Labour’s first Budget hopes to raise UK taxes by £40 billion. Highlights are as follows:
Income Tax
No increase. Threshold freeze will end from April 2028.
National Insurance Contributions (NICs)
No change to employee NICs. Threshold freeze will end from April 2028
Employer NICs will increase to 15% from 6 April 2025, and the contribution threshold will decrease from £9,100 to £5,000.
Capital Gains Tax
Basic rate (currently 10%) increased to 18%; higher rate of 20% to 24% from 30 October 2024.
Rates for Business Asset Disposal Relief (formerly Entrepreneurs’ Relief) and Investors’ Relief will rise from 10% to 14% from 6 April 2025, and 18% from 6 April 2026.
Corporation Tax
No major changes announced.
Inheritance Tax (IHT)
IHT thresholds frozen until 2030 (previously 2028). No change to headline rate of IHT (40%).
From 6 April 2026, assets qualifying for Agricultural Property Relief and Business Property Relief will attract relief at 100% up to a value of £1 million only, and at 50% over £1 million.
Most pensions will be included in a person’s estate for IHT purposes from 6 April 2027.
Taxation of Non-UK Domiciled Individuals
Domicile to be abolished as a tax concept, and a residence-based tax regime to replace it. This will impact personal and trust taxation.
Stamp Duty Land Tax (SDLT)
Surcharge for second home purchases to increase from 3% to 5% from midnight on 30 October 2024.
SDLT on enveloped dwellings to increase from 15% to 17%.
Private Schools
Standard rate VAT at 20% to apply to private school fees from 1 January 2025.
Business rates relief to be abolished from April 2025.
AUTHORS
Gary AshfordPartner
Gary is a well-known international tax partner (non-lawyer) with particular expertise in contentious tax matters. He previously held senior positions at HMRC and leading accountancy firms.
Gary is a well-known international tax partner (non-lawyer) with particular expertise in contentious tax matters. He previously held senior positions at HMRC and leading accountancy firms.
He has particular expertise in complex structures, including trusts and funds both in the UK and overseas, and supports non domicile and international clients in identifying areas of risk in their tax affairs. Gary is an expert on the various overseas tax agreements, international transparency, exchange of information and the increasing need for substance.
Gary has particular expertise assisting clients who need to make disclosures to HMRC or who are under Code of Practice 8 & 9 (COP8 and COP9), or criminal tax investigation. He advises on international tax issues, the OECD BEPS programme (UK implementation) and the EU Anti Avoidance Tax Directive.
He also advises private clients, trusts and corporate clients on a range of complex tax issues such as restructuring, residence, non domicile/remittances, transfer pricing matters, employment and property tax and various other matters including VAT.
Gary spends a considerable amount of his time helping high net worth and high-profile individuals and their companies on managing tax avoidance dispute issues and tax risks relating to overseas structures. Gary also advises, in collaboration with our reputation management lawyers, individuals on protecting what is rightfully theirs while at the same time limiting any media exposure.
Gary is an author for Bloomsbury and a tax lecturer on international tax matters. He also leads for the tax profession in tax consultations with HMRC and the Treasury. Citywealth listed Gary in their top 100 international private client litigation lawyers.
Zoë CampPartner
Zoë is a private client lawyer with more than 20 years’ experience. She advises on wealth and succession planning and provides UK tax and trust advice to families based both within and outside of the UK.
Zoë is a private client lawyer with more than 20 years’ experience. She advises on wealth and succession planning and provides UK tax and trust advice to families based both within and outside of the UK.
Zoë is a trust expert and also advises on the use of companies and partnerships as alternative family wealth and business holding structures. For many of her client families, philanthropy and responsible business practices are an integral part of their planning and, in response to this demand, she has been developing the knowledge and contact base to help families with their philanthropic and social goals.
Prior to joining Harbottle & Lewis, Zoë was a founding partner of New Quadrant Partners and helped to develop its strong UK/US team and entertainment offering.
She has been listed as a 'Leading Lawyer', a 'Prominent Figure' and a 'Power Woman' in the Citywealth Leaders List. She has also been recognised as an outstanding practitioner in Who’s Who Legal: Private Client, recommended in The Legal 500 guide and ranked for private wealth law in the Chambers HNW guide.
Alexa CollisPartner
Alexa Collis is a partner whose practice spans a broad range of UK and cross-border estate planning and wealth structuring matters.
Alexa Collis is a partner whose practice spans a broad range of UK and cross-border estate planning and wealth structuring matters.
Alexa has a particular focus on clients in the entertainment and creative industries, as well as entrepreneurs and business owners. Clients often seek Alexa’s expert advice on philanthropic and charitable matters as part of their estate planning.
Alexa has a substantial amount of experience in tax and estate planning for individuals and families with US connections. She is sought after by clients and intermediaries as a specialist in this field.
Alexa won the eprivateclient Top 35 Under 35 award in 2019, the Citywealth Future Leaders Award (Bronze – Senior/Managing Associate) in 2020 and was named as an eprivateclient NextGen Leader in 2024. She was also a finalist for the Future Leader in Private Client Services Spear’s award in 2024.
Alexa joined the firm in 2020, having previously worked at other firms in the UK and in the Channel Islands.
Siena GoldPartner
Siena advises individuals and family offices, trustees and financial institutions representing them on wealth and succession planning, family governance, philanthropy and cross-border tax.
Siena advises individuals and family offices, trustees and financial institutions representing them on wealth and succession planning, family governance, philanthropy and cross-border tax.
She has particular expertise in assisting internationally mobile individuals and helping clients with a presence in multiple jurisdictions who have substantial interests in Europe, North America and the Middle East. She especially enjoys helping clients address particularly complex issues or difficult family dynamics where they are looking to avoid litigation.
Siena won the UK rising star of the year award at the Chambers High Net Worth Awards in 2021. The judges noted she “continues to establish herself as one of the London market’s leading private wealth lawyers” with their sources saying she is “absolutely one to watch; she is really fantastic.”
Chris MoorcroftPartner
Chris Moorcroft is a private client adviser to individuals, families and trustees. He advises on transferring wealth between generations, protecting it from third parties, catering for death or incapacity, and managing complex cross-border tax and legal issues involving multiple jurisdictions.
Chris Moorcroft is a private client adviser to individuals, families and trustees. He advises on transferring wealth between generations, protecting it from third parties, catering for death or incapacity, and managing complex cross-border tax and legal issues involving multiple jurisdictions.
He advises on will planning and probate, particularly those which involve multiple jurisdictions, and acts as executor and administrator of estates. He has significant experience acting for trustees in international disputes and also conducts the administration of estates which are the subject of dispute.
He advises both international and domestic clients. He has a particular focus on US-connected clients and counts a number of clients from LATAM and the Middle East. He has an interest in the ‘next gen’ of wealth owners and speaks extensively on the topic of transitioning wealth to millennials and Gen Z. He has expertise in ESG and values-aligned investing, and advises trustees on associated issues of fiduciary risk.
David ScottPartner
David is a corporate tax and share incentives partner in our corporate group.
David is a corporate tax and share incentives partner in our corporate group.
He has a wealth of experience providing corporate and personal tax advice to the full range of the firm’s clients and his core practice involves tax advice for entrepreneurs and their businesses. David has considerable experience advising on the tax aspects of M&A transactions and expertise in all aspects of share incentive arrangements.
David works closely with businesses at varied stages of growth and size, advising both investors and investee companies on tax efficient fundraising, including EIS and SEIS, through to an exit.
He also advises on a range of employment tax issues, including share based incentives and option schemes ranging from the implementation of EMI and CSOP share schemes to highly tailored share-based arrangements for senior management such as growth shares. He also advises on the use of employee benefit trusts (EBT) and employee ownership trusts (EOT).
As the head of the charities and philanthropy group, he advises not-for-profit organisations and individual philanthropists on all charity law issues, including commercial arrangements and corporate governance issues, as well on specific charity tax issues.
David is member of the International Tax Specialist Group (ITSG).