Tax
UK Ends Permanent Non-Dom Status; Hikes IHT Threshold - Wealth Managers' Reactions

UK finance minister announced a series of measures in the first all-Conservative budget package since 1996. Wealth managers set out their preliminary thoughts.
Today’s budget statement by UK finance minister, or Chancellor of
the Exchequer, George Osborne, hiked the “nil-rate” band on
inheritance tax payments to £1 million ($1.54 million), removed
the notion of being a permanent non-domiciled resident and hiked
the threshold on the 40 per cent income tax rate. The minister
also announced measures to tighten rules on certain practices,
such as “base shifting” in areas of private equity.
This is the first budget by a Conservative-run government since
1996 (for the past five years, Osborne’s Conservative allies were
in a coalition with the centrist Liberal Democrat
Party.)
Here is a collection of reactions from wealth managers and
private client advisors to the measures. This item will be
updated as more reactions come in. (To see the main story,
click here.)
Camilla Wallace, partner at London law firm Wedlake
Bell
"The mere threat of the removal of non-dom status before the
election saw one of our London non-dom clients leave the UK for
Switzerland and several others started to think about where they
would relocate to if the outcome of the election was
unfavourable. With these changes we can expect to see others
follow suit.
"Non-doms are already familiar with the concept of effectively
losing their non-dom status for Inheritance Tax purposes after 17
years in the UK. This measures essentially extends that
treatment to Capital Gains Tax and Income Tax and comes as no
surprise."
Liam Bailey, global head of research at Knight
Frank
On their own, the changes to the non-dom tax rules will not have
a profound impact on the prime London market as demand is driven
by a number of factors, and non-doms form only a part of
demand.
These reforms follow a series of changes in recent years that
make it increasingly difficult to argue prime residential
property is under-taxed. The relatively subdued nature of the
prime London market since December’s stamp duty changes
highlights the risk of higher taxation on market demand and also
Government revenues.
Nimesh Shah, partner, Blick Rothenberg, a firm of
chartered accountants
Major changes announced to the non-domicile rules effectively
mean that non-doms are taxed on their overseas income and capital
gains after 15 years. This isn't aligned with the current
rules on inheritance tax where a non-dom is brought into UK IHT
after 17 years. It would make sense to align all three
taxes but this wasn't mentioned by the Chancellor.
Andy Zanelli, head of retirement planning, AXA Wealth
Plans announced in today’s Budget to introduce an addition to the
inheritance tax (IHT) threshold for property to £1 million
certainly make things interesting. Any increase in the IHT
allowance to allow for the sharp rises in house prices in the
last decade was always going to be a popular move as it would
effectively take aspirational households out of the reaches of a
tax that was never intended to catch them. The new additional
threshold leaves us with an uneven playing field and an
interesting financial planning dilemma. Those people looking at
estate planning now need to consider whether to downsize their
home and potentially invest money elsewhere or leave their money
tied up in property, knowing they can pass it on to their
children free of IHT. The consequence of this move means assets
within an estate are treated differently: my wife and I can leave
a £1 million property to our children without them incurring an
IHT charge, however should we choose to downsize and perhaps
invest some of that money, anything above the current nil rate
band of £325,000 would incur a 40 per cent tax charge. Added to
this, today’s move is likely to help very few families. Figures
verified by the Office of Budget Responsibility suggest that less
than 10%* of the estates that will be subject to IHT in 2015/2016
will be taken out of the IHT net. Is this an announcement that
seems better than it will actually be in practice?
Genevieve Moore, partner at Blick Rothenberg
The Chancellor indicates that tax “planning” will be targeted and
generate savings for this Government not just tax evasion or
avoidance under the microscope now.
Stella Amiss, international tax partner at PricewaterhouseCoopers
This is a bold and surprise move [on corporation tax reduction].Business weren't calling for a further rate reduction, and it's expensive - £6.6 billion over five years. But it sends a clear signal that the Government is pro tax competition and this message may be helpful in attracting overseas business to UK shores. The anti-avoidance measures for corporates were relatively piecemeal. Tinkering around the edges rather than making a big difference.
Frank Nash, Blick Rothenberg
The Chancellor must justify how he has arrived at the £1.5
billion extra tax revenue by abolishing permanent Non-Dom status,
which has so far encouraged substantial investment in the UK.
Andrew Sneddon, partner and head of tax at Trowers &
Hamlins
It is not surprising that the government is targeting
non-domiciled taxation rules, but there is concern that the
abolition of permanent non-domiciled status for long-term
residents risks an exodus of wealthy individuals prior to
reaching 15 years residency. Such individuals will need to review
their position before April 2017.
Institute of Economic Affairs
This Budget was a missed opportunity to bring down the 45p rate
of income tax. When the rate was cut from 60 per cent to 40 per
cent in 1988, tax revenues soared because it created the
incentive to work and invest in Britain. Changes to the 40p
threshold also look feeble, increasing more slowly than wage
growth. Politicians should raise this threshold annually by the
higher of wage growth or inflation to begin to compensate for
years of under-indexing. The announced reforms to
inheritance tax may be headline-grabbing, but are poorly thought
through. Aside from adding additional complexity, the changes may
well lead to a raft of unintended consequences by encouraging
some cash-rich pensioners to upsize if they have the resources to
buy a property for £1 million, further distorting our already
dysfunctional housing market.