In what is likely to be the last opportunity for the Conservative government to announce their Budget plans before the election, Jeremy Hunt has delivered his Spring Statement speech.
This is our summary of the changes that are most likely to affect our clients: SMEs, entrepreneurs, family businesses and those with SSAS pensions.
COMMENTARY
With the backdrop of an upcoming general election and the UK economy falling into recession, there has been a great deal of pre-statement speculation on whether there would be a reform of the non-domiciled tax regime to fund a cut to either income tax or National Insurance rates.
As expected, the Spring Statement did include a further 2% reduction to National Insurance to assist working taxpayers. From 6 April 2024, there will be:
- a 2% decrease in employee’s National Insurance Contributions (NIC) from 10% to 8%, and
- a further 2% reduction in class 4 NIC for self-employed individuals.
The abolition of the non-domicile tax regime from April 2025 was also announced with a transitional period lasting 2 years.
IMPACT FOR PENSIONS
General pension provisions
Following on from the granting of Royal Assent in late February for the legislation removing the lifetime allowance, there was little new content in the Budget relating to pension schemes and certainly nothing like the raft of changes forthcoming this time last year.
Some further detail was provided on last week’s announcement from the Chancellor in relation to future pension fund reforms, including requirements for Defined Contribution (DC) pension funds to publicly disclose their level of investment in the UK, as well as overseas. These form part of the government’s plan to boost the UK economy and increase returns for savers. It is unclear at this stage how, or if, this might apply to Small Self-Administered Scheme (SSAS) pensions, although many SSAS schemes continue to invest in the UK economy either via commercial property or employer loan-backs to support UK SMEs.
There was also confirmation that the government continues to work with the FCA and The Pensions Regulator (TPR) on the Value for Money (VFM) pensions framework. This framework comes with the expectation that regulatory powers will be used to close or wind-up schemes where their scale and performance does not offer value to savers. Further proposals and a consultation are expected shortly.
Impact on SSAS pensions
There appear to be no further changes to the SSAS pension rules specifically.
Contribution limits
There were no changes announced so the limits remain unaltered.
For Defined Contribution Schemes, the maximum annual contribution eligible for tax relief remains at £60,000.
For Defined Benefit Schemes, the maximum annual employer contribution is still likely to be between £150,000 and £180,000 per member per year, depending on actuarial considerations and an individual’s income in the tax year. The amount is based on an actuarial calculation of the contribution required to receive an annual pension of £3,750 (1/16th of £60,000.)
The three years’ carry forward rule for unused annual allowances which is available for contributions to either type of scheme remain unchanged.
When an individual has flexibly accessed a Defined Contribution pension scheme, the tax relief on future pension contributions in the money purchase domain is restricted. This Annual Allowance remains at £10,000.
IMPACT FOR BUSINESS OWNERS, SMEs, AND FAMILY BUSINESSES
Business taxes
The VAT registration threshold increased from £85,000 to £90,000 from 1 April 2024.
The Corporation Tax rate will remain at 25% for companies with annual profits of £250,000 or more.
Personal Taxes
Non-domiciled individual regime
The current tax regime for non-UK domiciled individuals will be abolished and the tax treatment will now follow a residence-based regime. People tax resident in the UK for more than 4 years will pay UK tax on their worldwide income and gains. The new regime will be in effect from 6 April 2025. There will be transitional arrangements in place for a two year period.
Whilst the announced change only covers income tax and capital gains tax, the government has announced the intention to adopt a residence-based system for Inheritance Tax (IHT) and will embark on consultation. The proposed changes include the possibility of a ten year exemption period for new arrivals and a 10-year provision for people leaving the UK and becoming non-UK resident. There was an assurance that no IHT changes will take effect prior to 6 April 2025.
Furnished holiday let income
Furnished Holiday Let (FHL) property income has been taxed under specific rules differing from those applicable to longer term residential lets. The Chancellor announced that the FHL tax regime will be abolished from 6 April 2025. The impact of this change will be dependent on the exact manner of implementation.
Capital gains tax on residential property
The higher rate of capital gains tax payable on the disposal of a residential property has been reduced from 28% to 24%.
High income child benefit charge
The administration of the high-income child benefit charge (HICBC) will move to a household-based system from April 2026. In the meantime, the threshold at which the HICBC is charged will increase to £60,000 (from £50,000) and the full withdrawal of the benefit will not occur until an individual earns £80,000, with the changes taking effect from 6 April 2024.
SDLT
SDLT multiple dwellings relief will be withdrawn from 1 June 2024. Where contracts were exchanged prior to 6 March 2024, transactions will continue to benefit from the relief irrespective of the completion date.
Other Areas
- No changes to the Personal Allowance were announced, which remains frozen at £12,570, and the threshold at which individuals will become liable for the higher rate of 40% will remain at £50,270.
- The additional rate of income tax (45%) remains applicable on income over £125,140.
- The Dividend Allowance that applies from 6 April 2024 is £500.
- The Capital Gains Annual Exemption that applies from 6 April 2024 is £3,000.
- The government will maintain the starting rate for savings (the 0% band for savings income) at £5,000 from 6 April 2024 to 5 April 2025.
- The Chancellor announced a new duty on vaping products from 1 October 2026. There will also be a one-off increase to tobacco duty.
- Air passenger duty on business class flights will be increased.
- There appear to be no changes to the rules relating to Employee Ownership Trusts, Family Buy Outs, Substantial Shareholding Exemption, Investment Companies or Merger and Demerger.
- There had been widespread discussion and speculation before the Spring Statement about the possibility that IHT might be amended. There have been no changes to the IHT rules.
Conclusion
It was clear from the outset that this Spring Statement was a pre-election opportunity for the Chancellor to improve the Conservative’s performance in the polls. The reduction to the National Insurance contributions and the reforms to the HICBC aim to win the middle-earning taxpayer’s vote.
Other recent news – SSAS
Whilst the Chancellor did not announce anything new that would affect SSASs in particular, two days before the Budget, the DWP announced the results of its consultation into a proposed per-scheme levy of £10,000 which would have affected all SSASs, regardless of size.
Whilst it might be argued that the levy was never intended to apply to SSASs, the DWP announced that it would drop the levy plan and instead impose a 6.5% increase in their fees across the board. Common sense has prevailed and the sector breathes a collective sigh of relief.
Contact us
If you would like to discuss any aspect of the Spring Statement with us, please contact your usual WBR representative.
Enquiries relating to new SSAS opportunities should be directed to Alan Godbeer on 07894 607917 or alan.godbeer@wbrgroup.co.uk.
Enquiries relating to tax related consultancy/advisory projects should be directed to Matthew Evans on 07525 499700 or matthew.evans@wbrgroup.co.uk.