Tax Matters: Autumn Budget 2024 – Delivering difficult decisions

The Freshfields Podcast

31-10-2024 • 28 mins

The UK Chancellor of the Exchequer, Rachel Reeves, has delivered the Autumn Budget 2024.

In the first Budget delivered by the Labour Party since 2010, Reeves announced an extensive array of tax reforms designed to 'stabilise' public finances and facilitate increased government spending.  Altogether, tax rises totalling £40 billion were announced - some expected, others less so.

In our latest podcast Peter Clements, Sarah Bond, Rose Swaffield, Josh Critchlow and Chris Gotch from our London tax team discuss the tax measures they found the most noteworthy in the Autumn Budget 2024, including:

  • Headline Budget announcements, including:
    • increases in the capital gains tax (CGT) main rates and reforms to business asset disposal relief and investors' relief, accompanied by anti-forestalling measures;
    • an increase in employer National Insurance contributions by 1.2% from April 2025; and
    • an increase in the CGT rates for carried interest from April 2025, with more significant reforms expected to follow;
  • Publication of the Corporate Tax Roadmap designed to provide stability for businesses and foster inward investment, including:
    • capping the headline UK corporation tax rate at 25%;
    • confirmation the permanent 'full expensing' capital allowance regime and existing R&D reliefs will be retained; and
    • plans to provide increased tax certainty to investors in major projects;
  • Measures designed to 'close the tax gap', including:
    • an increase in the interest rate for unpaid tax;
    • targeted anti-avoidance measures applying with immediate effect; and
    • the recruitment of additional HMRC compliance and debt management staff; and
  • Other changes to the UK's tax code, including:
    • confirmation the UK will introduce the Pillar Two undertaxed profits rule (the 'UTPR') for accounting periods from January 2025, along with the related repeal of the offshore receipts in respect of intangible property (or 'ORIP') rules;
    • the replacement of the remittance basis of taxation for non-UK domiciled individuals ('non-doms') with a new residence-based regime; and
    • confirmation of increases to the rate and duration of the Energy Profits Levy and the removal of the associated investment allowance.

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