In this episode, ahead of the country going to the polls, we will compare each party’s manifesto, looking in particular at their views on the economy, income taxes and personal allowance, CGT, pensions, closing tax loopholes for non-dom and corporate taxation.
Welcome to the opening episode of our First 100 Days in Office podcast series, where we will delve into the elected party’s policies and how these could impact sectors, businesses, and individuals.
In this episode, ahead of the country going to the polls, we will compare each party’s manifesto, looking in particular at their views on the economy, income taxes and personal allowance, CGT, pensions, closing tax loopholes for non-dom and corporate taxation.
Chairing this episode is Paul Barham, Head of International Private Client and an experienced tax partner who advises high-net-worth individuals, their families, and their businesses on international tax affairs.
Joining Paul is:
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Welcome to the opening episode of our First 100 days in office
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podcast series. We’ll delve into the elected party's policies
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and how this could impact sectors, businesses and individuals.
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With under a week to go until the country goes to the polls
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today, we're going to compare each party's manifesto, looking in particular
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at the views of the economy, income taxes,
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capital gains tax, pensions, closing some of the tax
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loopholes for non domiciled individuals and corporate taxation.
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I'm Paul Barham, Head of International Private Client.
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And today I'm joined by our Chief Investment Officer, Ben Seager Scott,
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a Senior Financial Planner from the team
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James Robinson and Lucy Marshal, Corporate Tax Director.
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Ben, if we begin with you, a lot of the headlines
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coming from the party manifestos were focused on the economy.
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What pledges stood out for you?
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Do you think they're achievable?
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Thanks, Paul.
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I mean, I think the main thing that that jumped out of me is,
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is the lack of any real deep economic proposals.
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Indeed, I think the Institute of Fiscal Studies called out
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a conspiracy of silence over how the books are going to be bounced.
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Maybe that's a little bit harsh, but I think all of the parties
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are facing the reality that the tax burden is very high
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spending commitments are high, public services are still under strain
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and borrowing costs are high, which means none of them really have have
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any room to maneuver or differentiate.
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And that's really come through, I think, in the manifestos, I think
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what all the parties are highlighting is this need to achieve growth.
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That means productivity growth is how you get out of this bind.
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You grow your way out of out of trouble.
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but frankly, looking at the manifestos
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at the moment, there's a lot of hope, not very much strategy.
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And I think there is an inference there that strategy will come after
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the election is out of the way.
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But it's not clear from the manifestos that we're seeing at the moment.
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I think there are some positive points in there.
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but really there's a lot of commonality across the major manifestos
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and in particular tend to focus on the Conservative and Labor manifestos.
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I think the tax exemptions we've seen over the last couple of years in areas
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around research and development, those will help business productivity.
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None of the parties are looking to roll those back,
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so that could support medium term productivity gains.
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Equally, there's there's a common point of no intention
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to increase corporation tax.
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What happens down the line and whether they come down.
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There's a bit of differentiation between the parties.
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But I think the main point is no real intentions to increase that
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corporation tax.
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That could be, if not a positive and certainly not a negative
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for the economic and business outlook.
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I think in terms of some of the more eyecatching plans, labor,
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of course, have a plan to create a great British energy corporation
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that's going to be partly funded by a windfall tax on oil and gas.
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Labor's also announced a plan to set up a national wealth
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fund that's going to be focused on clean technology.
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Now these are emotive areas, but I think they're relatively small in isolation.
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What's really missing is any wider material plan for the broader economy.
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Ben. Thank you.
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maybe we could just sort of get your view a little bit of
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what investors would like to see from the next government.
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I think what investors are really clamoring for is stability.
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And that might have to come after the election.
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Once whoever is in power has a chance to lay out their stall a little bit more.
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but stability, I think that's been missing,
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even though one party has been in power for a number of years.
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There's been different sort of Sup regimes within that.
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We've had just the conservative prime ministers Cameron
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that May, then Johnson and Truss then soon act.
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So even within one party there have been several different,
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effects for the mini eras,
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and that's made it difficult, I think, for businesses to plan ahead.
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So I think what investors and businesses are looking for is some sense of stability
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and a more pro-business rhetoric, particularly rewarding businesses
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for investing in long term productivity, because, again, it's it it's crucial
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to get that that idea across, that if we want to grow our way out of the current
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difficult tax situation, that businesses need to be able
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to invest to achieve that, that productivity growth.
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And I think also what we what we need and what investors will be hoping for
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is it is a steering away from windfall taxes.
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We've seen 1 or 2 windfall taxes on oil and gas in limited amounts.
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That's okay.
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What's important is we don't create this environment
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or this sense from the investing and business community
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that any time you make supernormal profits,
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the government is just going to come in and tax it.
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We're not we're not there.
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But I think
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whichever government gets in, investors will be looking for signs
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that they will allow businesses
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to flourish rather than jumping on any profit and tax.
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Get away.
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James, if I turn to you,
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maybe we can just touch a little bit about pension planning.
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I know Labor's backtracked on their plans to reintroduce the lifetime allowance.
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but they have said they'll review pension legislation if elected.
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what do you think they could do?
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as part of that review.
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It's a great question.
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I think the two there's two avenues that I think they could look to go down
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if looking to, to raise tax and to go back to Ben's point
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that it does feel like there is a need
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or that there could be a desire to raise taxes.
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One format or another is the growth that is hoped for to Ben Woods,
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isn't achieved necessarily that the first thing that's been mentioned
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is that they might look to just apply a flat rate of tax relief
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when paying into a pension.
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So at the moment you get tax relief based on whichever rate of income tax you pay.
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So people paying 40 and 45% rates of income tax
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get 40 and 45% tax relief when they pay into their pension,
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so they could look to rely on that as a single flat rate of tax relief.
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However, there was an article the other day from Steve Webb, the former
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pensions minister, that said while this in practice could be something
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they look to do.
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It could
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then be very complicated in terms of how they actually come to administer it.
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And he felt like it would be a bit too difficult to have this work in practice,
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because then we have to consider
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not only what tax relief are you getting on the way in,
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but what rate of tax are people paying on the way out and that
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could this create some form of retrospective tax charges
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if people already with pension funds
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are then going to be taxed in a different way to which they expected
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when they first paid into the pension?
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So that's the first thing we could look at.
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In reality, it might be easier for them to play around with what
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the annual limits are in pension contributions again.
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But when doing this, they have to be very careful about
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affecting different groups, particularly doctors.
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and whether they might be inadvertently
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hitting them with additional tax charges, given how good the NHS pension scheme.
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So so the first is how is it they look at tax relief on the way in the
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the other thing I think could be under review is how death
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benefit taxation operates on pensions, that
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when the lifetime allowance was removed, the way the conservative governments,
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put it was that they're removing the lifetime allowance
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or removing some tax charges that could be payable during your life,
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but they'd be introduced in what's called now called the, the lump sum death
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benefit allowance, which would have capped
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the amount of tax free benefits the next generation could receive.
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So the the implication there was that
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we won't tax it during life, but we're probably going to tax it more on death.
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With the iterative changes that we've seen coming out of pension
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legislation, it is still actually possible.
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Now for people to inherit a pension, keep it within the pension.
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And if death occurred before 75, there's no tax payable.
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If death occurs after 75, those beneficiaries
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could choose when it is they pay an income tax charge.
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So from a UK
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budgetary perspective, that's quite a challenge in that
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in theory, people could just defer when they draw paying from these funds
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indefinitely and never have to pay any tax charge on it.
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To me, what could feel sensible is if they look to apply
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a tax charge on death itself based on the value of benefits,
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but then look to not have a later tax charge apply on drawing income.
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If it were me, that's what I could see is the simplest way of doing it.
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But of course I've been surprised by the legislation changes before.
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Lucy, I thought it could be an interest question
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for you that what do you think it could mean about
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what do you see could change around capital gains tax, inheritance tax?
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And what could that mean around businesses in particular as well?
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Yeah.
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Well there has been quite a lot of talk about raises in capital gains
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tax especially.
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And I think the Liberal Democrats in their manifesto have said
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that they intend to raise capital gains tax, which is an interesting point
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to consider when thinking about it in the context of deals,
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because obviously, an increase in the rate of capital gains
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tax would mean a reduction in the take on proceeds for those business owners.
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And the obvious question is, is that going to put them off?
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which it could do.
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The flip side of that is a time and thing.
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when would we expect to see the changes to capital gains tax rate?
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If it was from next April?
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That may be produces a window to get deals through the line.
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So there could be a slight increase in deals in the short term.
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And then an expected decrease
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in the longer term, which then is something worth considering.
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If you do increase that rate and reduce the number of deals, does that then mean
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the actual take home of capital gains tax doesn't increase
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because you've reduced the number of deals to compensate for the higher rate?
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so it's an it's an interesting one to think about. And
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I guess the
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increase in capital gains tax rate has been threatened
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a number of times over the last, certainly five or so years.
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We've had a few incidents
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where we've expected it to go back and it's not happened for whatever reason.
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So it will be an interesting one to see how it plays out.
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On the other side of that, the on the h IHT side of things,
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there's been a lot of talk about BPR and whether that will remain
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as generous as it is now, and which I think is an interesting point.
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Thinking about it
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from a similar perspective, in that when you've got a trading company
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that qualifies for inheritance tax relief, a BPR,
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you are then encouraging,
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taxpayers to hold on to that asset until they die
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and let it pass on death because it passes free from inheritance tax.
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So maybe changes to BPR could encourage more selling.
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You just don't know.
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It's it's one of those should tax drive any of these things.
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Probably not.
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But it is a factor and something that
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could have an impact.
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Should we see any quite drastic changes?
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Lucy I think obviously business owners are, concerned about their position,
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and how they access, their,
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their investment or access their income generated by the business.
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But unless and then picked up on it earlier,
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there's, there's labor and the conservative parties
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have both said they're not raise corporation tax for these next five years.
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but but what are the benefits of freezing corporation tax?
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and are there any negatives of keeping it at the current rate,
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the main rate of 25% is a really good question,
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and I think it goes back to what Ben was saying at the start.
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What businesses say time and time again is that they want
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stability when it comes to corporation tax.
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And so freezing the rate gives them five years of stability,
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which means they can plan, they can make long term investment decisions.
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They can really think about the future without having changes
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to tax rates every year, which you can see from a business perspective
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how that would be difficult to plan for.
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The other thing is when, like in Lincolnshire, back
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to what we've just said about deals is when we think about value,
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the value of a business on a deal,
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typically that value is calculated
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above, always based on and it's before interest and tax.
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So like tax doesn't really impact the value from that perspective.
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So that's a good thing.
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I feel like when you talk about a tax
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take in a business, it's less personal than the CGT
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and IHT like even business owners, that's their money.
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Whereas the business is money is a different
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psychology, which is quite interesting.
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and the flip side of freezing the corporation
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tax rate is obviously we have quite a generous regime at the minute
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when it comes to full expensing, with which both parties have said
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they're going to keep and at a higher rate of tax.
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You are saving more by getting that relief.
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So that's positive.
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and as Ben alluded to before, both have said
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that they are going to keep the innovation relief such as R&D and patent box,
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again, both generous reliefs that a competitive on an international basis.
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So there are plenty of positives in there.
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I guess the negative side of keeping a 25%
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rate of corporation tax, is it on an international stage?
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It may be quite high, but the other side of that
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is that we now have a global minimum rate of tax at 15%.
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So I think we do see less shopping around for tax rates.
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And companies tend to locate where the commercially need to locate,
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so I don't think
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that would be an overwhelming concern
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for the certainly not our clients.
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Thank you. Lisa.
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James, maybe, we could pick up on,
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what the two main policies said about income tax
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and that they're not intending to increase income tax rates.
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but the Liberal Democrats have said they would raise the personal allowance
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and then look to raise income tax when finances allow.
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How different is this approach from the main parties who have pledged
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to freeze, thresholds until 2028?
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They're both different approaches,
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but in reality they're both trying to do the same thing one way or another.
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But they're just
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it feels like they're trying to do it in a way that feels different politically.
00:14:52:09 - 00:14:56:04
So if you take the example of the Liberal Democrats that said that,
00:14:56:06 - 00:14:59:10
look to increase thresholds and also look to increase the tax rate,
00:14:59:10 - 00:15:03:23
that they're increasing how much you can receive at any particular rate
00:15:04:14 - 00:15:06:12
and not have to pay more tax.
00:15:06:12 - 00:15:07:19
But they might therefore
00:15:08:22 - 00:15:11:23
make you pay more tax on a smaller amount effectively.
00:15:11:23 - 00:15:14:14
So you've got your rate increase, but the amount that you pay
00:15:14:14 - 00:15:16:00
pay it on is decreased effectively.
00:15:16:00 - 00:15:19:18
So you getting out to a similar sort of rate or even a higher rate
00:15:19:18 - 00:15:22:18
overall, rather than a so similar to what it was
00:15:22:21 - 00:15:26:21
for the conservative government and labor, and particularly what the conservative
00:15:27:07 - 00:15:30:14
government has been doing over the last few years already,
00:15:31:02 - 00:15:35:04
is that they've been increasing the overall tax take.
00:15:35:18 - 00:15:38:19
But while being able to say politically, we haven't raised taxes
00:15:39:05 - 00:15:42:19
because what they've what they've let happen is increasing
00:15:42:19 - 00:15:46:17
incomes and asset values over time has meant that more
00:15:46:17 - 00:15:49:17
people are paying tax at the higher rate or more people are paying.
00:15:49:17 - 00:15:52:05
Inheritance tax has been mentioned before already,
00:15:52:05 - 00:15:55:08
but just at the same percentage rate as it was before,
00:15:55:08 - 00:15:58:24
but by more people having higher incomes and higher asset values,
00:15:59:24 - 00:16:01:23
even by keeping the percentage tax rate
00:16:01:23 - 00:16:05:04
the same, it increases the overall tax rate for the UK government,
00:16:05:10 - 00:16:08:09
and it also increases the overall effective rate of tax.
00:16:08:09 - 00:16:11:09
People are paying on their overall incomes and over all assets.
00:16:11:18 - 00:16:15:15
It's been deemed a number of different times of the stealth tax over the years,
00:16:16:00 - 00:16:19:08
and it is something that people need to be careful of, is that even though
00:16:19:08 - 00:16:24:06
the headline rate is going up, by keeping allowances fixed for a number of years,
00:16:24:16 - 00:16:27:08
it should be increasing the amount of tax they pay over time.
00:16:27:08 - 00:16:29:10
Certainly. Okay.
00:16:29:10 - 00:16:30:24
And one of the things we've not really touched
00:16:30:24 - 00:16:34:10
upon, we've been talking about tax rates up to now is the impact of,
00:16:36:17 - 00:16:39:07
the international perspective for individuals.
00:16:39:07 - 00:16:43:17
Eight manifesto and a common theme throughout the discussion of tax
00:16:44:02 - 00:16:44:19
and the election over
00:16:44:19 - 00:16:48:18
the last few months has been around clear closing loopholes for Non-Doms.
00:16:50:18 - 00:16:52:10
and we saw that process really start
00:16:52:10 - 00:16:55:11
in, in March with the conservative government's budget,
00:16:56:04 - 00:16:59:10
where they were looking to move Non-Doms
00:16:59:10 - 00:17:02:23
and the tax regime for non domiciled individuals to a residency
00:17:02:23 - 00:17:05:23
based system.
00:17:06:05 - 00:17:07:10
the consequence of that
00:17:07:10 - 00:17:12:08
was that under those those rules, after four years of residency,
00:17:12:12 - 00:17:17:13
people from overseas would be paying the same tax basis as, as, as anybody.
00:17:18:04 - 00:17:21:04
from, from born, raised in the UK.
00:17:22:08 - 00:17:24:17
I guess when you look through the manifesto
00:17:24:17 - 00:17:27:17
and when I've taken it through the manifesto, is there certainly being,
00:17:28:12 - 00:17:30:05
comments around what might happen.
00:17:30:05 - 00:17:33:15
And in the press we've had, various announcements.
00:17:34:07 - 00:17:39:01
I think if we look at where we were, we seem to still have protected
00:17:39:01 - 00:17:43:01
trust status as an option, which certainly had inheritance
00:17:43:01 - 00:17:46:05
tax benefits for certain grandfathered offshore trusts.
00:17:47:23 - 00:17:52:07
the government in March, also announced,
00:17:52:17 - 00:17:57:01
a number of transitional provisions to move people off the non-dom regime.
00:17:57:08 - 00:18:00:11
And into that residency, system.
00:18:01:08 - 00:18:04:11
And some of the parties have sort
00:18:04:11 - 00:18:07:11
of discussed to a certain degree,
00:18:07:15 - 00:18:10:23
how they might tighten up on some of those, provisions,
00:18:12:00 - 00:18:15:00
to deal with that transition from one regime to the other.
00:18:16:02 - 00:18:19:02
I suspect we'll see a lot of changes.
00:18:19:04 - 00:18:22:07
on closing those loopholes in the next few months,
00:18:22:14 - 00:18:25:07
in the same way that you might hope to see more detail about
00:18:25:07 - 00:18:28:11
where the policy on income tax is going to go more widely.
00:18:28:23 - 00:18:31:15
Lucie's point on capital gains tax.
00:18:31:15 - 00:18:35:05
so we'll we'll we'll have to somewhat sort of wait and see.
00:18:36:06 - 00:18:41:04
but then with, with one of these changes or lack of clarity of the,
00:18:42:15 - 00:18:43:23
the hopeful clarity
00:18:43:23 - 00:18:48:12
that we will get in the coming weeks, how how does that impact
00:18:48:12 - 00:18:52:17
on the attractiveness of the UK amongst international investors?
00:18:53:17 - 00:18:55:20
I think, it's
00:18:55:20 - 00:18:59:03
that the first order effects are probably quite limited.
00:18:59:16 - 00:19:03:17
because a lot of these rule changes are aimed at individual deals
00:19:03:18 - 00:19:06:18
rather than businesses and the economy.
00:19:06:18 - 00:19:07:10
So I think
00:19:07:10 - 00:19:12:12
in terms of the fundamental attractiveness for now, it's a little bit more limited.
00:19:12:12 - 00:19:17:07
Of course, a lot of, non-doms are going to be international investors,
00:19:17:13 - 00:19:20:13
but then the broader international investor community,
00:19:21:18 - 00:19:24:18
non-doms are probably only a very small part of that.
00:19:24:23 - 00:19:27:18
Overall, I think it's much more about sentiment.
00:19:27:18 - 00:19:32:01
And I think though it doesn't necessarily make the UK less attractive,
00:19:32:06 - 00:19:35:04
potentially, it might make it a slightly
00:19:35:04 - 00:19:39:06
less attractive place to live for some investors, but it doesn't.
00:19:39:06 - 00:19:42:03
It shouldn't really affect directly the underlying market.
00:19:42:03 - 00:19:46:02
But again, like we're talking earlier about some of the windfall taxes
00:19:46:02 - 00:19:49:15
and other elements in and of itself, these these changes
00:19:49:15 - 00:19:53:04
probably don't change the attractiveness of the UK market.
00:19:53:10 - 00:19:57:01
But there is always the risk that if you start to be seen as being less
00:19:57:01 - 00:20:00:17
friendly to international investors, then that could start to change
00:20:00:22 - 00:20:01:24
some of the sentiments.
00:20:01:24 - 00:20:06:07
There's probably more of a sentiment risk rather than a fundamental attractiveness
00:20:06:07 - 00:20:08:05
risk, and it's going to be a calibration
00:20:08:05 - 00:20:11:01
that any government is going to need to think about.
00:20:11:01 - 00:20:16:03
The one area that that's related that perhaps would change some of the views,
00:20:16:03 - 00:20:20:13
but none the parties are talking about is stamp duty reserve tax.
00:20:20:13 - 00:20:22:19
Now, this is a tax the investors have to pay.
00:20:22:19 - 00:20:27:03
It's about half a percent or less, half a percent on most or on the purchase
00:20:27:03 - 00:20:31:17
of most shares in the UK and the UK is starting to become an outlier
00:20:32:13 - 00:20:36:08
in charging this sort of share transaction based tax.
00:20:36:08 - 00:20:38:17
But none of the parties are talking about it.
00:20:38:17 - 00:20:41:20
If if the government wants to change the attractiveness
00:20:41:20 - 00:20:46:05
of UK equities to international investors, that's investors generally.
00:20:46:10 - 00:20:47:19
That's an area they could look at.
00:20:47:19 - 00:20:51:18
But for now, that's not in scope of any of the parties.
00:20:52:06 - 00:20:54:12
Ben. Thank you. let's wrap up.
00:20:54:12 - 00:20:59:01
Firstly, thank you very much to Ben, Lucy and James for joining me today.
00:20:59:16 - 00:21:04:00
There are a number of themes that each manifesto seems to be covering.
00:21:05:12 - 00:21:07:08
I guess the point
00:21:07:08 - 00:21:11:01
that seems to sort of run throughout all of them is the focus on growth.
00:21:11:09 - 00:21:13:23
Despite some of the warnings about balancing the books
00:21:13:23 - 00:21:16:23
and the IMF comments a couple of months ago around
00:21:16:23 - 00:21:19:23
needing to be careful of tax cuts.
00:21:20:09 - 00:21:22:22
Some parties talk about increasing taxes,
00:21:22:22 - 00:21:26:04
others, hoping much more for a growth in the economy.
00:21:26:15 - 00:21:30:12
There is, in any event, a real change, in terms of tax
00:21:30:12 - 00:21:33:00
and the landscape for tax in the next few months,
00:21:33:00 - 00:21:37:05
it was really important to keep focused on planning for the future
00:21:37:05 - 00:21:41:10
and creating flexibility within that plan so that as and when we learn more
00:21:41:10 - 00:21:45:00
about these changes, you can reflect those in in whatever you do.
00:21:46:09 - 00:21:49:09
Our next episode will be released on Friday the 5th of July.
00:21:49:10 - 00:21:52:11
We'll be joined by our economist, who will give us
00:21:52:11 - 00:21:55:11
an update on how the markets have reacted to our new government.
00:21:56:16 - 00:21:58:08
Thank you for listening today.
00:21:58:08 - 00:22:01:16
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00:22:01:16 - 00:22:02:18
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