The first Labour Budget in 14 years and the first ever delivered by a female Chancellor of the Exchequer took place on 30 October 2024.  Rachel Reeves’ claim that the only way to deliver economic growth was to “invest, invest, invest” was met with chants of “tax, tax, tax” by the opposition.

So what type of Budget was delivered? A budget “putting more pounds in people’s pockets” or one of the largest tax raids in the history of a single Budget?

There are 40 billion reasons that would suggest the latter.

Major reforms relating to the concept of domicile, inheritance tax and the remittance basis of taxation were announced and further information on these announcements can be found here:

In addition to these significant changes there were further measures announced as follows:

Income Tax

Maintaining the Chancellor’s promise that she would shield workers from a rise in taxes there are no increases to the income tax rates and the Labour Government will not extend the current freeze on income tax thresholds, meaning that from 6 April 2028, personal allowances will be increased in line with inflation.

Capital Gains Tax (“CGT”)

As expected, there were increases in the rates of Capital Gains Tax (“CGT”).

The CGT lower rate of 10% and higher rate of 20% have increased to 18% and 24% respectively from 30 October 2024.  The new rates will match the residential property rates, which are not increasing.

Business Asset Disposal Relief (“BADR”) and Investors Relief (“IR”), currently offer a lower rate of CGT relief at 10%.  These rates will increase gradually to 14% from 6 April 2025 and will match the main CGT rate of 18% from 6 April 2026.

The lifetime limit for IR will be reduced to from £10 million to £1 million for all qualifying assets made after 30 October 2024, matching the lifetime limit for BADR.

From 6 April 2025 the CGT rate on carried interest, a performance-related reward received by fund management executives, will increase from 28% to 32%. The increased tax rate will be an interim measure ahead of full reform for the tax regime for carried interest, which will be completed by April 2026.  This reform will see carried interest fully subject to income tax and not CGT. 

Stamp Duty Land Tax (“SDLT”)

The SDLT surcharge for additional dwellings is increasing by 2% to 5%, in addition to the standard residential rates of SDLT, from 31 October 2024.  The surcharge applies to purchases of second homes, buy-to-let residential properties as well as companies and trusts purchasing residential properties. 

The single rate of SDLT payable by companies and other non-natural persons when purchasing residential properties worth more than £500,000 has increased from 15% to 17%.

Non-UK residents (including trusts and companies) purchasing additional property are already subject to a SDLT surcharge of 2% and, therefore, these increases will result in total surcharges of 7% for offshore entities.

Those who exchanged contracts prior to 31 October 2024 are not affected by this rate increase.

National Insurance (“NI”)

Over 50% of the £40 billion taxes raised will come from the NI regime.

From 6 April 2025 the employer’s rate of NI will increased by 1.2% to 15%.  The threshold at which employers start to pay contributions will be reduced from £9,100 per year to £5,000 per year.  To support small businesses the Employment Allowance will increase from £5,000 to £10,500 and the £100,000 threshold is being removed.

The Government will not extend the freeze on the NI contribution thresholds.  From April 2028 the employee contribution thresholds will be uprated in line with inflation.

Corporation Tax

The current main rate of corporation tax at 25% will not be increased for the duration of this Parliament.  The Small Profits Rate and marginal relief will also be maintained at their current rate and thresholds. 

Research & Development Relief and Capital Allowances were maintained at current rates.

The 100% First Year Allowances for qualifying expenditure on zero emissions cars and qualifying expenditure on plant and machinery for electric vehicle charge points will be extended for a further year to 31 March 2026 for corporation tax purposes.

The £1 million Annual Investment Allowance will also remain.

Inheritance Tax (“IHT”)

Thresholds

The current IHT thresholds are due to be frozen until 5 April 2028 and Labour have extended this freeze by a further two years until 5 April 2030.

The nil rate band remains at £325,000 and residence nil rate band remains at £175,000.

This means that 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 IHT liability.

Reliefs

Agricultural Property (“APR”) and Business Property Relief (“BPR”) will be reformed from 6 April 2026. The reliefs will be restricted so that only the first £1m of combined APR and BPR assets will be exempt from IHT.

Thereafter the rate of relief will reduce to 50% resulting in a total IHT rate of 20%. The 20% rate will also apply in all circumstances for quoted shares designated as “not listed” on the markets of recognised stock exchanges, such as AIM. 

For trusts the £1 million exemption applies as above, however, there is no reduced rate for values above £1 million, the IHT rate remains 40%.