Top of the list will be contacting existing clients who currently benefit from the remittance basis of taxation to break the news (assuming they don’t already know) that April 2025 onwards will be the dawn of a new era and it is time to review their affairs. Settling excluded property trusts may be useful whilst reviewing income and gains in existing protected settlements will be imperative.
Planning for new arrivers may include careful day counting noting that it is intended that split years will count towards the proposed four-year tax advantaged window, as will treaty non-residence years. Perhaps losing a “tie” for the purposes of the SRT to eke out another year of non-residence will be helpful—a slightly reduced rate of CGT encouraging the accommodation tie to go first? Those flying in and out may choose economy seats to avoid the increased rates of Passenger Air Duty.
Taking advantage of the transitional provisions including the temporary repatriation facility will be a no-brainer for some and further rebasing will be welcomed (although one hopes the five-year time delay in the rebasing period does not make valuation too difficult). It remains to be seen what will happen to mixed funds but, at a 12% rate of tax, a commercial view may be taken.
The announcement that existing IHT protections for trusts will continue is welcome news as is the opportunity to contribute to a consultation on the proposals to move to a residence-based regime for IHT. On this front it would appear 2025 will become the new 2006 in terms of the treatment of trusts settled before and after the relevant date.
Dominic Condé-Cole
Senior Associate
Dominic has extensive experience in advising national and international high net worth and ultra high net worth individuals, businesses and listed companies on UK taxation and wealth planning.