UK Autumn Budget 2024

On 30 October 2024, the UK Chancellor of the Exchequer Rachel Reeves delivered her Autumn Budget, the first budget of the Labour government elected earlier this year and the first UK budget delivered by a female Chancellor.

As the government had previously identified a shortfall in state finances, tax rises had been expected and these have taken the form of an increase in employers' national insurance contributions, changes to the way in which 'carried interest' is taxed (with both 'winners' and 'losers'), some capital gains tax increases and changes to the taxation of non-domiciled individuals as well as changes to inheritance tax. The government also plans to invest further in tax authority compliance staff.

The government has however also published a Corporate Tax Roadmap alongside the Budget. The roadmap includes a commitment to cap the headline rate of corporation tax at 25% (the lowest in the G7) for this Parliament (expected to be until 2029), to maintain the 'full expensing' regime for capital assets, to maintain R&D reliefs and enhance their administration by establishing an R&D expert advisory panel and to consult on widening the use of advance clearances for R&D reliefs. The government also plans to consult on a new process intended to give investors in major projects increased advance certainty.

The roadmap also refers to the government's plan to consult further on changes to the UK rules on transfer pricing – including the possible removal of UK-to-UK transfer pricing, potentially lowering the thresholds for exemption from the rules and on introducing a requirement for multinationals to report cross-border related party transactions to the UK tax authority. The government has additionally said that it will review the transfer pricing treatment of cost contribution arrangements. 

The roadmap reaffirms the UK's commitments to Pillar One and Pillar Two and includes a stated intention to consider opportunities for simplification of the UK's rules for taxing cross-border activities in light of the UK's adoption of Pillar Two. It repeats the promise to repeal the Offshore Receipts in respect of Intangible Property legislation from 31 December 2024 (from when the Pillar Two UTPR will apply).

Read our analysis of the announcements relating to multinational businesses, investment funds, the real estate sector, VAT, employees, share incentives and individuals.