As the UK gears up for the General Election on 4 July, significant tax policy announcements have been made by all parties. These announcements could have profound implications for taxpayers across the spectrum.
Updated: 13/06/24
We focus here on the announcements made so far by the Conservative and Labour Parties, as included in their manifestos.
For the details behind some the headlines, we’ll have to wait for a Budget and publication of draft legislation, likely to be September at the earliest.
So, what do we know so far?
Personal taxes
Income Tax
- Conservative and Labour: no increases to the rates of Income Tax or National Insurance for the life of the next Parliament but both parties have also confirmed the freezing of thresholds until 2028.
- Conservative: a ‘triple lock plus’ for UK pensioners. Pensioners would benefit from a future increased personal tax allowance, in order to ensure the basic state pension does not become subject to Income Tax.
- Conservative: the income threshold for the High Income Child Benefit Charge (HICBC) will double to £120,000.
The non-UK domicile regime
- Conservative and Labour:
- Abolition of remittance basis of taxation for ‘non-doms’.
- New residence-based regime: no UK tax on Foreign Income and Gains (FIG) for first four years of UK residence, provided taxpayer has been non-tax resident for the last ten years.
- Inheritance Tax (IHT): move to a residence-based regime from April 2025.
- Non-UK situs assets will be subject to IHT if the owner has been UK tax resident for ten years or more. This will remain the case for 10 years after ceasing to be UK tax resident (the 10-year tail).
- Offshore trusts: new trusts and additions to existing trusts made by a non-UK domiciled settlor on, or after, 6 April 2025 will be subject to new residence-based rules. The protection from tax on no-UK source income and all capital gains arising within settlor-interested trust structures will no longer be available for non-UK domiciled individuals unless they qualify for the new four-year FIG regime.
- Conservative:
- A temporary 50% exemption for the taxation of foreign income for the first year of the new regime.
- Two-year Temporary Repatriation Facility (TRF) to bring previously accrued FIG into the UK at a tax rate of 12%.
- Offshore trusts: trusts settled and funded before April 2025 by a non-UK domiciled settlor would have the ability to remain outside the scope of IHT regardless of the settlor’s status.
- Labour:
- Trusts: all assets held within a trust to be subject to IHT (subject to settlor being UK resident for 10 years).
- Investment incentive during the four-year arrival window so that UK investment income is free of UK tax.
- Further details:
- ‘Non-doms no more‘ – Taxation magazine
- Offshore trustees and non-doms tax strategies
- Non-doms UK tax strategies
National Insurance
- Conservatives: 2% cut to the rate of employees’ National Insurance (NI) by April 2027 with plans to abolish employees’ NI in the longer term and to abolish the main rate of self-employed NI by the end of the next Parliament.
Private equity
- Labour: increase rate of Capital Gains Tax (CGT) on carried interest to equal income tax rates or tax as income.
Inheritance Tax
- No announcements, except for the non-UK domicile regime as above.
Stamp Duty Land Tax (SDLT)
- Conservative:
- £425,000 tax free threshold for first time buyers to be made permanent.
- Introduce a new help to buy scheme to provide first time buyers with an equity loan of up to 20% of the cost of a new build home.
- No changes to the rate.
Capital Gains Tax
- Conservative:
- Introduce a two-year temporary Capital Gains Tax relief for landlords who sell to their existing tenants.
- No increase to the rate.
Pensions
- Labour: re-introduce Lifetime Allowance for pensions, abolished in the March 2023 Budget. The Lifetime Allowance (£1.073m) was a limit on the total value an individual’s private pensions could reach before tax at up to 55% was levied on a pension withdrawal or on reaching age 75.
- Conservative: a ‘triple lock plus’ for UK pensioners, as above.
Corporation Tax
- Labour: Cap the main rate at 25%.
- Conservative: No increase to the rate(s).
VAT
- Conservative and Labour: no increase to the rate of VAT.
- Labour: add VAT to school fees. You can read more here.
We will add further details as we receive them, together with a summary of actions you may wish to consider in advance of the General Election, or certainly the next Budget.
Manifestos
For full details, as published by the political parties, please see:
The SNP manifesto is still to follow.
Contact Katharine Arthur, Partner and Head of Private Client, if you wish to discuss how these proposed tax policies will affect you.
