Partner James Cook and trainee Aidan Chan have contributed an article to Taxation Magazine which discusses the far-reaching private client tax reforms announced in Rachel Reeves’ October 2024 Budget, focusing on changes to the non-dom regime, inheritance tax (IHT) planning and pensions.
The article outlines how the abolition of the non-dom regime from April 2025 marks a major shift to a residence-based system, bringing more long-term UK residents within the scope of IHT on their worldwide estates. While transitional measures and the FIG regime provide limited short-term relief, the authors highlight increased complexity, administrative burden and the risk of capital flight. They also examine reforms to business and agricultural property reliefs, including the £1m lifetime cap on full relief from April 2026, and the inclusion of most pension assets within the IHT net from April 2027. Overall, James and Aidan suggest that reforms intended to promote fairness may undermine simplicity and make long-term wealth and succession planning more difficult.
Rachel Reeves’ first Budget aimed to introduce reforms to produce a fair and broader tax base. However, the reforms have arguably created complexity and disruption for retirement planning, family businesses and long-term wealth strategies.
The full article is available online at Taxation by subscription only.
About James and Aidan
James Cook is a partner in the private client team. He advises on estate and succession planning, wills, probate, trusts, tax-planning, lasting powers of attorney, enduring powers of attorney and Court of Protection matters. His work often includes international elements whereby he advises both UK and non-UK clients. Aidan Chan is a trainee in the same team.
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