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It should come as no surprise that measures contained in the Budget replace the UK's current tax regime for non-UK domiciled individuals ("non-doms") with a new regime. Before the general election, the previous Conservative government and the Labour party in opposition both committed to introducing this change.
Prior to the Budget, there was widespread speculation that the Chancellor would make sweeping changes to the Capital Gains Tax ("CGT") regime, either by significantly increasing rates or by radically reducing existing reliefs (or both). However, as it turns out, most will likely view the Budget CGT changes as being relatively modest in comparison with what the government might have introduced. It seems unlikely the measures announced today will cause a substantial change in taxpayer behaviour as, crucially, there still remains a significant delta between the highest rates of income tax (45%) and capital gains tax (24%).
From an incentives and remuneration perspective, the measures announced in the Budget were rather piecemeal. With no fundamental changes to tax-advantaged employee plans (we are still waiting for a response to the call for evidence on all-employee plans) other aspects of the Chancellor's statement could nevertheless increase their appeal.
On 8 October 2024, the Investment Association (IA) published its much anticipated "Principles of Remuneration" (Principles) to guide remuneration committees over the 2025 AGM season.
The FCA has published some key findings on non-financial misconduct, including action points for firms. Although the survey was aimed at wholesale firms, the key findings report (Report) sets out some actions that firms should take in order to address non-financial misconduct.
In the fifth episode of this series, Senior Counsel Elissavet Grout, Senior Counsel Joseph Sheldrick and Associate Amy Broderick from our Tax team discuss the current inheritance tax rules and the potential changes that are anticipated in the forthcoming Autumn Budget.
In the sixth episode of this series, Nick White, Knowledge Counsel in our Pensions team, outlines some of the pensions tax options available to Chancellor of the Exchequer Rachel Reeves, as she prepares to deliver the new Government's first Budget.
In the seventh episode of this series, Senior Associate Aimee Hutchinson and Associate Claudia French from our Tax team shed light on some possible changes Labour may make to Real Estate taxes ahead of the forthcoming Autumn Budget. They discuss Labour's manifesto pledges, the future of the reserved investor fund and how other anticipated tax changes to CGT and carried interest will impact the real estate sector.
In the first episode of our series From Manifesto to Budget, Tax Partner Elena Rowlands, and Senior Associates Tom Margesson and Sarah Roman from our Asset Management Tax team provide an overview of the carried interest tax rules and discuss what measures the Government might introduce in the upcoming Autumn Budget 2024 to close what it has termed the "carried interest loophole".
In the second episode of this series, Partner Mahesh Varia, Senior Associate Claire Prentice and Trainee Michelle Soo from our Tax team, discuss the potential reforms to the tax treatment of individuals who are not UK-domiciled ("non-doms") in the upcoming Autumn Budget 2024. They cover the Labour party's election manifesto, updates by the new Labour government since winning the election and what we might expect in the Budget.
In the fourth episode of this series, Tax Partner Hannah Manning, Knowledge Counsel Kulsoom Hadi and Trainee Solicitors Josh Channon and Amar Degon discuss the possible reforms to capital gains tax to be announced in the Autumn Budget on 30 October 2024. The team reviews speculation from recent commentary and delves into past budget announcements, as well as discussing comparisons with CGT rates in other countries.
In the third episode of series, Head of Tax, Russell Warren, Associate Ross McGregor and Trainee Nadia Ashbridge discuss the possible reforms to key business taxes including Corporation Tax, VAT and Employer NICs expected to be announced in the Autumn Budget on 30 October 2024. The team also consider Labour's manifesto pledge promising a Business Taxes Roadmap and what this might mean for businesses in the longer term.
Amidst the disciplinary proceedings referred to an independent commission by the Premier League (the "League") in respect of alleged breaches by Manchester City Football Club ("City") of the League's financial rules, a decision has been made in the separate arbitration proceedings brought by City against the League in relation to its rules concerning Associated Party Transactions (the "APT Rules").
Welcome to the third edition of the Travers Smith Outsourcing Spotlight. In this issue, we look at the impact on outsourcing of the new Labour Government's employment reforms and the Digital Markets, Competition and Consumers Act 2024. We also discuss a range of other topics including artificial intelligence, smart contracts and a recent Supreme Court decision on force majeure clauses.
This article was first published in the October 2024 issue of Butterworths Journal of International Banking and Financial Law.
On 19 September, the Court of Justice ("CJEU") handed down its judgment in Booking.com BV and Booking.com (Deutschland) GmbH v 25hours Hotel Company Berlin GmbH and Others. This case made its way to the CJEU as a reference for preliminary ruling from the Amsterdam District Court connected to a private dispute between Booking.com and a number of providers of accommodation services in Germany.
Our round-up of recent and forthcoming developments in UK law and practice for our international stakeholders.