A Reflection by Gillian Everall, Managing Director

Looking back over the past decade, the journey of growing Everfair Tax has been an experience filled with lessons, challenges, and significant achievements. If I could speak to myself 10 years ago, here’s what I would tell my younger self and the key insights I’ve gained since then.

What I Would Tell Myself 10 Years Ago?

The first lesson I would tell myself is simply; just go for it! I remember the fear of uncertainty, but now I see how much time was spent considering the risks when in reality, there was so much more to gain.

When I first started, one of my biggest worries was whether the work would come in consistently, in hindsight now know, the work will come in and that wasn’t something to worry about. Business growth is never linear, and challenges will arise, but the key is to have confidence in your abilities and your business vision.

Another important realisation; you can cope with more than you think. Whether it’s tight deadlines, dealing with clients, or navigating tough economic conditions, you are stronger than you believe, and sometimes, you might even find it fun despite the stress.

The flexibility that comes with running your own business is a valuable asset. It’s a privilege I’ve come to appreciate more and more over the years.

One of the biggest fears I faced was hiring staff. It can feel intimidating to take on the responsibility of others’ livelihoods. But I would tell myself not to be scared of it. Hire when it feels right.

In business, there’s no such thing as having all the answers, and I’ve learned to get used to that. Success comes not from knowing everything, but from being adaptable and finding solutions when challenges arise. It’s critical to acknowledge that mistakes will happen, but the key is to learn from them. Don’t be afraid to face them head-on and grow through the experience.

Most importantly, I would remind myself to enjoy what I’m doing. Life is too short to be consumed by stress or worry.

What I Am Proud Of

Despite the challenges, there are many things I am incredibly proud of. The team we have today is a huge source of pride. We’ve grown into a strong, cohesive unit, and we continue to expand by taking on new trainees and investing in formal training sessions internally.

Our ability to offer a wide range of opportunities to the team and support their professional development has been rewarding. Seeing others grow, learn, and achieve their goals is one of the best parts of leadership. We’ve also been able to expand the services we offer, which has allowed us to serve a broader range of clients and provide them with more value.

Final Thoughts

Of course, hindsight is always 20/20, and there are definitely things I would change. For starters, I would have started sooner. I spent too long thinking about it before jumping in.

Looking back, these 10 years have been an incredible learning experience, filled with growth, challenges, and successes. I’m proud of where we are today, and I look forward to what the future holds. If there’s one thing I’ve learned, it’s that you don’t have to have it all figured out—you just need to keep moving forward, learning from each experience, and staying true to your vision.

On October 30, 2024, Chancellor Rachel Reeves delivered Labour’s first Budget since 2010. This long-awaited statement introduced significant changes to taxes on income, capital gains, pensions, and inheritance tax, targeting wealthier individuals and specific sectors to fund public spending and address economic inequalities. Here’s an overview of the main policies announced:

Tax Treatment for Non-Domiciled Taxpayers

• Four-Year Foreign Income and Gains Exemption (FIG): UK residents who were non-resident in the past 10 years can claim an exemption on foreign income and gains for the first 4 years of their residency, effective April 2025. Qualifying individuals will need to claim this on their tax returns, though they will forego certain personal allowances.
• Temporary Repatriation Facility (TRF): Previously non-domiciled individuals who used the remittance basis can remit untaxed foreign income gains under a new TRF. Available from April 2025, this facility offers a tax rate of 12% for the first two years, increasing to 15% for 2027/28
• Residence-Based IHT System: Set to replace the domicile-based system, the new residence-based IHT policy will tax non-UK assets based on UK residency, with a “tail” period of between 3 and 10 years depending on the length of residence, for those leaving the UK. This approach aims to simplify the rules, but long-term UK residents with overseas assets should expect greater scrutiny.
• Settled Property and Excluded Assets in Trusts: From April 2025, assets held in non-UK trusts will only qualify as excluded property if the settlor hasn’t been a UK resident for over 10 of the past 20 years.
• OWD Relief for Overseas Workdays: Available for the first four years of residence, Overseas Workday Relief (OWD) will no longer require that employment income is kept outside of the UK. However, a financial limit will apply: the lesser of 30% of employment income or £300,000 per year.

Inheritance Tax (IHT) Adjustments

• Pension Funds within IHT Scope: From April 2027, pension funds will fall within the scope of IHT, impacting those with substantial pension wealth.
• Revised Business and Agricultural Property Reliefs: Business and Agricultural Property Reliefs will be reduced from 100% to 50% for assets exceeding a combined value of £1 million, starting in April 2026. The rate on AIM (Alternative Investment Market) shares will also be reduced to 50%.

Capital Gains Tax (CGT)

• Aligned CGT Rates: Starting immediately, capital gains tax rates on all chargeable disposals have been aligned with those for residential property sales, set at 18% for basic rate taxpayers and 24% for higher rate taxpayers and trusts.
• Business Asset Disposal Relief (BADR): Changes are set to come into effect in April 2025, with the BADR rate initially increasing to 14% and then rising to 18% by April 2026. Despite these changes, the lifetime allowance of £1 million for relief remains intact, though new anti-forestalling rules are being introduced to prevent tax avoidance strategies.
• Investors Relief: The lifetime limit for the relief will reduce from £10 million to £1 million for disposals made on or after 30 October 2024.
• Carried Interest Increase: From April 2025, the rate on carried interest (a common form of compensation for private equity fund managers) will increase from its current 18% to a flat 32%.

Other Notable Changes

• Employer NIC Increase: From April 2025, employer National Insurance Contribution rates will rise from 13.8% to 15%, with the threshold for contributions dropping to £5,000.

• Stamp Duty Land Tax (SDLT) Surcharge Increase: Effective October 31, 2024, the SDLT surcharge on second homes will rise from 3% to 5%, aiming to address property market dynamics by deterring multiple property ownership.

• Freeze on Personal Allowance and Tax Thresholds Ending in 2028: After several years of frozen tax allowances, the government has announced these limits will begin to adjust in line with inflation from April 2028.

Implications for Individuals and Businesses

This budget marks a clear focus on closing tax loopholes, increasing tax liabilities on wealthier individuals, and incentivizing domestic investment. The changes could significantly impact high-net-worth individuals, businesses with substantial workforces, and investors. For non-domiciled residents, the move to a residence-based IHT framework and more stringent rules on trusts signal a major shift, demanding careful planning for those with international financial interests.

With these policies, the government aims to generate additional revenue, support essential services, and encourage fairer economic participation across sectors. For individuals and businesses alike, early financial planning and consultation will be essential to adjust to these changes in the coming years.

If you are unsure about how any of these changes impact your affairs, please get in touch with your usual advisor, or reach out to us via the contact form.

Our last post on the changes for non-UK domiciles focused on income tax and capital gains tax.  This post focuses on inheritance tax on non-UK assets but still under the theme of the only clarity being there is no clarity!

There are two strands to the inheritance tax changes – those impacting:

• Individuals; and

• The beneficial inheritance tax treatment of excluded property trusts (broadly trusts set up by non-domiciles under current rules to hold non-UK assets to keep them outside the scope of inheritance tax).

For individuals, the proposals would change the basis of inheritance tax to residence based rather than domicile based.  They would also reduce the time before people coming to the UK come within scope of inheritance tax on non-UK assets and increase the time before people leaving fall outside its scope. 

Labour have confirmed in their policy paper that they will change the basis of inheritance tax from domicile to residence based and that the commencement date will be 6 April 2025.  However, there will not be a formal consultation.  Instead there will be external engagement, including a review of feedback following the announcement in the Spring Budget and further external engagement.

It is with regard to inheritance tax and excluded property trusts where there is the biggest divergence between Labour and the Conservatives, particularly for existing trusts.  Under current rules the beneficial inheritance tax treatment generally continues regardless of changes in the settlor’s domicile.  This makes them a long term inheritance tax mitigation tool especially when someone is about to become deemed domiciled.

It was widely understood that existing trusts would continue this beneficial treatment under the Conservative proposals.  Labour have, though, stated that this would not be the case under them and that all trusts would be caught within the new rules regardless of when they were set up.  The mantra very much being that those staying in UK long term should not be able to avoid inheritance tax through the use of trusts.  What is not clear is how this will be achieved, despite there being a policy paper, so a lot of information we have at the moment remains speculation.

As mentioned in our previous posts, the earliest we are expecting any real detail is the Autmn Budget.  Broadly speaking, it is expected that individuals and trusts coming within the scope of inheritance tax on non-UK assets under the new rules will remain within its scope for a minimum of 10 years.

Since there is even less detail than there is for income tax and capital gains tax, we would expect there to be more speculation on what the changes will look like before we get more specific details.  Until then, we will follow up with further thoughts as soon as there is news that looks remotely like it will provide a bit more clarity.

Key takeaways:

• From 6 April 2025, individuals coming to the UK are expected to come within the scope of inheritance tax on non-UK assets sooner than currently
• It is expected that it will no longer be possible for long-term UK residents to use trusts to shelter non-UK assets from inheritance tax
• The expectation is that individuals and trusts coming within the scope of inheritance tax on non-UK assets will remain within its scope for a minimum of 10 years

Our previous post set the post-General Election scene for the state of play regarding changes to the UK taxation of non-UK domiciles following confirmation of a Labour Government.  In a nutshell, the theme is that the only clarity we have is that there is no clarity.

The outgoing Conservative Government initially announced changes, but with no associated legislation.  Labour have confirmed they similarly intend to make changes but again with no real detail.  The changes will impact how non-UK domiciles are assessed to income tax, capital gains tax and inheritance tax.  This post will focus on income tax and capital gains tax.

For income tax and capital gains, the changes principally involve abolishing the remittance basis and Labour have confirmed in their policy paper that they will do this.  So, it is a safe presumption that this basis of taxation will soon be consigned to the bin (save for some inevitable hangovers).  Therefore, what is clear is there will be change but what will we be left with?

Labour have also confirmed that they will introduce the Conservatives proposal of a new system to replace the remittance basis.  The proposal was for a new system providing a four year exemption for foreign income and gains where prior long-term non-UK tax residency conditions are met.

The Conservative proposals also included four other key foreign income and gains measures alongside the four year exemption:

• A 50% transitional relief for remittance basis users falling outside of the four year exemption.  This relief would exempt 50% of foreign income in 2025/26.
• A temporary repatriation facility to allow previously unremitted income and gains to be remitted at a low tax rate of 12% in 2025/26 and 2026/27.
• A simplified overseas workday relief.
• A capital gains rebasing (strangely to 2019).

The only measure Labour have definitively said that they would not introduce is the 50% transitional relief.  They support the temporary repatriation facility but will make a further announcement in the Autumn Budget relating to the tax rate, the length of time it is in place for and possibly an expansion to include overseas structures.  They have said they will introduce a capital gains rebasing but will announce the rebasing date in the Autumn Budget while they will retain a “form of Overseas Workday Relief”.

In addition to the Conservative proposals, Labour have also said they will review “offshore anti-avoidance legislation”.  This is to “remove ambiguity” and “modernise the rules” to “ensure they are fit for purpose”.  No specific details have been given though changes are not anticipated until 2026/27.

As mentioned in our previous post, the earliest we would expect any real detail is the Autumn Budget.  While we would expect there to be a lot of speculation until then we will follow up with further thoughts as soon as there is news that looks remotely like it will provide a bit more clarity.

Key takeaways:

• As was the case with the outgoing Conservative Government, Labour intend to abolish the remittance basis and replace it with a new four year exemption system
• The new system is expected to be available to arrivers meeting prior residence conditions but will include transitional arrangements for existing remittance basis users
• Offshore anti-avoidance legislation is to be reviewed so that they are modern and effective
• Further detail is not expected until the Autumn Budget

In tax sometimes all we crave is a bit of clarity.  This certainly is the case with changes to the UK taxation of non-UK domiciles first proposed by the Conservatives.  When the proposed changes were announced little detail was given, rather that this would follow in draft legislation.  There has, though, been much speculation.

At Everfair our aim is always to consider the facts and give short shrift to speculation but in such an important area it is sometimes necessary to sort the facts from the fiction.  This post will seek to look at where we are after the General Election and the new Chancellor’s first public spending statement which was accompanied by a policy paper for the changes.  It will aim to sort the facts (or what little facts we do have) from the speculation (most commentary since the announcement of the proposals has been speculation).

While we still do not have any concrete details to be able to discuss the changes with any reliability or clarity, the confirmed change in government has meant a delay in when any detail might surface.  We are now expecting the detail in Labour’s first budget which has been confirmed for the Autumn, due to take place on Wednesday 30 October.  So, it is worthwhile considering where things stand with regard to what Labour have said, particularly in their policy paper.

The policy paper confirms that the non-domicile changes will be introduced by Labour following their confirmation as the new Government but the exact form (and to a lesser extent timing of their introduction) are two very significant unknowns.  So, rather than having the clarity we crave, really the only clarity we have is that there really is no clarity.

The lack of clarity in this important area of UK tax presents tax advisers with an unwelcome dilemma.  We would like to be able to advise our clients to allow them to plan with certainty but this is currently not possible.  Sometimes, though, it might be worth considering different options, including perhaps identifying a worst-case scenario, to formulate a potential plan which will at least allow speedy action once more details are known.

What we do know are that the changes are two-fold, impacting:

• income tax and capital gains tax, principally the removal of the remittance basis; and

• inheritance tax on non-UK assets, especially the use of excluded property trusts (broadly trusts set up by non-domiciles to hold non-UK assets which keep the assets outside the scope of inheritance tax).

Our next post will focus on the impact for income tax and capital gains tax while a subsequent post will focus inheritance tax.

Key takeaways:

• There is no clarity on the tax landscape for non-UK domiciles – changes have been announced but as yet little specific detail has been given.

• The change in Government has delayed when any detail will be given, with this not now expected until the first Labour budget on 30 October.

• As with the Conservatives before them, Labour will introduce changes impacting income tax, capital gains tax and inheritance tax.

As we head into a new tax year, we have summarised all the upcoming changes to tax from 6 April 2024.

Personal Pensions

• As of 6 April 2024, the Lifetime Allowance charge has been abolished.
  • This means there will be no limit on how much you accumulate in your pension in your lifetime (annual limits still apply)
• Capped pension tax-free lump sum at £268,275 – or 25% of your pension pot, whichever is lower.
  • Any withdrawal above this will be subject to income tax at your marginal rates

ISAs

• Tax-efficient ISA allowance remains at £20,000
• Junior ISA annual allowance remains at £9,000
• You can now open and pay into different ISAs of the same type in a single tax year.
• Plans to introduce a British Stocks and Shares ISA, meant to encourage investment in British companies.
  • This would allow you to save an additional £5,000 per year tax efficiently into the new ISA
  • No date announced for when this will be available, consultation to take place

Savings Allowance

• No changes to the personal savings allowance
• Allowance of £1,000 for basic rate taxpayers, £500 for higher rate tax payers and £0 for additional rate tax payers

Dividends Allowance

• Dividend allowance is being reduced from £1,000 to £500 as of 6 April 2024.

Capital Gains Tax

• The CGT allowance has been reduced from £6,000 to £3,000 from 6 April 2024.
• For residential property gains on disposals made from 6 April 2024, the higher rate of CGT will reduce from 28% to 24%.
  • Private Residence Relief will still apply on qualify sales of a main residence

High Income Child Benefit Charge (HICBC)

• The threshold for HICBC will be increasing from £50,000 to £60,000.
• The rate at which HICBC has also been halved from 1% of Child Benefit for every additional £100 earnt above the threshold to 1% for every additional £200 earnt above the threshold
• This means the threshold for which Child Benefit will be completely clawed back has increased from £60,000 to £80,000.
• As long as you earn between £60,000 and £80,000 it may still be worth it financially to claim the benefit.

Personal Tax

• No changes to personal tax rates, or the personal tax thresholds.

National Insurance

• The main rate of primary Class 1 NI contributions will be reduced by 2p from 10% to 8% on earnings between £12,570 and £50,270 per annum (2% rate remains on earnings above this amount).
• The main rate of Class 4 NI contributions will be reduced from 9% to 6% on profits between £12,570 and £50,270 (2% rate remains on profits over this amount).
• Removal of the requirement for the self-employed to pay Class 2 NI contributions with effect from 6 April 2024

Domicile

• The government has announced plans to abolish the remittance basis of taxation for non-UK domiciled taxpayers and replace it with a simpler residence-based system. The changes are proposed to take effect from 6 April 2025
• Overseas Workdays Relief will be reformed based on the new system to remove the need to retain income earned overseas outside the UK
• There will be a consultation to move to a residence-based system for Inheritance Tax

If you have any questions about how these upcoming changes may impact you, please get in touch with your usual advisor, or email us at info@everfairtax.co.uk.