Autumn Statement 2014 update from Edwin Coe

The 2014 Autumn Statement has just been published by the UK Revenue (‘HMRC’) following the Chancellor’s speech at lunchtime today.

Some of the key highlights that may be relevant to private individuals and families include the following:-

Stamp Duty Land Tax (‘SDLT’)

A major and unexpected change to SDLT has been announced.  To date, SDLT, which is paid by the purchaser of a property, has been paid in “slabs” such that the percentage charge applies to the entire purchase price of a property, with no sliding scale applying to the different bands.

The new regime, which applies from midnight tonight, introduces a progressive sliding scale of different taxable bands for SDLT for the first time (in a similar way to that applying for income tax).

The new regime applies as follows:

• the first £125,000 of any purchase price is charged at 0%,
• the portion of the transaction value between £125,000 and £250,000 is charged at 2%,
• the portion between £250,000 and £925,000 at 5%,
• the portion between £925,000 and £1.5m is to be charged at a new rate of 10%
• any portion in excess of £1.5m is to be charged at a new rate of 12%.

The changes will have a major effect in shifting the burden of SDLT away from “average” property transactions onto higher value residential transactions.

Annual Tax on Envelope Dwellings (ATED)

The annual ATED charge for residential properties worth over £2m will increase by 50% above inflation for the chargeable period from 1 April 2015 to 31 March 2016.

This follows on from the previous announcement that the scope of ATED will be extended and will apply to properties over £1m as from 1 April 2015, and the ongoing extension of the attack on high value residential property in the announcement published last week of the results of the consultation on the extension of capital gains tax to UK residential properties owned by non-UK residents.

Non-Domiciliaries

The annual charge by which resident non-domiciliaries can access the remittance basis of taxation is set to increase, so that those resident in the UK for 12 or more out of the last 14 years will now have to pay £60,000 per annum (instead of £50,000 to date).

There will also be a new charge introduced for people who have been resident in the UK for 17 or more out of the last 20 years, at the rate of £90,000 per annum.

Anti-avoidance and Fairness

The attack on perceived aggressive tax avoidance continues, with the extension of the existing offshore penalties regime to include inheritance tax and the introduction of a new aggravated penalty of up to 50% for moving hidden funds to circumvent international tax transparency.

Further legislation will also be introduced to strengthen the DOTAS (Disclosure of Tax Avoidance Schemes) system generally.

Pensions

The government has confirmed its plans to abolish the 55% tax charge on inherited pensions, to come into force in April 2015.

Savings

As of today, the tax benefits of ISA wrappers can now be passed on death to a surviving spouse or civil partner.

We will be publishing further guidance on a number of these points shortly.

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