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Non-dom changes rumoured

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Tax Journal understands that there is insider Westminster gossip which suggests that the chancellor may be considering changes to his proposals for the replacement of the remittance basis. Having initially been seen to be borrowing Labour’s plans, and later overtaken by the opposition’s tougher stance on non-doms, Mr Hunt is reported to be mulling over a longer guarantee period for foreign income gains brought into the UK and concessions on IHT which could include protection for pre-April 2025 trusts.

James Quarmby, Partner at Stephenson Harwood, said: ‘Remarkably, it seems that the Chancellor is no longer wedded to the four year FIG regime and may be contemplating a longer Italian style fixed fee regime, possibly with a ten year guarantee. 

‘I’m also led to believe that there are “big concessions” on IHT in the pipeline,’ Quarmby added.

Such changes may prove welcome in practice, with the Financial Times reporting increased concerns around the combined effect of non-dom reform and post-Brexit immigration rules on the competitiveness of the UK on the international playing field. The FT quotes Adar Poonawalla, CEO of the Serum Institute of India: ‘If you're going to make it impossible, virtually, for someone to stay there because you’re putting so much either tax burden or these restrictions on movement of labour and human beings, how are you supporting the businesses?’

According to HMRC’s 24 April 2024 technical note on the remittance basis changes, draft legislation is to be published later in 2024, noting that ‘some points of detail concerning IHT will be settled after consultation with representative bodies and other interested parties’. The Treasury’s ‘listening events’ on the proposals continue until 31 May.

Reform of the remittance basis may remain firmly on the chancellor’s agenda, with a recent report by the International Monetary Fund suggesting that stabilising UK debt over the next few years will require additional revenue from somewhere – potentially from higher taxes – leaving little room for extra tax cuts, and casting doubt on the government’s desired roadmap towards further reductions in NICs.

Issue: 1664
Categories: News