Autumn Budget 2024 — Overview of tax legislation and rates (OOTLAR)-沙之星跨境

This document sets out the detail of each tax policy measure announced at Autumn Budget 2024 and of previously announced measures that will be included in Finance Bill 2024-25. It is intended for tax practitioners and others with an interest in tax policy changes, especially those who will be involved in consultations both on the policy and on draft legislation.

Chapter 1 — Finance Bill 2024-25

Personal Tax

1.1 Income Tax charge and rate

The government will introduce legislation in Finance Bill 2024-25 to set the charge for Income Tax, and the corresponding rates, as it does every year.

Finance Bill 2024-25 will set the:

main rates for tax year 2025 to 2026, which will apply to non-savings, non-dividend income of taxpayers in England, Wales, and Northern Ireland
savings rates for tax year 2025 to 2026, which will apply to savings income of all UK taxpayers
default rates for tax year 2025 to 2026, which will apply to non-savings, non-dividend income of taxpayers who are not subject to the main rates of Income Tax, Welsh rates of Income Tax or the Scottish rates of Income Tax

Income Tax rates and rate limits on non-savings and non-dividend income for Scottish taxpayers are set by the Scottish Parliament. The UK rates are reduced by 10 pence in £1 for Welsh taxpayers, and the Welsh rates of Income Tax for non-savings and non-dividend income are set by the Welsh Parliament, and added to the UK rates.

1.2 Starting rate for savings

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to retain the 0% band for the starting rate for savings income at its current value of £5,000 for tax year 2025 to 2026. This measure will apply to the whole of the UK.

1.3 Changes to the taxation of non-UK domiciled individuals

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25, abolishing the remittance basis of taxation for non-UK domiciled individuals and replacing it with a residence-based regime, which will take effect from 6 April 2025.

Individuals who opt into the regime will not pay UK tax on foreign income and gains (FIG) for the first 4 years of tax residence. From 6 April 2025, the government will introduce a new residence-based system for Inheritance Tax.

For Capital Gains Tax purposes, current and past remittance basis users will be able to rebase personally held foreign assets to 5 April 2017 on a disposal where certain conditions are met. Overseas Workday Relief will be retained and reformed, extending to a 4 year period and removing the need to keep the income offshore.

The amount claimed annually will be limited to the lower of £300,000 or 30% of the employee’s net employment income.

The government is extending the Temporary Repatriation Facility to 3 years, expanding the scope to offshore structures, and simplifying the mixed fund rules to encourage individuals to spend and invest their FIG in the UK.

A technical note has been published alongside Autumn Budget 2024.

The government is also publishing a call for evidence on the personal tax offshore anti-avoidance rules. This call for evidence seeks to understand and identify areas where the personal tax offshore anti-avoidance rules could be improved or updated. 

The tax information and impact note for this measure provides more information: Tax changes for non-UK domiciled individuals

1.4 Inheritance Tax nil-rate band and residence nil-rate band

As announced at Autumn Budget 2024, the Inheritance Tax nil-rate bands are already set at current levels until 5 April 2028, and the government will introduce legislation in Finance Bill 2024-25 to fix these levels for a further 2 years until 5 April 2030. The:

nil-rate band will continue at £325,000
residence nil-rate band will continue at £175,000
residence nil-rate band taper will continue to start at £2 million

Qualifying estates can continue to pass on up to £500,000 and the qualifying estate of a surviving spouse or civil partner can continue to pass on up to £1 million without an inheritance tax liability.

The tax information and impact note for this measure provides more information: Inheritance Tax nil-rate band and residence nil-rate bands from 6 April 2028

1.5 Reducing tax-free overseas transfers of tax-relieved UK pensions

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to:

remove the exclusion from the Overseas Transfer Charge (OTC) of transfers to Qualifying Recognised Overseas Pension Schemes (QROPS) established in the European Economic Area (EEA) and Gibraltar, where the member is resident in the UK or an EEA state — this will mean that pension transfers from tax relieved UK pensions to QROPS in the EEA and Gibraltar will now be subject to a 25% charge, unless another exclusion applies, bringing their treatment in line with transfers to QROPS established in the rest of the world — the measure will take effect from 30 October 2024
bring the conditions for a scheme to be an Overseas Pension Schemes (OPS) and Recognised Overseas Pension Schemes (ROPS) established in the EEA in line with those for OPS and ROPS established in the rest of the world, so that from 6 April 2025, OPS established in the EEA will be required to be regulated by a regulator of pension schemes in that country, and ROPS established in the EEA must be established in a country with which the UK has either a Double Tax Agreement which allows for exchange of information or a Tax Information Exchange Agreement
require scheme administrators of registered pension schemes to be UK resident from 6 April 2026

The tax information and impact note for this measure provides more information: Changes to rules for overseas pensions and scheme administrators

1.6 Clarification of taxable status of Statutory Neonatal Care Pay

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to clarify the Income Tax treatment of the Statutory Neonatal Care Pay Scheme, which is part of the Employment Rights Bill.

Legislation in Finance Bill 2024-25 will confirm that Statutory Neonatal Care Pay is taxable as social security income. This measure will have effect on and after the date of Royal Assent to Finance Bill 2024-25.

The tax information and impact note for this measure provides more information: Tax treatment of Statutory Neonatal Care Pay: Income Tax

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to ensure that the notice an employer must provide to an employee under a Share Incentive Plan regarding the possible effect of deductions from salary on entitlement to social security benefits and statutory payments will also refer to Statutory Neonatal Care Pay. The changes will take effect from 6 April 2025.

The tax information and impact note for this measure provides more information: Share Incentive Plan — consequential change because of the Neonatal Care (Leave and Pay) Act 2023

1.8 Changes to the Capital Gains Tax (CGT) rates

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to increase the main rates of Capital Gains Tax (CGT) from 10% and 20% to 18% and 24% respectively. The change will take effect for disposals made on or after 30 October 2024.  

 The rate of CGT for Business Asset Disposal Relief and Investors’ Relief is increasing to 14% for disposals made on or after 6 April 2025, and from 14% to 18% for disposals made on or after 6 April 2026.  

 No changes will be made to the 18% and 24% rates of Capital Gains Tax that apply to residential property gains.  

 The tax information and impact note for this measure provides more detail: Changes to the rates of Capital Gains Tax

1.9 Capital Gains Tax — Investors’ Relief — reduction in the lifetime limit

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to reduce the Investors’ Relief lifetime limit from £10 million to £1 million for Investors’ Relief qualifying disposals made on or after 30 October 2024.

The tax information and impact note for this measure provides more detail: Capital Gains Tax: Investors’ Relief — lifetime limit reduction

1.10 Carried interest taxation reform

As announced in July 2024, and as confirmed in Autumn Budget 2024, the government will reform the way carried interest is taxed, ensuring that this is in line with the economic characteristics of the reward.

From April 2026, the tax regime will be within the Income Tax framework, with a 72.5% multiplier applied to qualifying carried interest that is brought into charge.  As an interim step, the government will introduce legislation in Finance Bill 2024-25 to increase the 2 Capital Gains Tax rates for carried interest to 32% from 6 April 2025.

The government published a summary of responses to the call for evidence from earlier this year. This publication includes a summary of responses to the call for evidence and outlines the next steps, including a consultation on introducing further conditions of access into the regime.

The tax information and impact note for this measure provides more information: Carried interest: rates of Capital Gains Tax

1.11 Alternative finance — Tax rules for alternative finance

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 making changes to certain alternative finance tax rules for Capital Gains Tax, Corporation Tax, Income Tax and Annual Tax on Enveloped Dwellings.

These changes, which apply from 30 October 2024, will ensure that tax consequences are the same for those using alternative and conventional financing arrangements across the UK.

This change follows a consultation on alternative refinancing arrangements. The summary of responses to the 2024 consultation was also published at Autumn Budget 2024.

The tax information and impact notes for this measure provides more information on:

1.12 Taxation of Employee Ownership Trusts and Employee Benefits Trusts

As announced at Autumn Budget 2024, following a consultation, the government will introduce legislation in Finance Bill 2024-25 for a package of reforms to the taxation of Employee Ownership Trusts and Employee Benefit Trusts.

These reforms will ensure that the regimes remain focused on encouraging employee ownership and rewarding employees, and to prevent opportunities for abuse. The changes will take effect from 30 October 2024.

The summary of responses to the 2023 consultation was also published at Autumn Budget 2024.

The tax information and impact note for this measure provides more information: Changes to the taxation of Employee Ownership Trusts and Employee Benefit Trusts

Corporate Tax

1.13 Corporation Tax charge and rate

The government will introduce legislation in Finance Bill 2024-25 to set the charge for Corporation Tax as it does every year, and to maintain the main rate at 25% and the small profits rate at 19%, for the financial year beginning 1 April 2026.

1.14 Energy Profits Levy (EPL) reform 2024

As announced in July 2024, the government will introduce legislation in Finance Bill 2024-25 to provide for changes to the Energy Profits Levy (EPL). The legislation will increase the rate of the levy by 3 percentage points to 38% and the sunset clause will be extended to 31 March 2030. The legislation will remove the 29% investment allowance, and the rate of the decarbonisation allowance will be set at 66% to broadly maintain the cumulative value of relief for decarbonisation expenditure. These changes will take effect from 1 November 2024.

The government has also announced that it will publish a consultation in early 2025 on how it will respond to price shocks once the EPL ends.

The tax information and impact note for this measure provides more information: Energy Profits Levy reforms 2024

1.15 Relief for payments made into a Carbon Capture Usage and Storage (CCUS) decommissioning fund

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to provide relief for certain payments made by oil and gas companies into decommissioning funds where assets are transferred for use in CCUS activities, to maintain the tax treatment had these assets instead been decommissioned. It will also exempt associated receipts received by oil and gas companies from the Energy Profits Levy. The changes will take effect from Royal Assent to Finance Bill 2024-25.

The tax information and impact note for this measure provides more information: Oil and Gas taxes: providing relief for certain payments made into Carbon Capture Usage and Storage decommissioning funds

1.16 Stamp Duty Land Tax — increase to the higher rates on additional dwellings (and the single rate of tax on purchases by non-natural persons)

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to increase the higher rates of Stamp Duty Land Tax (SDLT), payable by purchasers of additional dwellings and by companies, from 3% to 5% above the standard residential rates. The government will also increase the single rate of SDLT payable by companies and non-natural persons acquiring dwellings for more than £500,000, from 15% to 17%.

The changes will apply to transactions with an effective date on or after 31 October 2024.

The tax information and impact note for this measure provides more information: Stamp Duty Land Tax: Increase to the higher rates of Stamp Duty Land Tax and to the single rate payable by non-natural persons

1.17 Abolition of Furnished Holiday Lets (FHL) tax regime

As announced in July 2024, the government will introduce legislation in Finance Bill 2024-25 to remove the specific tax treatment and separate reporting requirements for Furnished Holiday Lettings (FHL).

Income and gains from a FHL will form part of the person’s UK or overseas property business. These changes will take effect on or after 6 April 2025 for Income Tax and Capital Gains Tax and from 1 April 2025 for Corporation Tax and for Corporation Tax on chargeable gains.

The tax information and impact note for this measure provides more information: Furnished holiday lettings tax regime abolition

1.18 Close company shareholders — anti avoidance measure

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to prevent avoidance of the section 455 Corporation Tax Act 2010 (Loans to Participators) charge, by ensuring that the Targeted Anti-Avoidance Rule (TAAR) remains robust and effective.

The change repeals the relief for return payments where the TAAR has applied and moves the related legislation together for clarity.

The changes will take effect from 30 October 2024 and specifically will apply to return payments made on or after that date.

The tax information and impact note for this measure provides more information: Corporation Tax — close company shareholders — anti-avoidance measure

1.19 Changes to tax rules on liquidations of Limited Liability Partnerships (LLP) from 30 October 2024

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to change the taxation of Capital Gains rules that apply to the liquidation of Limited Liability Partnerships (LLP) from 30 October 2024.

A tax charge will arise where an LLP is liquidated, and assets are disposed of to the contributing member, or a person connected to them. The tax liability will arise on the chargeable gains made at the time the asset was contributed to the LLP. 

The tax information and impact note for this measure provides more information: Capital Gains: Limited Liability Partnership liquidations

1.20 Capital allowances — extending first-year allowances for zero-emission cars and electric vehicle charge-points

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to extend the 100% first-year allowances for zero-emission cars and electric vehicle charge-points until:

31 March 2026 for Corporation Tax
5 April 2026 for Income Tax

The tax information and impact note for this measure provides more information: Capital Allowances: extension of first-year allowances for zero-emission cars and electric vehicle charging points

1.21 Agricultural Property Relief and environmental land management

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 to extend the existing scope of Agricultural Property Relief from 6 April 2025 to land managed under an environmental agreement with, or on behalf of, the UK government, devolved governments, public bodies, local authorities, or approved responsible bodies.

The tax information and impact note for this measure provides more information: Agricultural Property Relief and environmental land management

1.22 Multinational Top-up Tax — undertaxed profits rule (UTPR)

As announced in July 2024 and as confirmed in Autumn Budget 2024, the government will introduce the undertaxed profits rule (UTPR) contained within the Pillar 2 rules. The government will introduce legislation in Finance Bill 2024-25 to implement the UTPR.

The UTPR is the UK’s adoption of the third and final Pillar 2 rule. Pillar 2 is an international agreement to help tackle profit shifting and aggressive tax planning by multinationals.

The UTPR is implemented by amending the Multinational Top-up Tax and Domestic Top-up Tax rules contained within Finance (No.2) Act 2023 and will take effect for accounting periods beginning on or after 31 December 2024.

Draft legislation for the UTPR was published for consultation on 18 July and 27 September 2023. Changes have been made reflecting stakeholder feedback.

The tax information and impact note for this measure provides more information: Pillar 2: adoption of the undertaxed profits rule

1.23 Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) — amendments

Further to the implementation of Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) in the Finance (No.2) Act 2023 (and subsequent amendments in Finance Act 2024), the government will introduce legislation in Finance Bill 2024-25 to make additional amendments to the MTT and DTT legislation.

These amendments will include the introduction of the transitional country by country reporting safe harbour anti-arbitrage rule. Draft legislation for this rule was published for consultation in July 2024. Minor changes have been made reflecting responses received.

These taxes are the UK’s adoption of Pillar 2, an international agreement to help tackle profit shifting and aggressive tax planning by multinationals. The amendments reflect recent internationally agreed guidance and technical adjustments to ensure the rules work effectively. They will mainly take effect for accounting periods beginning on or after 31 December 2024, although some amendments will have effect from 31 December 2023. The anti-arbitrage rule will take effect from 14 March 2024, the date of it’s announcement by Written Ministerial Statement.

Provision is being made for certain territories and domestic minimum top-up taxes to have qualifying or accredited status in accounting periods ending before regulations are made specifying particular territories and taxes.

The tax information and impact note for this measure provides more information: Pillar 2: Multinational Top-up Tax and Domestic Top-up Tax amendments

1.24 Offshore Receipts in Respect of Intangible Property (ORIP) repeal

The government confirmed at Autumn Budget 2024 that it will repeal the Offshore Receipts in Respect of Intangible Property (ORIP) rules in Finance Bill 2024-25.

The ORIP legislation at Chapter 2A of Part 5 Income Tax (Trading and Other Income) Act 2005 will not apply to income arising from 31 December 2024.

The tax information and impact note for this measure provides more information: Repeal of the Offshore Receipts in Respect of Intangible Property (ORIP) rules

1.25 Additional tax relief for visual effects (VFX)

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 for film and high-end TV companies to claim an enhanced 39% rate of Audio-Visual Expenditure Credit (AVEC) on their UK visual effects (VFX) costs. UK VFX costs will be exempt from the AVEC’s 80% cap on qualifying expenditure. The changes will take effect from 1 April 2025, for expenditure incurred on or after 1 January 2025.

The tax information and impact note for this measure provides more information: Corporation Tax: additional tax credit for visual effects (VFX) expenditure

1.26 UK reporting for the Cryptoasset Reporting Framework (CARF) and amendments to the Common Reporting Standards (CRS)

As announced at Autumn Budget 2024, the government has published a summary of responses to the consultation entitled ‘Cryptoasset Reporting Framework, Common Reporting Standard amendments, and seeking views on extension to domestic reporting’, and is extending CARF to include reporting on UK resident taxpayers by UK service providers.

The Cryptoasset Reporting Framework (CARF) and amendments to the Common Reporting Standard (CRS) will be implemented in the UK from 1 January 2026.

The government will introduce legislation in Finance Bill 2024-25 to provide the Treasury with the power to make the CARF regulations. HM Treasury will make these CARF regulations in 2025 in time for implementation on 1 January 2026.

As announced at Autumn Budget 2024, the government will introduce legislation in Finance Bill 2024-25 enabling HM Treasury to make Stamp Duty and Stamp Duty Reserve Tax (SDRT) changes in relation to FMI sandboxes, by Statutory Instrument.

This power will apply to FMI sandboxes established under the Financial Services and Markets Act 2023. In line with the government’s commitment to delivering the Private Intermittent Securities and Capital Exchange System (PISCES), the power will be used to provide an exemption from Stamp Duty and SDRT for PISCES transactions.

The power will take effect from Royal Assent to Finance Bill 2024-25. The Statutory Instrument will be introduced to a similar timeline to the legislation that will establish the PISCES regulatory framework.

The tax information and impact note for this measure provides more information: Stamp Duty and Stamp Duty Reserve Tax — power to make changes in connection with FMI sandboxes and exemption for PISCES

1.28 Taxation of company cars — the appropriate percentage for tax years 2028 to 2029 and 2029 to 2030

As announced at Autumn Budget 2024, the government is setting company car tax rates for tax years 2028 to 2029 and 2029 to 2030.  

Appropriate percentages for zero emission and electric vehicles will increase by 2 percentage points per year in 2028 to 2029 and 2029 to 2030, rising to an appropriate percentage of 9% in tax year 2029 to 2030.  

Appropriate percentages for all cars with emissions of 1 to 50g of CO2 per kilometre, including hybrid vehicles, will rise to 18% in tax year 2028 to 2029 and 19% in tax year 2029 to 2030.   

Appropriate percentages for all other vehicle bands will increase by 1 percentage point per year in tax years 2028 to 2029 and 2029 to 2030. This will be to a maximum appropriate percentage of 38% for tax year 2028 to 2029 and 39% for tax year 2029 to 2030. 

The tax information and impact note for this measure provides more information: Income Tax: Company car tax rates 2028 to 2030

Autumn Budget 2024 — Overview of tax legislation and rates (OOTLAR)