The freeze on the income tax and employee national insurance thresholds will not be extended beyond 2027/28, meaning that from 2028/29 taxpayers can expect the thresholds to again begin to increase in line with inflation. However, as many of these thresholds will have been frozen since 2020/21, fiscal drag means that the tax burden has and will continue to rise because there have not been any inflationary increases. From 6 April 2025, the employee NICs Lower Earnings Limit (LEL) and the Small Profits Threshold (SPT) will both increase by the September 2024 CPI rate of 1.7 percent. The LEL will be £6,500 per annum (£125 per week) and the SPT will be £6,845 per annum. For those paying voluntarily, Class 2 and Class 3 NICs rates will increase from the same date by the same amount. The main Class 2 rate will be £3.50 per week, and the Class 3 rate will be £17.75 per week. Double cab pick-up vehicles to be treated as cars Following a Court of Appeal judgement, double cab pick-up vehicles (DCPUs) with a payload of one tonne or more will be treated as cars for certain tax purposes. The previous Government had planned to do so from 1 July 2024 as announced last February but did a U-turn on this after representations from industry. From 1 April 2025 for Corporation Tax, and from 6 April 2025 for Income Tax, DCPUs will be treated as cars for the purposes of capital allowances, benefits in kind, and some deductions from business profits. The existing capital allowances treatment will apply to those who purchase DCPUs before 6 April 2025. Transitional benefit in kind arrangements will apply for employers that have purchased, leased, or ordered a DCPU before 6 April 2025. They will be able to use the previous treatment, until the earlier of disposal, lease expiry, or 5 April 2029. High Income Child Benefit Charge (HICBC) reform to household income not proceeding The Government will not proceed with the reform announced in the Spring Budget 2024 to base the HICBC on household income. According to the Budget publications, this is because it would have come at a significant fiscal cost of £1.4 billion by 2029/30. However, to make it easier for all taxpayers to get their HICBC right, employed individuals will be able to pay the HICBC through their tax code from 6 April 2025, and Self-Assessment returns will be pre-prepopulated with Child Benefit data for those not able to do so. Starting rate for savings unchanged This will remain unchanged in 2025/26 at £5,000 and although this will allow individuals with less than £17,570 in employment or pensions income to receive up to £5,000 of savings income tax free, this does not take into account higher interest rates on savings income in recent years. Taxable status of Statutory Neonatal Care Pay The Government will legislate in Finance Bill 2024/25 to clarify the income tax treatment of Statutory Neonatal Care Pay which will ensure the payment is liable to income tax to ensure consistency with the tax treatment of other statutory maternity and paternity pay schemes. Employment related securities changes From 6 April 2025, the notice an employer must provide to an employee under a Share Incentive Plan regarding the possible effect of deductions from salary on entitlement to social security benefits and statutory payments must refer to statutory neonatal care pay. This will be legislated for in Finance Bill 2024/25. Further loan charge review to be commissioned A further independent review of the loan charge will be commissioned to help bring the matter to a close for those affected, whilst ensuring fairness for all taxpayers. Further details about the review will be set out by the Exchequer Secretary in due course.  Company car tax (CCT) rates for 2028/29 and 2029/30 announced The Government announced the rates for CCT for these tax years. CCT rates will continue to strongly incentivise the take-up of electric vehicles, while rates for hybrid vehicles will be increased to align more closely with rates for internal combustion engine vehicles in order to focus support on electric vehicles. The changes are as follows: Appropriate Percentages (APs) for zero emission and electric vehicles will increase by 2 percentage points per year in 2028/29 and 2029/30, rising to an AP of 9 percent in 2029/30. APs for cars with emissions of 1 – 50 g of CO2 per kilometre, including hybrid vehicles, will rise to 18 percent in 2028/29 and 19 percent in 2029/30. APs for all other vehicle bands will increase by 1 percentage point per year in 2028/29 and 2029/30. The maximum AP will also increase by 1 percentage point per year to 38 percent for 2028/29 and 39 percent for 2029/30. This means for vehicle bands with emissions of 51 g of CO2 per kilometre and over, APs will increase to 19 percent – 38 percent in 2028/29 and 20 percent – 39 percent in 2029/30. Qualifying care relief From 6 April 2025, qualifying care relief, the amount of income tax relief available to foster carers and shared lives carers will increase by the September 2024 CPI rate of 1.7 percent.

Revenue has updated the Tax and Duty Manuals which provide guidance on the automatic exchange of information for financial account holders, and the implementation of and filing guidelines for the Foreign Account Tax Compliance Act in Ireland. The updates are intended to provide clarity on the reporting of US tax identification numbers for financial institutions and account holders. Further information is available in eBrief No. 267/24.  

Revenue has updated the Tax and Duty Manual which details Revenue Legislative Services’ guide to interpreting legislation to provide further clarity with regard to the decision in Elliss v BP [1987] 59 TC 474, and its effect on how the term "shall" is to be interpreted in legislation (section 7).  

Revenue has reported that some agents have reached out for support and to acknowledge that their Internal Agent IT security has been compromised. Revenue advises practitioners to review their IT security processes/protocols and remote access for potential risks. Revenue has confirmed that the security of ROS has not been compromised. 

Although no changes will be made to a range of key business taxes as confirmed in the Corporate Tax Roadmap 2024, from 6 April 2025 the rate of employer National Insurance Contributions (NICs) will increase for all employers, and its 0 percent threshold will reduce. This is targeted to raise £26 billion, though it remains unclear if this takes into account the related tax effects of increasing employer NICs such as reduced employee NICs, income tax, and corporation tax. Transfer pricing is to be reformed, and the UK’s carbon border adjustment mechanism (CBAM) will be introduced from 1 January 2027 as planned. A range of enhancements were announced to the suite of the UK’s creative sector reliefs and the Pillar Two Undertaxed Profits Rule (UTPR), the final part of the G20-OECD Global Minimum Tax agreed by over 135 countries and jurisdictions, will take effect for accounting periods beginning on or after 31 December 2024. Corporate Tax Roadmap 2024 The promised Corporate Tax Roadmap 2024 has been published. This reinforces the previous commitment to cap the Corporation Tax Rate at 25 percent and maintain the Small Profits Rate at 19 percent. Marginal relief will also be maintained at its current rate and there will be no changes to Corporation Tax thresholds. Other key business taxes which will remain untouched are Full Expensing, the Annual Investment Allowance, the rates of R&D tax relief, and the Patent Box regime. In the Institute’s Pre-Budget Submission, we raised the importance of certainty and stability for the UK’s R&D tax relief regime, given its instability and the myriad of changes in recent years. The commitment to preserving R&D tax relief is therefore welcome. Employer NICs The rate of employer NICs will increase from 13.8 percent to 15 percent from 6 April 2025 and the secondary threshold will reduce to £5,000 (previously £9,100) from the same date. The secondary threshold is the level at which an employer is liable to pay employer NICs on each employee’s salary. This will remain at £5,000 until 6 April 2028 and will increase in line with CPI thereafter. To support small businesses with these changes, from 6 April 2025 the employment allowance will increase from £5,000 to £10,500 and the £100,000 eligibility threshold will be removed thus expanding this to all eligible employers. The current employment allowance gives eligible employers with employer NICs bills of £100,000 or less a discount of £5,000 on their employer NICs bill. Employer NICs relief for veterans The employer NICs relief for employers hiring qualifying veterans will be extended a further year until 5 April 2026. This means that businesses will continue to pay no employer NICs up to the annual earnings of the veteran’s upper secondary threshold of £50,270 for the first year of a veteran’s employment in a civilian role. Carbon border adjustment mechanism (CBAM) The Government has published its response to the March 2024 consultation on the introduction of a UK CBAM which the Institute responded to earlier this year. The response confirms that the UK CBAM will be introduced on 1 January 2027, placing a carbon price on goods that are at risk of carbon leakage imported to the UK from the aluminium, cement, fertiliser, hydrogen and iron and steel sectors. Products from the glass and ceramics sectors will not be in scope of the UK CBAM from 2027 as previously proposed. The registration threshold will be set at £50,000, retaining over 99 percent of imported emissions within the scope of the CBAM, while removing over 80 percent of otherwise registrable businesses. Over 70 percent of those removed from the CBAM altogether by this threshold are micro, small, or medium sized businesses.   Creative sector reliefs  As previously announced, from 1 April 2025 film and high-end TV productions will be able to claim an enhanced 39 percent rate of Audio-Visual Expenditure Credit on their UK visual effects costs. UK visual effects costs will be exempt from the Audio-Visual Expenditure Credit’s 80 percent cap on qualifying expenditure. Costs incurred from 1 January 2025 will be eligible. This measure will be legislated in Finance Bill 2024/25.   From 1 April 2025, UK films with budgets under £15 million and a UK lead writer or director will be able to claim an enhanced 53 percent rate of Audio-Visual Expenditure Credit, known as the Independent Film Tax Credit. Expenditure incurred from 1 April 2024 on films that began principal photography on or after 1 April 2024 is eligible. Also from 1 April 2025, the rates of Theatre Tax Relief, Orchestra Tax Relief and Museums and Galleries Exhibitions Tax Relief will be set at 40 percent for non-touring productions and 45 percent for touring productions and all orchestra productions. These rates apply UK-wide. Both these measures have already been legislated for.  R&D tax relief  In addition to a detailed email from HMRC’s R&D Communications Forum, the Government will discuss widening the use of advance clearances in R&D reliefs with stakeholders, with the intention to consult on lead options in Spring 2025. A document has also been published setting out further information on the scale and characteristics of error and fraud up to 2023/24, the policy and operational changes that have been made to address this, and further data on taxpayer experience.   Reform of transfer pricing  A further consultation on reforms to the UK’s rules on transfer pricing, permanent establishments, and the Diverted Profits Tax will launch in Spring 2025. This will include the potential removal of UK-to-UK transfer pricing. A consultation will also be published in Spring 2025 on further changes to the transfer pricing rules which will examine proposals such as:   lowering the thresholds for exemption from transfer pricing for medium-sized businesses whilst retaining an exemption for small businesses, and  introducing a requirement for multinationals in the scope of transfer pricing to report information to HMRC on certain cross-border related party transactions.  Alongside this, a review will be conducted on the transfer pricing treatment of cost contribution arrangements, to ensure that the rules are certain and do not act as a deterrent to investment that brings economic benefits to the UK.   Technical amendments will also feature in Finance Bill 2024/25 to provide certainty that Advance Pricing Agreements are available for financing arrangements covered by the Transfer Pricing rules in line with HMRC’s existing Statement of Practice 1 (2012).   Pillar Two UTPR   The UTPR will be included in Finance Bill 2024/25 and will take effect for accounting periods beginning on or after 31 December 2024. Technical amendments to the Multinational and Domestic Top-up Tax legislation will also be included in the Finance Bill to incorporate the latest international updates and stakeholder feedback.   Repeal of offshore receipts for intangible property   The offshore receipts for intangible property rules will be abolished for income arising on or after 31 December 2024, based on the Government’s view that the Pillar Two UTPR will more comprehensively discourage the multinational tax-planning arrangements that these rules sought to counter. Repeal will be legislated for in 2024/25.   Apprenticeship levy  As previously announced, the government will take steps to transform the Apprenticeship Levy (AL) into a more flexible Growth and Skills Levy by investing £40 million, with the aim of delivering new foundation and shorter apprenticeships in key sectors. The reformed levy will be developed in partnership with employers, providers, and learners.   Skills England will take the time to consult with a wide range of partners to ensure that levyfunded training meets the needs of employers, providers, and learners, and secures good value for money. Disappointingly, no mention was made of how this will be taken forward in Northern Ireland where the AL is a devolved function. 

The Parliamentary Budget Office (PBO) has published a briefing paper on budgetary issues in Finance Bill 2024. The paper provides an analysis of measures contained in the Finance Bill 2024 that the PBO believes could have a budgetary impact, and it includes an overview of these measures, including information on possible costs, policy background and policy impact.  Where possible, the PBO has endeavoured to provide information on the cost or yield of a measure, or a policy change as estimated by the Department of Finance.  Amendments to the Finance Bill arising out of this week’s Committee Stage are due for consideration at Report Stage week commencing Monday 18 November. The briefing paper is based on the Bill as published and does not take account of any future amendments. 

On Wednesday, the Chancellor of the Exchequer, Rachel Reeves announced the Labour government’s first Autumn Statement. The government has set out to restore balance in the public finances, however businesses are concerned that they will bear the burden of this rebalancing act. While the need to balance public spending is key to the government’s decisions, the innovative tax policies needed to drive long-term growth and sustainability are not evident in the package announced this week. Chartered Accountants Ireland is particularly concerned that the increase in employers’ National Insurance will not be sustainable for many businesses. While the allowances may provide some protection for the most affected businesses, it is adding to businesses’ already bulging employment costs. You can read our coverage of this week’s Autumn Statement in our Special Tax Newsletter which issued on Wednesday evening. You can also read our press release which issued following the Budget announcement.

In Irish news, Minister Chambers publishes the report on the Funds Sector 2030 review, Revenue publishes the updated RICT Form and readers are reminded that next Thursday 7 November is the deadline for filing Vacant Homes Tax returns. In UK news, read this week's miscellaneous updates, including updates on the plastic packaging tax and the independent film tax credit.  In International news, the European Commission adopts a new proposal to help companies with their filing obligations under the EU Minimum Taxation Directive (Pillar Two).  Ireland 1. The Minister for Finance, Jack Chambers TD has published the report of the Funds Sector 2030 review. 2. Revenue has updated forms for Employment Investment Incentive Scheme. 3. Thursday 7 November 2024 is the return filing deadline for Vacant Homes Tax for the year ended 31 October 2024. UK 4. Read this week's miscellaneous updates, including updates on the plastic packaging tax and the independent film tax credit. International 5. The European Commission adopts a new proposal to help companies with their filing obligations under the EU Minimum Taxation Directive (Pillar Two). Keep up to date with all the latest Irish, UK, and international tax developments through Chartered Accountants Ireland’s Tax Newsletter. Subscribe to the Tax News by updating your preferences in MyAccount. You can also read this week’s EU exit corner here.        

The government has identified a significant ‘tax gap’ across the UK economy. The tax gap is the difference between what should be collected (based on taxpayer data) and what is actually collected. Over the next five years, the government is expanding HMRC’s resources in an aim to bring in an additional £6.5 billion per year in tax revenue. The plan to bridge the tax gap includes a commitment to overhauling HMRC’s IT system. It is proposed that this will improve HMRC’s debt management system by ensuring tax debt is settled faster, making the overall organisation more productive. The government announced that an additional 5,000 compliance staff will be recruited, while 1,800 debt management staff will be maintained and recruited. Taxpayers can also expect digitalisation to simplify interaction with HMRC allowing taxpayers to self-serve and manage their own tax affairs.