25/04/24

UK: HMRC to engage on non-dom changes, while Labour considers investment incentive

As published on: taxjournal.com, Thursday 25 April, 2024. 

HMRC is running a series of external engagement events across May 2024 to hear views on the non-dom policy changes that were announced at Spring Budget 2024. Anyone who wants to attend any of the sessions is asked to register their interest by 3 May using the email address set up for comments on the non-dom proposals ([email protected]).

Multiple sessions, with a mix of in-person and virtual meetings, are planned, starting on Monday 13 May and running up to Friday 31 May.

HMRC says that ‘further details on how the government plans to engage on the technical detail of the legislation, together with details of the Inheritance Tax consultation and Overseas Workday Relief engagement, will be published in due course’.

HMRC’s technical note Changes to the taxation of non-UK domiciled individuals sets out the detail of the proposals.

Meanwhile, in a further policy paper (seen by Tax Journal), the Labour Party has echoed its support for the UK government’s proposed replacement of the remittance basis of taxation, including the four-year arrival window for income tax and CGT and the ten-year window for IHT, but confirms its intention to include all foreign assets held in trust within the scope of UK IHT (opposing the government’s plan to allow individuals to shield assets from IHT using offshore trusts).

On this point, the paper says: ‘The Government should have included this in their consultation as an option but instead have ruled it out. Not doing this will mean hundreds of billions of assets permanently shielded from UK inheritance tax, with approximately £430m in inheritance tax foregone a year.’

Labour also opposes the 50% first-year discount under the government’s proposals, but the paper says that the party ‘will consider whether there should be an investment incentive during the four-year window, so that UK investment income is free of UK tax and not disincentivised versus investment elsewhere in the world’.

Labour is also looking at ways to encourage historical foreign income and gains (FIG) to be brought into the UK to ‘end the legacy of the current non-dom rules’. The government is proposing a two-year window to remit stockpiled FIG to the UK at a lower rate of tax, so the suggestion here seems to be that Labour would seek a longer-term incentive.

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UK HMRC Non-doms Investment

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