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ARTICLE · 10 DECEMBER 2024

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UK Autumn Budget 2024: A Private Client Perspective

The UK Chancellor's 2024 Budget abolishes the non-dom tax regime, introduces a new FIG system, and imposes changes on inheritance tax, pensions, CGT, and SDLT, with a focus on fiscal tightening.

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In her first Budget, UK Chancellor Rachel Reeves confirmed the abolition of the remittance basis of taxation for non-domiciled UK residents (non-doms) from 6 April 2025, as well as substantially curtailing the current protections for non-UK assets held by non-doms from UK inheritance tax (IHT).

New 'FIG' Regime

Under the current remittance basis, UK resident non-doms are subject to UK tax on their foreign income and gains (FIG) only to the extent that they are remitted to the UK. With the abolition of the non-dom regime, this benefit will be removed.

Instead, 'new arrivers' – referred to in the draft legislation as 'Qualifying New Residents' – to the UK will benefit from 100% relief from UK taxation on their FIG for their first four years of UK residence, providing they have been non-UK resident for at least 10 consecutive tax years prior to becoming UK resident. This new FIG regime will apply whether or not the sums are brought into the UK, removing

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