Tax
OPINION OF THE WEEK: A Big Tax Hit To HNW Individuals – The UK Budget

The editor reflects on the first Budget from a Labour-led UK administration for 14 years. It was, judging by the previews, never going to make for happy reading. And so it proved.
Well, at last, the UK’s new finance minister, Rachel Reeves,
delivered her Autumn Budget yesterday, just in time for
Halloween. In total, there were almost ÂŁ40 billion ($52
billion) of tax hikes; there was additional borrowing, arguments
– some highly controversial – about the true size of fiscal
“black holes,” and promises to make parts of the public
sector more efficient. (Good luck with that.) As of the time of
writing these words a few hours after Reeves stopped talking, UK
government bond markets are a bit softer, and my editorial
colleagues are wading through a mass of reactions.
There has been considerable speculation for weeks about tax
hikes. And this duly took place: a rise in capital gains
tax, a squeeze on the reliefs for inheritance tax, higher
employers’ National Insurance contributions (which are likely to
be passed on almost entirely to employees, which arguably kills a
pledge in the Labour Party manifesto of this year); no
continuation of the income tax threshold freeze beyond the
current 2028/29 cutoff (which is some small comfort,
assuming that does not change), and the imposition of value added
tax on private schools.
And in a move that surprises few, Reeves has moved ahead with
removing the UK’s resident non-domicile system and is
adopting a temporary residence-based approach instead.
“Domicile” will cease to be a feature of the UK tax code. Details
about trusts and inheritance tax are crucial, and they don't
look good. Stephen Kenny, head of private client at audit
and accountancy firm PKF Littlejohn, said Reeves has left
non-doms with few reasons not to leave the UK as soon as
possible. He wrote in a note yesterday: "Historically, the IHT
payable on an offshore trust was always linked to the settlor’s
domicile at the time they settled it. It’s now linked to the
settlor’s residence at the time of the charge, which massively
increases potential liabilities. For many non-doms, paying
UK IHT on all assets in an offshore trust will be unacceptable.
There’s no question that many people in this situation will leave
the country to [move to] more tax-favourable jurisdictions."
Another comment, from Matthew Sperry, Private Wealth partner
at Katten Muchin Rosenman. catches the flavour of the
change: “Labour seems to have largely adopted what they had
proposed previously. This includes no grandfathering for trusts
that were IHT protected, meaning foreigners resident in the UK
for 10 years will be fully exposed to IHT – including those
that settled trusts that were IHT exempt under current law. I
fully expect that this news will hasten the exit for many
non-doms that were advised to postpone any moves until after this
Budget. Labour has ignored those that have warned that this move
would eviscerate the non-dom tax base."
Well, that appears to undermine the notion that Reeves might have
been willing to soften the IHT blow.
While some speculation before yesterday may have added to a
sense of panic, it is also uncontroversial to state that the
long lead-time to the Budget has created plenty of time for
people to fret, examine foreign options, and act. Data
suggests that business owners and holders of equities,
for example, have sold out to avoid a possible big CGT hike. Even
if the actual new CGT rates aren’t as scary as thought, will
these people reverse course?
This is an ideological Budget, and clearly very pro-state in its
direction of travel. The package shifts resources from
the wealth-producing side of the country to the wealth
consumption side. While not as severe as some feared, the changed
rules on IHT mean that there is more risk that a family-run farm
or business might be broken up upon the death of the original
owners, particularly if a farm or firm is above a certain
financial size. That seems hard to square with the fact that
family-owned businesses are often the bedrock of a broad-based
economy and society, and often make better employers.
Now it is true that spending on medical care and improving
infrastructure will ultimately boost the supply side of the
economy; if our roads are better, broadband is faster and our
health is more robust (fewer people will be off work because they
are ill, etc). But all too often politicians of all stripes like
to call spending “investment,” but that can play fast and
loose with what businesspeople understand investment to be. Quite
a lot of the higher spending is on consumption – such as
above-inflation pay rises for public sector (unionised)
employees. The productivity of the state typically lags that of
the private sector. Tilting the balance yet further to the public
sector does not seem a formula for faster growth. If we look at
the countries around the world where wealth rises fastest, they
tend to be less heavily taxed in general. Even socialist Sweden
moved away from this model in the 1990s, to give one example.
Of course, the wealth sector cannot be insulated from worries
that have arisen in recent times about widening
inequality and rising demands on the public purse from, say,
the defence side (Ukraine, other), better medical care (for
example, mental health and ageing populations), and the like.
Reeves made much of the alleged neglect of certain areas of
spending in her speech yesterday, and it is hard not to be struck
by what she said. Many of us no doubt grumble about potholes in
the roads, or spotty internet connections, or the fact that no
reservoirs have been built in the UK for more than three decades.
There is a lot to do.
But I worry that with the world economy in a difficult
position, and facing likely tariff hikes if there is a Trump
presidency in the US next January, and still handling the
disruptions from geopolitics and the pandemic, now is not the
time to add to burdens on business. I am unconvinced that
Reeves’ effort yesterday will go down as a net plus for the UK
economy. I hope I am wrong.
Where do we go from here?
Where does all this leave the UK-based wealth management
industry, and how the country is seen abroad?
In talking to people in Switzerland, Singapore, Dubai, the US and
Luxembourg, to give a few cases, there is a sense that the
country is losing its wealth edge, and quickly. Unless Reeves and
colleagues are able to counter this and learn, the impression
appears now set that the UK is not a friendly place for wealth
owners.
Now it is true that when there is uncertainty and change, this
creates much work for private client advisors. People tell me
they are flat-out with work. A London-based lawyer who has worked
in the field for decades says clients are worried and he is
spending a lot of time talking to them. I come across this time
and again.
But getting work from people who are trying to reduce the impact of a policy is only one way to make a living, and it is arguably a diminishing advantage. Overall, the UK must expand the cohort of affluent and HNW individuals and families, and that means encouraging enterprise. It is clear, to my mind, that the UK wealth sector is operating in a chilly cultural environment, and needs to raise its game in explaining to a wider public why wealth management matters, and why helping and guiding entrepreneurs and heads of business is important.
It may be that the passing of time will do the job of changing minds. If there really is a big flight of HNW people abroad, and the tax base shrinks and the economy is sluggish, Reeves might have to change course, particularly if opinion polls look grim and her party starts losing by-elections.
The wealth sector, whether the government likes it or not, cannot hope to keep its head down and hope for the best, but it must prepare for changes and try to influence thinking more than it perhaps has chosen to do in the past. The sector must be part of a growing conversation, and be as constructive as it can be. For example, family offices and other holders of large blocks of capital must try and insert themselves into conversations about how to invest in areas such as infrastructure, which politicians like to make much of.
This Budget was never going to be a fun experience for the affluent and HNW end of the population once this new government came into office. And thus it has proved.