Author Archives: Richard Verge - Tax Director

About Richard Verge - Tax Director

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Richard is a personal tax expert and is able to advise high net worth individuals on either immediate tax concerns or a long term plan to ensure that their affairs are structured to take advantage of the tax reliefs available.

His experience from working with HMRC ensures that he is more than adept at understanding the view from the other side, to the benefit of his clients. Richard advises entrepreneurs, owners of family businesses and partners in professional practices and provides advice on planning from both a personal and worklife perspective.

Buried towards the end of yesterday’s spending review documentation Spending Review 2025 – GOV.UK is the announcement of an extra £6.4 billion for HMRC. This is planned to provide for an additional 5,500 compliance staff and 2,400 debt management staff. For those of us who have to liaise with HMRC on a regular basis this would appear to be a welcome change as response times for fairly straight forward enquires can be many months at present and HMRC by their own admission accept that their overall performance is well below acceptable levels.

Unfortunately this won’t mean that it will be easier to pick up the phone and get a quick response to your tax problems. The direction of travel at HMRC is firmly towards increasing digitisation of the tax service. An additional £500 million is being provided for the next three years with the stated aim of making 90% of “customer interactions” self-serve by 2029-30.  HMRCs plan is that by reducing the availability of personal contact and encouraging taxpayers to do everything online this will improve efficiency and provide a better overall experience for the tax paying public.

I quote from HMRCs 2023/24 annual review: “our overall service levels on telephony and correspondence remained below our service standards in 2023 to 2024, and we recognise that this caused real difficulties for some customers and agents. To deliver the service standards our customers expect, our aim is to reduce the volume of contact through phone and correspondence over time and boost the number of customers self-serving online, without needing to contact us.” HM Revenue & Customs

I readily acknowledge that when HMRCs digital systems work the experience is good, but when the computer gets it wrong it can be very difficult and frustrating trying to put right.  I worry that the opportunity to phone HMRC and speak to someone is being gradually withdrawn.

To end on an optimistic note, lets hope that the extra compliance staff and further investment in digital infrastructure will be successful in reducing errors along with the need to pick up the phone. No one likes to pay tax, but an efficient accurate and fair tax service is a vital part of a vibrant successful society.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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With all of the speculation leading up to the autumn budget and the many predictions for what the first Labour government budget in 14 years would bring, it is a relief to have details finally of how Rachel Reeves intends to fill the much talked about black hole in the public finances.

To raise the required £40bn one of the major taxes had to rise. Employers’ NIC was the only option left open to the chancellor following Labour’s manifesto pledge not to raise Income Tax, National Insurance and VAT for working people. It was therefore little surprise that the Employers’ NIC rate is being increased to 15% from April 2025.

The widely expected increase in Capital Gains Tax comes into immediate effect, but the top rate increase from 20% to 24% is lower than many had been predicting.

Changes to Inheritance Tax include the removal of the exemption for inherited pension funds and the scaling back of business property and agricultural property relief. We also have further clarification regarding the change to the rules for non-domiciled individuals.

The chancellor confirmed that private school fees will be subject to VAT at the standard rate of 20% with effect from 1st January 2025. Private schools will also lose entitlement to business rates relief.

Individual and corporate landlords are facing another increase in Stamp Duty Land Tax with the higher rate for additional dwellings being increase from 3% to 5% effective from 31st October.

The key message of “restoring economic stability” was clearly present in the Corporation Tax Road Map published alongside the budget with promises to cap the Corporation Tax rate at 25% for the lifetime of the parliament, maintaining the current capital allowances and R&D reliefs and ensure the UK’s regime remains internationally competitive.

For details of the budget announcements see our budget summary below:

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There is a widespread expectation that Capital Gains Tax (CGT) will be increased in the October Budget. This could be done in a number of ways including:

  • Increasing the rate from the current rates of 20% and 24%.
  • Realigning with income tax.
  • Removing existing exemptions and reliefs.

What might you do in anticipation of any of the above:

  • If you are already considering a sale, then bringing this forward to before Budget day would give more certainty over the rates that you will be paying. It is not impossible that rate increases could be back dated but this would be highly unusual and, in our view, very unlikely. Don’t forget that the tax point for CGT is usually the date of exchange of contracts and not the date of completion.
  • If you had not previously considered selling assets to lock into current rates, there may be benefit in making sales now. This would of course mean paying tax now with the potential to save a larger tax bill in the future.
  • Likewise, if you have any remaining Business Asset Disposal Relief allowance available (currently up to £1 million) and are considering selling assets that would qualify, bringing the sale forward would give certainty of being able to benefit from the relief. It is unclear whether any changes to the CGT regime would also involve changes to Business Asset Disposal Relief.
  • If you are an EIS or VCT investor, you will be aware of the option to defer CGT on their acquisition. With a potential increase in rates there could be benefit in holding off from making a deferral claim for disposals which have already taken place. Claims to defer gains would normally be made on your self-assessment tax return, so if you haven’t already submitted your return and made a claim you may want to wait until after Budget day.
  • Gifts of chargeable assets are treated as taking place at market value. Gifts can therefore be used to crystallise gains if, say, you wanted to gift assets to other family members or perhaps into a trust.
  • Holdover relief can, in certain circumstances, be claimed on gifts of qualifying business assets to defer capital gains. There is a 4-year time limit for making hold over elections, so if this option is relevant to your circumstances then waiting until after Budget day to make a hold over election may be advisable.
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However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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There has been much media speculation about whether Business Property Relief (BPR) and Agricultural Property Relief (APR) will be reduced or abolished altogether. Given Rachel Reeves’s promise to be pro-business, this may not be on her agenda but if these valuable reliefs were abolished, what would the inheritance tax landscape for family businesses look like and should you be taking any action now to position your business for potential changes? 

Bring Forward Succession Planning 

One way to prepare for possible changes in BPR and APR could be to bring forward succession planning. By starting the process earlier, you can take advantage of the reliefs as they currently stand, while you prepare your successors for their future role and ensure a smoother transition of business ownership.  

Bringing in Younger Family to Shared Ownership 

Encouraging younger family members to take on shared ownership roles can be a strategic move in the face of potential changes to inheritance tax reliefs. As with starting your succession process early, by involving the next generation in the business through shared ownership now, you may benefit from BPR and APR in their current form. 

Are AIM Investments Still a Good Idea? 

AIM (Alternative Investment Market) investments have been popular due to their qualification for BPR, which can provide significant inheritance tax relief. However, with the uncertainty surrounding the future of BPR, some are reassessing the viability of their AIM investments.  

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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After 14 years of Conservative rule, Labour has taken the reins under Keir Starmer with a massive majority as the electoral map shifted from blue to decisive red on 4 July. 

The last time the Labour Party replaced a Conservative government, within a few days it sprung

an economic surprise that nobody saw coming – granting independence to the Bank of England. Just over 27 years later, no such shock move seems likely, but with Labour’s key message a promise of change, what lies ahead? 

The challenges 

The economic backdrop which Labour inherited on 5 July is markedly darker than that of 27 years ago. In the 1997/98 financial year, government borrowing was 1.1% of GDP and total government debt (ex-Bank of England) was 36.7% of GDP. The corresponding figures for 2024/25 are projected to be nearly triple – 3.1% and 91.7%.  

Whereas at the turn of the century the government benefitted from a ‘peace dividend’, the ratcheting up of global tensions of the last few years mean it now faces the opposite situation, with the defence budget set to rise to 2.5% of GDP. Added to that, the much higher debt figure imposes a heavy ongoing servicing cost on the government. Net interest alone is projected to account for nearly £65 billion of expenditure in 2024/25. 

The wider range of challenges facing the new Prime Minister and his cabinet go deeper, as identified by chief of staff Sue Gray earlier in the year. These are the specific issues that feel closer to people’s lives than the more abstract public sector borrowing figures which they affect. Chief amongst these are: 

  • the NHS funding gap and social care requirements; 
  • public sector pay negotiations, particularly around the NHS; 
  • local council bankruptcies; 
  • the housing deficit; 
  • potential collapse of the largest water company, Thames Water; 
  • overcrowding in prisons and the criminal justice backlog; 
  • the schools and university funding crisis. 

In these financial circumstances, a government elected under the banner of change will soon face tough decisions on tax, spending and borrowing. The honeymoon – arguably more relief than joy at the change of government – may not last long.  

Tax focus 

Tax was a key attack area for the Conservatives during the election, who were themselves on weak ground due to their recent record. Labour’s manifesto listed its now familiar (and distinctly modest) tax raising plans of: 

  • reducing tax avoidance; 
  • revising non-domiciled taxation rules; 
  • levying VAT and business rates on private schools; 
  • ending the capital gains tax treatment of carried interest;  
  • a windfall tax on ‘oil and gas giants’; and 
  • increasing stamp duty land tax rates by one percentage point on residential property purchases by non-UK residents. 

The manifesto also said “We will ensure taxes on working people are kept as low as possible. Labour will not increase taxes on working people, which is why we will not increase National Insurance, the basic, higher, or additional rates of Income Tax, or VAT.” Unfortunately, the definition of ‘working people’ was never resolved during the election campaign. In interviews, Keir Starmer and Rachel Reeves did not appear to agree.  

The manifesto additionally promised to cap corporation tax at 25% but was silent on inheritance tax (IHT) and capital gains tax (CGT), both arguably not taxes of ‘working people’. This pair of capital taxes could feature in the next Budget, although HMRC’s own estimates suggest a sharp rise in CGT rates would be self-defeating because of ‘behavioural effects’, e.g. gains would just be left unrealised. On the other hand, a month before the election was called, the Institute for Fiscal Studies published a paper explaining how the closure of three IHT ‘loopholes’ could raise nearly £4 billion a year by 2029/30.  

 An autumn Budget 

Rachel Reeves, the first female Chancellor, ruled out an emergency Budget and has said she will give the Office for Budget Responsibility (OBR) the normal ten weeks’ notice to prepare an Economic and Fiscal Outlook ahead of her first Budget. However, over the weekend she requested an update from the Treasury on the UK’s financial position which will be presented to parliament by the end of this month. In announcing the review on Monday, Reeves added “difficult decisions” lay ahead.  

In theory the earliest Budget date could be Friday 13 September, or 18 September if she sticks with the traditional Wednesday for Budget Day. Such a tight timeline is now thought to be unlikely for three reasons: 

  • The Labour Party’s Conference starts in Liverpool on 22 September. 
  • Reeves will want to make decisions on the next Spending Review, both in terms of its contents and whether it will cover the next three years from April 2025 (as originally scheduled) or be an interim review for just the coming year.  
  • One of the surprise Labour losses in the election was Jonathan Ashworth, the former Shadow Paymaster General and a key member of Reeves’ shadow Treasury team.  

The Parliamentary timetable 

An early summer election has meant that the timing of when the new parliament can get down to work is contingent upon some basic realities of the Parliamentary and party calendars: 

  • State Opening on 17 July After the process of electing the speaker and swearing in MPs, due to begin from 9 July, 17 July marks the State Opening of Parliament and the King’s Speech. The Speech will show the government’s immediate priorities and be followed by six days of debate in the Commons. 
  • Summer recess Before parliament was dissolved, the House of Commons had been scheduled to start the summer recess on 23 July. The new government is set to push that date out, although there is a tension between being seen to take early action and giving MPs and their teams and families sufficient time to recover from the election campaign. Whenever the Commons does rise, it will probably return, as usual, in the first week of September. 
  • Conference recess In the past, the House of Commons has taken a three or four weeks recess in September/October to allow MPs to attend their party conferences. In 2024 the LibDem Party’s conference runs from 14-17 September, Labour’s from 22-25 September and the Conservatives’ from 29 September to 2 October. The new government will probably not want the House of Commons to be absent for so long.    

The hundred days 

In his speech on the steps of Downing Street on 5 July, Keir Starmer said “the work of change begins immediately.” As the tricky summer timeline shows, there isn’t much parliamentary time for the government to work with before they hit 12 October, which will mark the end of Labour’s first 100 days in office. In political folklore this is the period when a new government has the greatest political capital. Given the challenges and expectations of the new government, working up to that point will focus the mind of the Prime Minister and his advisers when reviewing those recess periods and setting a date for their first Budget.  

The Chancellor is due to meet with the OBR over the next few days. Focusing on housing, removing planning restrictions and the ever-present need for growth in her first speech to the Treasury on 8 July, Reeves that she would confirm a Budget date before the summer recess for “later in the year”. Those 100 days are going to be very busy. 

Whilst there was a lot of concern before the election that there could be some retrospective tax measures introduced, the initial signs are that the new government is taking a measured and pragmatic approach.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

If you would like to discuss how this applies to you, we would be delighted to talk to you. Please make contact with the author on the details shown below.

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Year-end tax planning is crucial for individuals and businesses to optimise their financial strategies, minimise tax liabilities, and take advantage of available allowances and incentives before the end of the tax year. For those looking to optimise their year-end tax planning for 2024, there are several considerations to be made following the Spring Budget announcement:

Investing tax efficiently

  • Consider using your £20,000 ISA allowance for the year.  
  • Do you wish to take advantage of the tax incentivised investments including EIS, SEIS or VCTs?  All offer generous tax advantages but the downside is they are high risk investments. 
  • Top up your pension savings. The annual allowance (the maximum you can save into pensions in any one year) increased from £40,000 to £60,000 for 2023/24 and the lifetime allowance was abolished. This gives greater opportunity to build up your pension pot. 

Capital Gains Tax (CGT) 

  • The CGT Annual Exemption for 2023/24 is £6,000 per person and will reduce to only £3,000 from 6 April 2024. Check to see if you have made full use of your available exemption.  
  • Transfers of capital assets between married couple and civil partners can be made free of CGT. Take advantage of this to maximise use of both of your annual exemptions.  
  • If you have more than one home, you can elect which is to be your main residence for CGT purposes. There is a two-year time limit for making elections so make sure you don’t miss out.  
  • Be careful if you are investing in crypto assets. HMRC usually treat trading in crypto assets as a personal investment subject to CGT. Moving money between different crypto assets is a disposal and acquisition and will crystallise a gain or loss.  

Retaining your tax allowances 

  • Your personal income tax allowance is reduced by £1 for every £2 that your income exceeds £100,000. Pension contributions and Gift Aid payments can be deducted in arriving at your total income for this purpose and can be used to help preserve your personal allowance. 
  • A dividend allowance of £1,000 is available to everyone regardless of their total income. This is reducing to only £500 from 6 April 2024.  

Child benefit 

Are you affected by the high-income child benefit charge (HICBC)?  For the 2023/24 year the HICBC effectively claws back child benefit if either of a couple’s income exceeds £50,000. The chancellor recognised in the budget that this treats couples with similar amounts of income unfairly where one party to the couple is the majority earner. Whilst changes are being made to address this, for 2023/24 a couple with a more equal income spread can benefit.  

Basis period reform for unincorporated businesses 

New rules requiring unincorporated businesses to report taxable profits on a tax year basis have been introduced, with the 2023/24 year being a transitional year. This could have a significant tax impact for businesses which currently declare profits for a period other than the tax year.  If you haven’t already planned for this change it is still not too late to do so. 

VAT on school fees 

It is widely anticipated that VAT will be introduced in school fees in future. Your children’s school may already be in communication with you on this topic. Keep in touch with them as there may be opportunities available to help mitigate against this increase.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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This last spring Budget before the next general election was always likely to have a political flavour. Against a backdrop of historically high taxes, Jeremy Hunt presented us with some pre-election tax cuts including a 2% reduction in National Insurance and a 4% cut in the rate of capital gains tax on residential property.

Additional tax cutting measures included further support for creative industries with the extension of existing tax reliefs for orchestras, theatres, and museums, and additional help for the film industry. There were also increases to the high-income child benefit charge threshold; the freezing of alcohol duty and the extension of the 5p cut in fuel duty.

These tax cuts are to be paid for partly by the much anticipated abolition of the Non-Dom regime which is expected to raise £2.7bn.  More money is to be provided to HMRC to bolster their debt management capacity which is anticipated to raise significant additional funds.

Other tax raising measures include the abolition of the beneficial tax treatment of furnished holiday lets; the abolition of Stamp Duty Land Tax Multiple Dwellings relief; the extension of the energy profits levy and the introduction of duty on vaping products.

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Jeremy Hunt opened his Autumn Statement by announcing that he was introducing “110 measures to help grow the British economy”. Fortunately for those of us listening he didn’t go into details of them all, but the message was clear that stimulating growth was a priority.

The Chancellor set out five focus areas: reducing debt; cutting tax and rewarding hard work; backing British business; building domestic and sustainable energy; and delivering world-class education.

The two headline tax measures were the full expensing of capital allowances for companies and the reduction in National Insurance contributions. Full expensing of capital allowances for companies was introduced on a temporary basis in the Spring Budget but has now been made permanent. The National Insurance reduction affects employees and the self-employed, with class 2 NIC being abolished completely and rates reducing to 8% for the self-employed and 10% for employees.

Other announcements included removing barriers to investment in infrastructure; reforms to the plannings system; more detail on the changes to the previously announced Research and Development Tax Reliefs; and measures to help small business with getting paid on time.

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Dramatic aerial view of gently rolling patchwork farmland with pretty wooded boundaries, in the beautiful surroundings of the Cotswolds

The Bio-diversity Net Gain (BNG) requirement means that any habitat lost by a development must be replaced with enhanced habitat elsewhere such that the improvement in habitat scores at least 110% of the value of the habitat that is being lost.

However, in situations where there is no suitable land at the proposed site, the developers will be able to access a register of land that can be quite remote from the site.

This obviously opens up possibilities for land-owning individuals and organisations to list land as available and enter into conservation covenants to fulfil the BNG obligations of the developers.

Issues for landowners to consider

Financial Returns

The prices currently mooted could represent an attractive option for many landowners but it will be important to evaluate the proposition fully.

The length of the covenant

At the moment covenants look to have a minimum lifespan of 30 years though this could be more depending on the nature of the development.

Conservation costs

Landowners will need the expertise to ensure that they are positively enhancing the habitat as required. That is likely to require new skills.

Tax implications

Depending on the existing use of the land, there may be unintended tax consequences such as IHT so its important to take advice.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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HMRC have just issued a consultation in connection with the off payroll working rules. This consultation is a little unusual in being aimed very closely at a specific issue, and the timeframe for the consultation is also relatively short. This leads me to suspect that HMRC are looking to implement a change in the near future and that the issue which the consultation is seeking to address is the potential for double payment of tax and NIC under the off payroll working rules.

If your worker falls within the off payroll working rules then, as an employer, you will be required in effect to treat them as an employee for PAYE purposes and to deduct PAYE tax and NIC from their deemed earnings.  

It is possible that the worker may also have paid income tax and NIC on the same income either because they thought they were outside of these rules completely or they have operated PAYE and NIC through their own personal service company under the old IR35 rules.  

At the moment there is no mechanism by which you can take into account any tax already paid by the worker against the PAYE tax and NIC you are due to pay to HMRC. The consultation is considering changing the law to allow tax already paid by the worker to be directly offsetable against your PAYE liability as the engager.  

The practical problem that this will come up against is the tracing of those payments from the worker back to the employer/engager. Should you be in this position of having workers within the off payroll working rules, then going forward you should ensure that you keep sufficient information on your workers so that HMRC could easily trace any such taxes already paid by the worker. This could include: 

  • The workers name and address 
  • Date of birth
  • National insurance number
  • The name and address of their intermediary company
  • The company registration number of the intermediary
  • The Unique Tax Reference (UTR) of the intermediary or the worker

This is still in the consultation process so it is not yet certain whether the rules will change, but it could be worthwhile starting to gather this information as part of your take-on procedures. 

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

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