They cover: 

• the new Government's proposed tax plans, including in particular the planned changes to non-dom taxation;
• timing considerations; and
• possible reactions by clients to the changes. 

If you would like more information or want to discuss any of the topics in this podcast, please get in touch with David and Paul.

Episode summary

In this latest policy in practice podcast episode, David Gauke, head of public policy at Macfarlanes, is joined by Paul Hardwick, a partner in the private client team, to discuss the tax implications of the recent General Election. They highlight Labour’s manifesto commitments, with a particular focus on significant tax changes such as reforming the tax treatment of UK resident non-UK domiciliaries (non-doms). The podcast delves into the specifics of these proposed changes and their potential impacts on private clients.

Paul explains that the new Government's plans include the abolition of the existing non-dom regime (including the remittance basis of taxation), to be replaced with a new four-year residence-based regime from 6 April 2025. Inheritance tax is also moving from a domicile to a residence-based system. “Protected settlement” status is to be removed from all trust structures, and the future inheritance tax treatment of trusts (in particular, those already in existence) is currently unclear. These changes are expected to bring about uncertainty for clients, particularly those with existing trusts, who will need to adapt to the new tax environment. David and Paul also discuss the need for clients to be prepared for a swift transition once the policies are implemented.

David anticipates that detailed policy changes and draft legislation may be outlined in the upcoming budget announcement, expected in autumn 2024, following an initial review of public spending by Rachel Reeves. In the meantime, Paul advises clients to engage in scenario planning to be ready for various outcomes. The podcast underscores the importance of staying informed and working closely with advisors to navigate the forthcoming tax landscape efficiently.

If you would like a full written transcript of this podcast, please get in touch.

Visit our UK non-dom reforms hub page for more information and analysis of the announcements relating to the reforms as they develop.