spring budget 2023

Charter Tax Consulting Ltd

Spring Budget
15 March 2023
Client Summary Note


Introduction

Today, Chancellor Jeremy Hunt delivered his second Budget.  He stated with conviction that the UK is not expected to go into a technical recession this year though of course as we’ve all learned by now, what’s said today can change tomorrow.  That said, the Budget was upbeat, and generally business friendly.  We saw in particular a strengthening of the R&D regime and various business investment reliefs, including the confirmation of proposed investment zones.

Those looking to pay into their pensions will also be very pleased that the lifetime allowance has been lifted – albeit the 25% tax free lump sum is effectively capped now instead. Well hidden in some proposals to improve the regime for Agricultural Property Relief is also a statement that the government do not propose any changes to the Business Property Relief regime, which is more good news.

Our non-dom clients will be delighted not to be subject to yet more changes – indeed, the non-dom regime did not so much as get a mention in the Budget!

As ever, should you have any queries on how these Budget changes may affect you or your business, then please do get in touch.

Yours

The Charter Tax team

Changes to Pensions

The amount of tax relieved pensions savings are currently restricted both on the amount you can contribute in any one tax year and over an individual’s lifetime.  These restrictions have been tweaked and tinkered with over the years, but in broad terms have been in place for the last 9 years.

 Changes announced today increase the annual tax efficient contribution limit from £40,000 to £60,000 (subject to the tapering rules), and remove the lifetime allowance (currently £1,073,100) completely from 6 April 2023.  As a result of the removal of the lifetime allowance, the 25% tax free lump sum that can be taken when drawing down on pension savings has been restricted to £268,275 – 25% of the current lifetime allowance.  This will not impact on those who have protected pension pots.  However,  those with protected pension pots will want to take professional advice before considering whether to resume pension contributions as this could severely curtail their 25% tax free lump sum.

The income threshold for the tapering of the annual allowance for higher earners will also be increased from £240,000 to £260,000, with the corresponding minimum tapered amount increasing from £4,000 to £10,000.

The Money Purchase Annual Allowance will also be increased from £4,000 to £10,000 for those already drawing a pension, giving them more flexibility to boost pensions savings.

Taxpayers who have perhaps not contributed to pension schemes for fear of exceeding the lifetime limit should therefore look carefully (and quickly) at whether they should contribute to their pension scheme this year and in future years in order to obtain maximum relief from any carried forward annual allowances, which are lost after three years.

Example:

Mr X had stopped contributing to his pension as he was approaching the lifetime allowance and was concerned that his pension pot would soon exceed the allowance. Mr X’s annual income is £200,000 and he now wishes to contribute to his pension scheme.

Ordinarily, an individual can use unused annual allowances from the previous three tax years. Subject to any transitional rules, it is assumed that these will remain available.

In the 2022/23 tax year, he therefore makes a gross contribution of £100,000, utilising the 2022/23 £40,000 annual allowance and £60,000 of unused allowances from previous years. Mr X receives tax relief at his marginal rate of tax on these contributions.

In 2023/24 tax year, Mr X then makes another gross contribution of £100,000, utilising the 2023/24 £60,000 annual allowance and £40,000 of unused allowances from previous years. Mr X receives tax relief at his marginal rate of tax on these contributions.

Farms - APR and BPR

Our farming and landowner clients will be interested in today’s consultation on the “Taxation of environment land management and ecosystem service markets”.  This brings forward several key issues, though all seemingly trying to positively assist the farming community.

As already pre-announced, there will be three Environmental Land Management Schemes in England going forward, to be rolled out this year end next; a Sustainable Farming Incentive scheme, a Countryside Stewardship scheme and a Landscape Recovery scheme.  In addition, the government is planning to produce a Nature Markets Framework to in effect give Farmers a way to sell carbon credit units through various carbon capture and biodiversity schemes.  The consultation will look at how the sale of such units generated by ecosystem service markets should be taxed.

The other angle that government is reviewing is in relation to the scope of agricultural property relief (APR) for inheritance tax purposes.  The government appear keen to support farmers making long-term land use changes from agricultural to environmental use and so we may well see a widening of the availability of APR in some situations in the coming years.  For example, where land has been farmed but is then given over to one of the environmental schemes, that land may in the future still attract APR whereas at the moment that could be problematic.

Meanwhile, clients will be grateful to learn that a statement has been issued that the government is not considering changes to business property relief.

Capital Allowances

“Full Expensing” – Tax Relief for Companies on Investment in Plant and Machinery

With the end of the super-deduction allowance on 31 March 2023, it was anticipated that Jeremy Hunt would introduce a replacement tax relief to encourage companies to continue to invest in plant, machinery, and equipment for their businesses.

The replacement ‘full expensing’ relief was announced today, which will enable companies (but not unincorporated businesses) to claim the full cost of qualifying plant and machinery in the year of purchase as a First-Year Allowance (FYA).  This means that the full cost of qualifying purchases will be deducted from taxable profits before corporation tax is calculated.

As ever, it’s important to look at the details of the announcement, which confirms that the 100% tax relief will only apply to ‘main rate’ expenditure, which doesn’t include integral fixture and fittings to buildings such as electrical, water and air-conditioning systems.  Integral fixtures and fitting are classified as ‘special rate’ expenditure, and will receive a 50% First-Year Allowance instead, alongside other ‘special rate’ expenditure.

Cars are also excluded from benefiting from the new first-year allowances.

It’s also important to note that the plant and machinery must be new and unused, so second-hand equipment will not qualify for the new full expensing relief.

Due to the way that a later disposal of an asset on which FYAs have been claimed will be calculated, it is likely that using the Annual Investment Allowance first will be beneficial for many companies, with claims for the full expensing relief used after the £1million Annual Investment Allowance has been utilised (see below).

The full expensing relief is available from 1 April 2023 to 31 March 2026, although the Chancellor hinted that they would consider making this a permanent tax relief after that date.

Annual Investment Allowance (AIA)

For those businesses that are unable to benefit from the new Full Expensing regime (such as partnerships and sole-trade businesses), and companies with ‘special rate’ expenditure that only receives 50% First-Year relief, the Annual Investment Allowance is still available to provide 100% tax relief on qualifying plant and machinery purchases of up to £1million in an annual accounting period.

Groups and connected companies that share their Annual Investment Allowance will need to carefully plan their allocation of AIA to maximise tax reliefs, based on the nature of their expenditure and considering possible future disposals of assets acquired.

Electric Vehicle Charge Points

As previously announced, 100% First-Year Allowances on equipment for electric charge points will be extended to 31 March 2025 for Corporation Tax and 5 April 2025 for Income Tax purposes.

Corporation Tax

As previously announced, the main rate of corporation tax will rise to 25% on 1 April 2023.

Rate of tax

The first £50,000 of taxable profits will still be charged at 19% and a tapering system known as marginal relief will increase this rate to the full 25% over the next £200,000 of profits.  All taxable profits over £250,000 will be charged at 25%.

There will then be an effective rate of tax of 26.5% for profits between £50,001 and £250,000.

  • The first £50,000 taxed at 19% gives a tax liability of £9,500.
  • Next £200,000 taxed at 26.5% gives a tax liability of £53,000.
  • The total tax charged on first £250,000 profits is £62,500.

Periods that overlap 1 April 2023 will be pro-rata on an averaging basis for trading profits.  Each of the above bands will also be reduced by the number of associated companies a company has.

Associated companies

The related 51% group company test at S279F to S269H CTA 2010 will be repealed and replaced by associated company rules. This will be the case for its application for determining whether a company is large or very large for quarterly instalment payment.

This reverses the above group test and returns the associated company rules with a company now being associated with another company at a particular time if, at that time or at any other time within the preceding 12 months:

  • one company has control of the other or
  • both companies are under the control of the same person or group of persons

Associated companies structure

Currently, each company is treated independently when assessing the companies for payments on account as they are not part of a 51% group.  They can therefore generate profits of up to £1.5m each before they will join the payments on account regime.

From 1 April 2023, as a result of the changes noted above, Company A and Company B will form part of a corporation tax group when assessing payments on account, due to common ownership.  The threshold of £1.5m will be reduced by the number of companies, in this case 2 and therefore if a company generates more than £750,000 it will be required to make payments on account, with any late payments or under/overpayments attracting an interest charge.  This would also mean any taxable profits over £125,000 (£250,000/2) would be subject to tax at 25%.

To complicate matters further, there is an exception to this rule if it can be shown that Company A and Company B are commercially interdependent, financially, economically and organisationally.

R&D Incentives

As announced in the Autumn 2022 statement, the government had already published changes to the rates of relief provided under both the SME R&D scheme, and the RDEC scheme (which is aimed at larger companies).  Those changes are summarised here on our Autumn 2022 budget commentary. These changes take place from 1 April 2023.

Today, the Chancellor announced additional R&D tax credit relief for small or medium (SME) sized enterprises which undertake intensive R&D activities.

As a result it is envisaged that more companies are likely to fall within the payments on account regime and if you think you may be affected, please get in touch.

Additional Tax Relief for Research and Development Intensive Small and Medium Enterprises

Small and medium enterprises that are loss-making and have qualifying R&D expenditure which forms at least 40% of its total expenditure (as defined by the anticipated legislation) will benefit from the enhanced relief. The R&D tax credit, which enables SMEs to surrender certain R&D losses in exchange from a payment from HMRC, will be at 14.5% compared to the new rate of 10% which applies to non-R&D intensive companies from 1 April 2023.

The effect of the increased tax credit rate is to enable R&D intensive companies to continue to claim a 14.5% tax credit for surrendered R&D losses, as all SME R&D companies could up to 31 March 2023 (prior to the announced reduction in tax credit to 10% from 1 April 2023).

When considering whether a company meets the ‘intensity ratio’ of 40%, R&D and total expenditure of connected companies will be included within the calculation. It is also expected that further anti-avoidance measures to prevent the manipulation of the enhanced relief will be introduced in the final legislation.

Administrative Changes to R&D Claims

In order to tackle abuse of the R&D tax relief system, all claims made after 1 August 2023 will need to be accompanied by a new additional information form which will include additional information about qualifying expenses and the R&D project.

For accounting periods beginning on or after 1 April 2023, companies will also need to inform HMRC in advance that they intend to make an R&D claim.  This will need to be notified via a digital service within six months of the end of the accounting period in which the claim relates, although a notification will not be required where a company has made an R&D claim in one of the preceding three accounting periods.

Theatre, orchestra, and museums and galleries exhibition tax reliefs

The government has continued to support theatres, orchestras, museums and galleries by extending the current rate of corporation tax relief available to qualifying companies for another two years through until 1 April 2025.

This relief allows for an additional deduction to be claimed against taxable profits generated by companies engaging in the production of qualifying theatre shows, orchestral concerts and exhibitions.  Much like R&D credits, if the additional deduction results in a loss, those losses can be surrendered for a payable tax credit.

The rates of relief remain at 45-50% until 1 April 2025 when we will then see rates fall to 30-35%. The reliefs available for theatres and orchestras then reduce to 20%-25% from 1 April 2026, although the relief available for museums and galleries exhibitions will cease at this date.

Audio-Visual tax reliefs

The film, TV and video games tax reliefs will be reformed from 1 April 2024. The new Audio-Visual Expenditure Credit will replace the current film, high-end TV, animation and children’s TV tax reliefs.

The government will use the Research and Development Expenditure Credit (RDEC) as a basis for the expenditure credits. Relief is given as a credit against the company’s tax liability at rates of 34% or 39% the qualifying expenditure, although the amount of credit given is also added to the company’s taxable profits. The credit rates will be as follows:

Audio-Visual Expenditure Credit (AVEC):

  • Films and high-end TV programmes will have a headline rate of 34%
  • Animations and children’s TV programmes will have a headline rate of 39%

Video Games Expenditure Credit (VGEC):

  • Headline rate of 34%

There are minimum expenditure thresholds in place. The credit must not be higher than the company’s total expenditure on it’s workers’ PAYE and NICs for the accounting period or the excess is carried forward for use in future periods.

Restricting the Charitable reliefs for UK Charities

Previously charities or Community Amateur Sports Clubs (CASC) located in the UK, the European Union or European Economic Area could qualify for charitable tax reliefs in the UK.

Flexing its Brexit muscles, the government today announced changes so that to get relief, the charities do need to be UK registered charities.  For CASC’s, this means they must be based and provide the facilities for eligible sports in the UK in order to qualify for relief.  A transitional period will exist for EU/ EEA charities who have so far received relief.

Share Schemes

 Share schemes provide an important way for many companies to incentivise and remunerate employees. The Government had asked for evidence regarding the highest level Enterprise Management Incentive (EMI) scheme through which smaller companies can provide up to £250,000 to key employees. The call for evidence was expanded to the more restrictive Company Share Option Plan (CSOP) arrangements.

Minor changes to EMI schemes have been made in this Budget, simplifying administration of the scheme.  In particular, from 6 April 202 the requirement to sign a working time declaration will be removed.  In addition, from 6 April 2024, the deadline for notifying an Enterprise Management Incentives option will be extended from 92 days following grant to 6 July following the end of the tax year.

The more significant change is for CSOP – EMI’s smaller cousin. Following representations that the jump from EMI to CSOP (for example when the company becomes too large to qualify for EMI) was too large, the share options limit for CSOP will be doubled to £60,000. The restriction on the types of shares which are eligible will also be relaxed by removing the “employee controlled” condition. This is still a significant step down from EMI, but will surely make the scheme more attractive to companies who cannot use EMI.

Seed Enterprise Investment Scheme (‘SEIS’)

SEIS offers tax relief to investors buying shares, to help small start-up companies raise money.  The relief offers initial tax relief of 50% to investors on investments up to £100,000.

There are various conditions in place that a company must meet to be eligible for the scheme.  In particular:

  • Gross assets must not exceed £200,000, and
  • The new qualifying trade must be less than two years old.

As of 6 April 2023, these conditions are relaxed so to increase to £350,000 and three years respectively.

Furthermore, as of 6 April 2023, the amount on which SEIS tax relief can be claimed by investors will be increased to £200,000.

Capital Gains Tax

Divorce

As previously promised, the government will legislate to relax the no gain / no loss rule for divorcing spouses and civil partners, meaning that the previous rather restrictive time period will not be relevant. Instead, parties will have up to three years after the year of separation, and no gain / no loss will apply to transfers as part of a formal divorce agreement. Main residence relief will also be expanded to be available to the party retaining an interest in the family home.

For capital gains tax purposes, a disposal is charged when there is an unconditional exchange, rather than when the asset is conveyed to the new owner. Where conveyance is delayed, this can put HMRC or taxpayers at a disadvantage when it comes to claiming reliefs / assessing liability. The proposed change will amend the relevant dates to operate by reference to conveyance rather than exchange.

Carried interest

Fund managers receiving carried interest taxable in more than one jurisdiction may find that tax credits in the two countries do not tie up exactly due to timing differences in the liabilities. HMRC will therefore provide an election which can be made whereby the carried interest can be taxed on the accruals basis rather than on the receipts basis. There will be a computation in the legislation when published outlining how this will work.

Top-Up Taxes for Multi-National and Large Groups

 As previously reported, in support of the G20’s aim to ensure that multinational groups pay their fair share of tax in the jurisdiction that they operate in, the UK is introducing two additional ‘top-up’ taxes to ensure that a minimum effective tax rate of 15% is paid by large groups with headquarters in the UK and large companies with operations in the UK.

The top-up taxes are aimed at groups with global annual revenues in excess of €750 million, and is another measure aimed at the likes of Amazon and Google to ensure that they pay a fair amount of tax in the jurisdictions that they operate in.

The UK does already have various anti-avoidance measures designed to prevent profits being shifted outside of the UK tax net (transfer pricing and diverted profit tax – which was hailed as the Amazon tax when it was first introduced - to name just a few) but one assumes that either these must not have quite hit the mark in respect of the level of tax collected or that politically the government wanted to be clear that it was meeting the G20’s above stated aim.

The government’s report suggests that from 2024 onwards, it expects to raise an additional £2 billion in taxes through these new measures therefore there must be an expectation that these new introductions will finally increase the tax collection from the world’s biggest enterprises.

Multinational Top-up Tax – Groups with Global Annual Revenues in Excess of €750 million

This will introduce a new tax on UK parent members within a multinational group if the parent company has direct or indirect interests in an entity located in a non-UK tax jurisdiction and the groups profits arising in that non-UK jurisdiction are taxed at a rate below the 15% minimum rate.

Domestic Top-up Tax - Groups with Global Annual Revenues in Excess of €750 million

This will apply to UK companies within a large UK or multinational group, and will levy the top-up tax where the groups profits arising in the UK are taxed at a rate below 15%.

The new taxes will take effect for accounting periods beginning on or after 31 December 2023 and will involve additional reporting requirements to HMRC to show how the top-up taxes have been calculated for every jurisdiction.

Calculations and Exemptions

There are of course detailed calculations that will be required to determine the effective tax rate in each jurisdiction, and the allocation of profits between the appropriate jurisdictions.

When calculating the ‘top-up’ amounts for a jurisdiction which has an effective tax rate of below 15%, for the multinational top-up each jurisdiction will be able to deduct a substance-based income exclusion which will amount to 5% of the eligible payroll costs in relation to that jurisdiction and 5% of the accounting value of tangible fixed assets located in that jurisdiction, before applying the top-up percentage to the resultant profits remaining. This we assume is to ‘reward’ groups that have some substance and operations in some of their jurisdictions and penalise those that have no operations in a jurisdiction beyond perhaps owning some IP.

There will also be a de minimis exclusion which will enable a group to elect for the top-up tax to be nil where the average revenue in the relevant jurisdiction is less than €10million and the average profit is less than €1million.  Initially, there will also be some safe harbour jurisdictions which will exclude operations in lower-risk jurisdictions in the short- term.

It remains to be seen if the introduction of these measures, which will undoubtedly be complex to calculate and comply with, will have the desired impact or the level of tax collection predicted by the Treasury.

Transfer Pricing Documentation - Introduction of Prescribed Format

As highlighted in the Autumn statement 2022, from 1 April 2023, the government is introducing a prescribed and standardised format for transfer pricing documentation to provide clarity to large multinational businesses operating in the UK on the records they are required to maintain.

The standardised documents will need to include a master file containing information relevant for all group members and a local file detailing the material transactions specific to the UK tax payer.

For the largest multinational groups with global revenues over €750 million, country-by-country reporting is already a requirement, and must contain aggregate data on the global allocation of income, profits and taxes paid by tax jurisdiction. This isn’t being expanded to smaller multinational groups.

Transfer Pricing is formally required for companies or groups that have more than 250 employees and either annual turnover over £10million or gross assets over £50million, and broadly requires adjustments to corporation tax returns where transactions with connected parties have not been undertaken on an arm’s length basis.

Investments Zones

The creation of new Investment Zones were first announced in September 2022, and the framework to allow for these zones will now come into effect as soon as the Spring Finance Bill 2023 is passed.

The eight identified investment zones are within England although the Government is working with the devolved administrations to establish at least one in each of Scotland, Wales and Northern Ireland.

Each Investment Zone will receive funding of £80m. Investment Zone areas can opt to use a mix of tax reliefs and spend or only spending, therefore if a place chooses not to take up tax reliefs for the designated tax sites then they will have a larger spending envelope available to them.

The below tax reliefs can be offered to businesses in the Investment Zone, although as stated, the areas can opt to offer none or a mix of them.

Available Tax Reliefs

The following tax reliefs are available for businesses where made available:

  • Stamp Duty Land Tax (SDLT): a full SDLT relief for land and buildings bought for commercial use or development for commercial purposes
  • Business Rates: 100% relief from business rates on newly occupied business premises, and certain existing businesses where they expand in Investment Zone tax sites.
  • Enhanced Capital Allowance: 100% first year allowance for companies’ qualifying expenditure on plant and machinery assets for use in tax sites.
  • Enhanced Structures and Buildings Allowance: accelerated relief to allow businesses to reduce their taxable profits by 10% of the cost of qualifying non-residential investment per year, relieving 100% of their cost of structures and buildings over 10 years.
  • Employer National Insurance Contributions relief: zero-rate Employer NICs on salaries of any new employee working in the tax site for at least 60% of their time, on earnings up to £25,000 per year, with Employer NICs being charged at the usual rate above this level. This relief can be applied for 36 months per employee.

VAT

Penalty regime

We have previously highlighted a change in the VAT penalty regime that took effect on 1 January 2023.

A link to our help sheet can be found here:-

https://www.charter-tax.com/wp-content/uploads/2022/12/Helpsheet-New-VAT-Penalty-System-from-1-January-2023-Copy.pdf

HMRC have clarified that when HMRC makes an assessment to recover money, because HMRC has made a payment or repayment to a taxpayer which is too high, late payment interest will be charged from the date HMRC made the original payment. Currently, the interest is charged 30 days after the date of the assessment.  This will ultimately result in a higher interest charge.

For businesses who use the VAT Annual Accounting Scheme, late payment interest and late payment penalties will not be charged on instalments that are paid late. Late payment interest and late payment penalties will still apply to any balancing payment that is not paid on time.

In order to align various taxes, the government have announced when the following changes will be made:-

  • The changes to repayment interest take effect from the date of Royal Assent to the Spring Finance Bill 2023.
  • The changes to late payment interest take effect from 15 March 2023.
  • The changes to late payment penalties take effect from 1 January 2023.

VAT on Energy Saving Materials

The government has requested feedback on whether the list of Energy Saving Materials that qualify for VAT Relief should be expanded to include new technologies that are not currently included on the official qualifying list.

Currently, the installation of Energy Saving Materials in residential accommodation in Great Britain is subject to a temporary zero-rate for VAT until 31 March 2027, when the VAT rate will revert to 5%.

The following items are considered as qualifying Energy Saving Materials benefitting from the zero-rate of VAT:

  • Controls for central heating and hot water systems
  • Draught stripping
  • Insulation
  • Solar panels
  • Ground source heat pumps
  • Air source heat pumps
  • Micro combined heat and power units
  • Wood-fuelled boilers
  • Wind turbines
  • Water turbines

Once the Windsor Agreement is ratified, the government will look to extend these reliefs to Northern Ireland.

The government are also asking for feedback on whether the above VAT relief should be reinstated for installations in a building intended solely for a relevant charitable purposes, as this relief was withdrawn in 2013 as it was not compatible with EU law. One can’t imagine anyone answering “no” to this question…

Consultation on Expanding the Cash Basis

The cash basis is an optional basis for calculating taxable income for certain unincorporated businesses. The cash basis calculates taxable income based on the period in which money is paid and received, whereas the accrual basis calculates this based on the period the income and expenses relate to. The cash basis is therefore a simplified method available for the self-employed with a turnover of less than £150,000, although, once in the scheme turnover can increase to £300,000 until the taxpayer must exit the cash basis and move to the accruals basis.

A consultation period has been opened to discuss the below expansion of the scheme although other ideas are welcomed.

Consultation Points

  • Increasing the turnover thresholds for businesses to use the cash basis – either to align with the VAT cash accounting scheme (with entry and exit thresholds of £1.35m and £1.6m respectively) or to remove the threshold completely
  • setting the cash basis as the default basis, with an opt-out for accruals
  • increasing the £500 limit on interest deductions in the cash basis – the government is currently considering options to increase the limit to £1,000
  • relaxing restrictions on using relief for losses made in the cash basis – losses currently generated under the cash basis are restricted in that they can only be offset against profits of the same trade, whereas the proposals would offer greater flexibility akin to the accruals basis

Many larger businesses will anyway be incorporated so not eligible for the expanded cash basis but for unincorporated businesses the option to use cash accounting will be well worth reviewing in due course.

Tax Administration

HMRC are inviting consultations for 12 weeks on modernising PAYE and income tax self assessment (ITSA) as part of its modernisation strategy, launched in 2020. The move towards digital is inevitable and not without its own difficulties, and the paper does highlight the £40million spent each year on postage by HMRC! With MTD pushed back by a further two years (to 2026), our earnest hope is that HMRC will invest sufficiently in their staff and digital resources to make going digital an improvement rather than an unwelcome headache.

Two other points arising from the Budget in relation to tax administration affect those at opposite ends of the spectrum:

  • HMRC have been given additional powers to withhold payments to people and organisations subject to financial sanctions
  • Individuals who assign away their tax refund to (in our view unscrupulous) firms who take a large cut of any refund are legally entitled to the money and cannot assign away the refund in this way 

Sundry

Low income trusts and estates

We have since 2016 had a situation where trustees and personal representatives have been removed from the requirement to declare and pay tax on income where the only source of income is savings income amounting to less than £100.  This was only supposed to be a temporary measure when introduced.

Following a consultation that took place between April 2022 and 18 July 2022, the government have announced the following changes for trusts and estates with income less than £500 with effect from 6 April 2024.

  • No tax will be due on income up to £500. For trusts, where the settlor has made more than one trust this will be restricted to the higher of £500 divided by the number of trusts in existence or £100.
  • In relation to accumulation and discretionary trusts, the default basic rate and dividend ordinary rate of tax that applies to the first £1,000 of income will be removed.
  • Beneficiaries in receipt of distributions from UK estates that fall within the £500 limit for personal representatives will not be taxed on the income.

In advance of these changes, HMRC will be making technical amendments to ensure that, for beneficiaries of estates, tax credits and savings allowances will continue to operate correctly with effect from 6 April 2023.

Changes to Tax Relief for crypto assets

A further announcement in the small print of the budget documents released after the Chancellor sat down was that from the tax year 2024/25 self assessment tax returns for individuals, trusts and estates will be updated such that amounts in relation to crypto assets will be separately identifiable.

We are finding more of our personal tax clients are now investing in the growing area of crypto assets, and this change highlights the fact that this is an area the HMRC may well be focusing on in the future.  Indeed, some non-dom clients are still caught out not realising that the purchase of crypto can potentially be regarded as a remittance, so tax advice should always be sought before entering the crypto markets.

National Quantum Strategy  Paper

The Government today issued a “National Quantum Strategy” paper.  The message is that the Government are looking to support business in becoming a world leader in the development of quantum technology.  The level of support for this area is impressive, at £2.5 billion over the coming 10 years.  Of key interest from a tax perspective is that as part of this plan the UK will proactively seek to attract, retain and invest in talent in this area, as well as attract foreign companies to bring their quantum tech businesses to the UK.   Visa routes to the UK will be updated to include additional routes for highly skilled individuals and entrepreneurs in the sector.

Quantum computing is arguably the next revolutionary step in the way we use technology so the level of Government support for this sector is exciting.

Review of the business rates system

The government is looking to review the valuations used in the business rates system every 3 years in an attempt to reflect changes in current economic conditions.

Childcare Support

As expected the Chancellor has announced changes to the childcare system aimed at helping parents return to work should they wish to.  Working parents will be able to claim 30 hours of free childcare per week for 38 weeks per year from the time their child is 9 months old until they start school

Any Questions?

Please get in touch if you have any queries. 

CHARTER TAX CONSULTING LIMITED

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