Changes to the Tax Rules for Non-Domiciles

Changes to the Tax Rules for Non-Domiciles

Understanding Domicile and Its Tax Implications

The UK tax system has long allowed individuals to be taxed differently depending on their domicile status. This has provided opportunities for non-domiciled taxpayers to make tax savings on overseas income and assets. However, from 6 April 2025, significant changes to the tax rules for non-domiciles will take effect, replacing the current system with a residence-based approach.

 

What Is Domicile?

Domicile refers to an individual’s permanent home and is distinct from nationality, residence, or citizenship. It is typically acquired at birth from the individual’s father (or mother if the father is unknown). While it is possible to change domicile, this generally requires moving to another country and severing ties with the previous one.

 

Current Tax Implications of Domicile

Domicile status has played a key role in both Income Tax and Inheritance Tax (IHT):

  • Income Tax:
    • UK residents who are UK domiciled are taxed on their worldwide income as it arises.
    • UK residents who are non-UK domiciled can opt for the remittance basis, meaning they only pay UK tax on income brought into the UK.
  • Inheritance Tax (IHT):
    • UK domiciled individuals are subject to IHT on their worldwide estate.
    • Non-UK domiciled individuals only pay IHT on UK assets.

 

Changes to the Tax Rules for Non-Domiciles

From 6 April 2025, the concept of domicile for tax purposes will be abolished, and a residence-based system will be introduced.

 

Changes to Income Tax

  • The remittance basis will be scrapped and replaced with a new 4-year Foreign Income and Gains (FIG) regime.
  • Individuals who move to the UK after at least 10 years of non-UK residence will not pay tax on foreign income and gains for their first four tax years.
  • After the four-year period, they will be taxed on their worldwide income and gains like any other UK resident.
  • Those who have already been UK resident for less than four years (following 10 years of non-UK residence) as of 6 April 2025 can use the FIG regime for any remaining qualifying years.

 

The Temporary Repatriation Facility (TRF)

  • This facility allows individuals who previously used the remittance basis to remit untaxed foreign income and gains at a lower tax rate.
  • The tax rate on designated funds will be:
    • 12% for 2025–26 and 2026–27
    • 15% for 2027–28
  • Individuals can choose when to remit designated amounts to the UK, even after the TRF window closes.

 

Changes to Overseas Workdays Relief (OWR)

  • OWR will continue but will be based on residence and limited to four years.
  • An annual cap will apply, set at the lower of:
    • 30% of qualifying employment income, or
    • £300,000 per tax year.

 

Changes to Inheritance Tax

  • From 6 April 2025, a residence-based IHT system will apply.
  • Individuals who have been UK resident for at least 10 of the past 20 tax years will be classified as Long-Term Residents.
  • Long-Term Residents will be subject to IHT on their worldwide assets, similar to UK-domiciled individuals.
  • A “tail provision” means this IHT liability continues for up to 10 years after an individual leaves the UK, depending on their period of UK residence.

 

How We Can Help

These changes to the tax rules for non-domiciles mark a fundamental shift in the UK tax system. If you are a non-domiciled individual, it is essential to review your tax position ahead of April 2025.

 

At Lewis Brownlee, our tax specialists can help you:

  • Understand how these changes affect your personal tax situation.
  • Plan for the transition to a residence-based system.
  • Explore tax-efficient ways to manage foreign income, remittances, and inheritance planning.

 

If you need expert advice on navigating the new tax rules for non-domiciles, get in touch with our team today.

 

Tax Director, Tom Foster
Author Bio

Tom Foster – Tax Director

Tom is the Head of Taxation at Lewis Brownlee. Having joined the firm from a top 20 accountancy practice in March 2014. His expertise and dedication led to his promotion to Tax Director in April 2017. With over 25 years of experience as a general tax practitioner, Tom has a wealth of knowledge in assisting both individuals and businesses to manage their tax affairs efficiently and legally.

Tom’s areas of expertise include Capital Gains Tax, Inheritance Tax Planning, EMI Share Schemes, Property Taxation, Personal Tax Planning, EIS and SEIS, Trusts and Estates, Research & Development, and Tax Investigations.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on your tax matters.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube

Understanding Enterprise Investment Scheme Relief (EIS)

Understanding Enterprise Investment Scheme Relief (EIS)

Enterprise Investment Scheme (EIS) relief was introduced to encourage investment in smaller, private British businesses. To support this, several tax incentives are available, making EIS an attractive option for investors.

 

What tax reliefs are available?

The Enterprise Investment Scheme relief offers several tax advantages, including:

 

Income Tax Relief

The main benefit is a 30% income tax reducer. This can be claimed in the year of investment or carried back to the previous tax year. However, EIS relief cannot be carried forward.

The maximum investment that qualifies for tax relief is £1 million per tax year.

 

Capital Gains Tax (CGT) Exemption

If EIS shares are held for at least three years before being sold, any gains made on them are free from CGT. However, income tax relief must have been claimed on these shares, and the relief must not have been withdrawn.

 

CGT Deferral Relief

Capital gains made on other assets can be deferred if the proceeds are reinvested into EIS shares. This applies if the investment was made within one year before disposal or up to three years after.

For sales made after 30 October 2024, the CGT rate on these deferred gains will be:

  • 24% for higher-rate taxpayers
  • 18% for basic-rate taxpayers

 

EIS Loss Relief

If EIS shares result in a loss, investors can offset this loss against their income tax instead of CGT. The loss relief is calculated after deducting any previously claimed 30% income tax reducer.

 

Inheritance Tax (IHT) Relief

EIS shares held for at least two years at the time of death can qualify for 100% relief from Inheritance Tax (IHT) up to 5 April 2026. After this date, up to £1 million will still qualify for 100% relief, with the excess benefiting from 50% relief—resulting in an effective IHT rate of 20%.

 

Seeking professional advice on EIS relief

While Enterprise Investment Scheme relief offers valuable tax benefits, there are specific conditions that must be met to claim these reliefs. If you are considering investing in EIS shares or have already done so, our tax specialists can help ensure you maximise the available reliefs.

We provide expert tax advice, ensuring that you navigate EIS relief effectively. Please get in touch to discuss how we can assist you.

 

Please note: This blog only considers the tax implications of EIS investments and does not constitute investment advice.

Tax Director, Tom Foster
Author Bio

Tom Foster – Tax Director

Tom is the Head of Taxation at Lewis Brownlee. Having joined the firm from a top 20 accountancy practice in March 2014. His expertise and dedication led to his promotion to Tax Director in April 2017. With over 25 years of experience as a general tax practitioner, Tom has a wealth of knowledge in assisting both individuals and businesses to manage their tax affairs efficiently and legally.

Tom’s areas of expertise include Capital Gains Tax, Inheritance Tax Planning, EMI Share Schemes, Property Taxation, Personal Tax Planning, EIS and SEIS, Trusts and Estates, Research & Development, and Tax Investigations.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on your tax matters.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube

Late Payment Interest: What You Need to Know

Late Payment Interest: What You Need to Know

The Government announced in the Budget that late payment interest charges will increase from 6th April 2025. Currently, HMRC applies an interest charge of 2.5% above the base rate on outstanding tax liabilities. This will rise by 1.5%, bringing the new rate to 8.75%, up from 7.25%.

With late payment interest increasing, taxpayers should ensure they meet their deadlines to avoid unnecessary costs.

 

The Impact of Late Payment Interest

Late payment interest can accumulate quickly, resulting in significant additional costs. A common reason for late tax payments is that taxpayers are unaware of their liability, often because they leave their tax return until the last minute.

If you are unsure how much tax you will need to pay in January, it is best to complete your tax return early. This gives you time to plan and arrange payments, avoiding unexpected financial strain.

 

Reducing Payments on Account – Proceed with Caution

Some taxpayers choose to reduce their payments on account to lower their immediate outgoings. However, if these payments are reduced too much, late payment interest charges will apply. Careful planning is essential to avoid unexpected interest costs.

 

Executors and Inheritance Tax

Executors handling estates should also be mindful of late payment interest. Those paying inheritance tax via instalments can be exposed to additional charges. Where possible, clearing tax liabilities quickly can help minimise costs. Instalment payments should only be used when absolutely necessary.

 

Should You Consider a Loan to Cover Tax Payments?

In some cases, taking out a short-term loan to cover a tax payment may be worth considering. If the interest rate on the loan is significantly lower than HMRC’s late payment interest, this could be a more cost-effective option.

 

How We Can Help

With tax rates already high, avoiding unnecessary interest charges is crucial. Our expert tax team can help you manage your tax liabilities efficiently, ensuring you meet deadlines and minimise costs.

 

If you have any questions or need assistance with your tax payments, speak to a member of our tax team today.

☎️ Chichester: 01243 782 423  ☎️ Midhurst: 01730 817 243  ☎️ Whiteley: 01489 287 782

Tax Director, Tom Foster
Author Bio

Tom Foster – Tax Director

Tom is the Head of Taxation at Lewis Brownlee. Having joined the firm from a top 20 accountancy practice in March 2014. His expertise and dedication led to his promotion to Tax Director in April 2017. With over 25 years of experience as a general tax practitioner, Tom has a wealth of knowledge in assisting both individuals and businesses to manage their tax affairs efficiently and legally.

Tom’s areas of expertise include Capital Gains Tax, Inheritance Tax Planning, EMI Share Schemes, Property Taxation, Personal Tax Planning, EIS and SEIS, Trusts and Estates, Research & Development, and Tax Investigations.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on your tax matters.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube

Farming-focused strategies for agricultural IHT relief

Farming-focused strategies for agricultural IHT relief

Changes to Inheritance Tax (IHT) rules coming into effect in April 2026 could have significant implications for farming families. The government plans to cap the amount of 100% IHT relief on business and agricultural assets to £1 million. While some argue that reliefs still effectively amount to £3 million, the reality may be more complex. Careful planning and farming-focused strategies for agricultural IHT relief will become even more critical in this changing landscape.

 

Understanding the New IHT Cap

From April 2026, the £1 million cap on IHT relief for agricultural and business assets will apply per individual. While this may sound generous, there’s a crucial limitation: the £1 million relief is not transferable between spouses. This means that a surviving spouse cannot inherit the unused portion of the cap from their deceased partner.

To complicate matters, estates worth over £2.7 million lose access to the residential nil rate band, further reducing potential reliefs. For many farming families, this will create significant tax liabilities.

 

A Farming Family Example

Let’s explore a typical scenario:

  • A married couple owns a small farm valued at £2 million, with their home (not qualifying as a farmhouse) worth £600,000.
  • They have £400,000 in savings, bringing total assets to £3 million.
  • Reciprocal Wills leave everything to the surviving spouse, with the estate passing to their children on the second death.

Under the new rules, the surviving spouse cannot use the first spouse’s unused IHT cap. Combined with the loss of the residential nil rate band, this leaves only £1.65 million in reliefs. The remaining estate is subject to tax, resulting in a £540,000 IHT bill.

For families who have owned farms for generations, this liability could force the sale of the farm to meet the tax obligation.

 

How Does the £3 Million Relief Apply?

The government’s claim of £3 million in reliefs depends on specific circumstances. If the first spouse to die leaves their £1 million share of the farm directly to their children, this transfer is exempt. The surviving spouse’s estate then reduces to £2 million, preserving eligibility for:

  • £1 million for agricultural relief,
  • £650,000 from standard nil rate bands, and
  • £350,000 from the residential nil rate band (with the transferable element).

This illustrates the importance of careful planning and Will structuring to maximise available reliefs. Without strategic decisions, farming families risk missing out on significant tax benefits.

 

Why Careful IHT Planning Matters

The new cap aims to prevent investors from gaining excessive IHT relief. However, it could disproportionately affect genuine farming families and other small business owners. The distinction between active farmers and investors already exists in current rules. Extending this principle might have been a fairer solution.

Regardless, the changes highlight the need for farming-focused strategies for agricultural IHT relief. Proactive planning can help families preserve their assets and safeguard their farming legacies.

 

How We Can Help

At Lewis Brownlee, we specialise in Agricultural Accounting and Horticultural Business Accounting. Our team of Chartered Accountants and Tax Advisers has extensive experience in helping farming families navigate complex IHT rules.

We provide tailored advice to help you:

  • Structure your Wills and estate to maximise IHT relief.
  • Plan intergenerational transfers to protect your family farm.
  • Understand the new IHT rules and their impact on your assets.

With our farming-focused strategies for agricultural IHT relief, we can help secure the future of your business and minimise tax liabilities.

Contact us today to arrange a consultation and start planning for the changes ahead.

 

☎️ Chichester: 01243 782 423  ☎️ Midhurst: 01730 817 243  ☎️ Whiteley: 01489 287 782

Lewis Pridgeon
Author Bio

Lewis Pridgeon – Tax Compliance Manager

Lewis joined the tax team in 2013 and has since become a full member of the Association of Taxation Technicians. He has extensive knowledge across many areas of tax and accountancy, with a particular focus on personal tax clients. Lewis has developed expertise in advising non-resident landlords and specialises in agricultural and horticultural tax planning.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on your tax matters.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube

Avoid Missing the Tax Return Deadline: Key Information You Need

Avoid Missing the Tax Return Deadline: Key Information You Need

Avoid Missing the Tax Return Deadline: Key Information You Need

As the 2023/24 tax return deadline of 31 January 2025 approaches, it’s crucial to act promptly to avoid penalties. Whether you’re filing a personal, partnership, or trust return, ensuring your tax affairs are in order is essential. Here’s what you need to know and how we can help.

 

Understanding the Tax Return Deadline

The electronic submission deadline for all 2023/24 self-assessment returns is 31 January 2025. This applies if you’ve received a notice to file more than three months ago. Missing this deadline will result in a £100 late filing penalty, with further penalties accruing if the delay continues beyond three months.

In addition to filing, any tax owed must also be paid by 31 January 2025. Late payments will incur interest at 8.75% starting from 6 April 2025, so prompt action can save you money and stress.

 

Why Early Preparation Matters

Filing your tax return can be a complex process, and preparing a complete and accurate submission takes time. By providing your financial information to us early, you’ll allow us to ensure everything is in order before the tax return deadline. This reduces the risk of errors and gives you peace of mind.

If you’ve received a notice to file but are unsure whether you need to complete a return, we can help. Notices to file can be cancelled if the criteria for submission are not met, but this needs to be resolved promptly to avoid unnecessary complications.

 

 

How We Can Help

As Chartered Accountants and Tax Advisers, we specialise in making tax compliance simple and stress-free for our clients. Here’s how we can assist you:

  • Accurate Preparation: We’ll ensure your tax return is complete and correct, avoiding penalties.
  • Tailored Advice: Unsure if you need to file? We can clarify your situation and act on your behalf to resolve notices.
  • Timely Filing: By working together, we can meet the tax return deadline with time to spare.

Don’t leave your tax return to the last minute. Contact us today to get started and make the 2023/24 tax return season worry-free.

☎️ Chichester: 01243 782 423  ☎️ Midhurst: 01730 817 243  ☎️ Whiteley: 01489 287 782

Tax Director, Tom Foster
Author Bio

Tom Foster – Tax Director

Tom is the Head of Taxation at Lewis Brownlee. Having joined the firm from a top 20 accountancy practice in March 2014. His expertise and dedication led to his promotion to Tax Director in April 2017. With over 25 years of experience as a general tax practitioner, Tom has a wealth of knowledge in assisting both individuals and businesses to manage their tax affairs efficiently and legally.

Tom’s areas of expertise include Capital Gains Tax, Inheritance Tax Planning, EMI Share Schemes, Property Taxation, Personal Tax Planning, EIS and SEIS, Trusts and Estates, Research & Development, and Tax Investigations.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on your tax matters.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube

Key Tax Points from UK Budget 2024: Bite Size Summary

Key Tax Points from UK Budget 2024: Bite Size Summary

Our Tax Director, Tom Foster, provides a bite-sized summary of the key tax points from the UK Budget 2024. This latest budget introduces impactful tax changes that could affect both individuals and businesses. Here, Tom breaks down the essentials, giving you a clear overview of what’s changing and when. As a firm of Chartered Accountants and Tax Advisers based on the South Coast, we’re here to help you navigate these updates with ease and confidence.

 

Changes Effective Tomorrow

Increase in SDLT Surcharge
Starting tomorrow, the Stamp Duty Land Tax (SDLT) surcharge on additional property purchases will increase from 3% to 5%. This update affects individuals looking to buy second homes or investment properties and highlights the government’s efforts to moderate property investment.

When it comes to giving tax advice, I prefer to deal with knowns and certainties. Advising action based purely on rumours or potential changes can lead to unnecessary tax liabilities. That said, it’s crucial to align your tax planning with your intentions. For instance, if you weren’t already planning on selling, gifting, or investing, there’s often no sense in making hasty decisions purely out of fear of the unknown.

 

Changes Effective from April 2025

Employer National Insurance Contributions (NICs)
Employer NICs will rise from 13.8% to 15%, while the secondary (employer) threshold will reduce from £9,100 to £5,000. Small businesses will see an increase in the employment allowance, which rises to £10,500. These changes may lead to increased payroll costs for businesses, affecting budgets and hiring strategies.

Capital Gains Tax (CGT) on Non-Residential Property
The CGT rate on non-residential property gains will increase from 10% to 18% for basic rate taxpayers, and from 20% to 24% for higher-rate taxpayers. This brings CGT rates in line with residential property gains, which remain unchanged.

Business Asset Disposal Relief
Contrary to speculation, there is no immediate change to business asset disposal relief. However, from April 2025, the tax rate will increase to 14%, with further rises expected. 

 

Inheritance Tax (IHT) Adjustments

Frozen Nil Rate Bands
The nil rate bands for inheritance tax remain frozen until 2030. However, from April 2026, a £1 million cap will be introduced on 100% relief for Business Property Relief (BPR) and Agricultural Property Relief (APR). Relief on AIM holdings will be limited to 50%, and from April 2027, inherited pension funds will also be subject to IHT.

 

How We Can Help

Navigating these tax changes can be challenging, especially with new rules impacting areas like SDLT, CGT, and IHT. As a firm of Chartered Accountants and Tax Advisers, we’re here to provide personalised guidance and help you understand the key tax points from the UK Budget 2024. Whether you’re an individual, small business, or large enterprise, our team on the South Coast can help you make informed decisions to optimise your tax position and plan for the future.

Reach out to us today to discuss how we can assist you in navigating these changes efficiently.

☎️ Chichester: 01243 782 423  ☎️ Midhurst: 01730 817 243  ☎️ Whiteley: 01489 287 782

Tax Director, Tom Foster
Author Bio

Tom Foster – Tax Director

Tom is the Head of Taxation at Lewis Brownlee. Having joined the firm from a top 20 accountancy practice in March 2014. His expertise and dedication led to his promotion to Tax Director in April 2017. With over 25 years of experience as a general tax practitioner, Tom has a wealth of knowledge in assisting both individuals and businesses to manage their tax affairs efficiently and legally.

Tom’s areas of expertise include Capital Gains Tax, Inheritance Tax Planning, EMI Share Schemes, Property Taxation, Personal Tax Planning, EIS and SEIS, Trusts and Estates, Research & Development, and Tax Investigations.

Let us guide you through the details and help you prepare for what lies ahead. Contact us for expert advice on how to approach the key tax points from UK Budget 2024 tailored to your financial goals.

If you’d like to speak to one of our experts, please call 01243 782 423. Alternatively, please email us from our contact page and we will be in touch!

We also update our YouTube channel regularly with new content, see here: Lewis Brownlee YouTube