Planning Considerations for Affected Individuals

The UK’s 2024 Budget has introduced a series of landmark reforms that significantly impact individuals with offshore tax arrangements, particularly those who have historically benefited from non-domiciled (non-dom) status. With new rules coming into effect from April 2025, it is vital for affected individuals to reassess their strategies, ensure compliance, and protect their assets in this evolving regulatory landscape.

At Sandstone Tax, we work closely with clients to navigate these changes, providing tailored solutions to secure wealth while remaining fully compliant with international tax obligations.

Reassessing Tax Planning Strategies

For those who previously relied on non-dom status to manage global tax exposure, the 2024 Budget represents a turning point. These reforms affect both personal tax positions and the offshore structures that many have historically used, such as trusts, companies, and foundations.

As a result, trustees and tax advisors may now need to restructure existing offshore arrangements to maintain efficiency, protect assets, and avoid unintended tax liabilities. Strategies that worked in the past may no longer be suitable under the new framework, making regular reviews and proactive adjustments essential.

Engaging with Advisors

In recognition of the complexity of these reforms, The Treasury is actively consulting with industry stakeholders to shape the final framework and provide clear guidance ahead of the 2025 implementation.

For affected individuals, this makes ongoing communication with experienced advisors crucial. By engaging with tax professionals who understand both domestic and offshore implications, clients can:

  • Stay ahead of regulatory updates.
  • Understand the impact of reforms on their specific circumstances.
  • Identify opportunities to restructure and mitigate exposure.
  • Future-proof their offshore tax strategies.

The earlier these discussions begin, the more options remain available to manage the transition effectively.

Anti-Avoidance and Compliance Enhancements in 2024

Enhancing Compliance

As part of the wider reforms, The Treasury is conducting a full review of existing anti-avoidance legislation, including the Transfer of Assets Abroad (TOAA) rules and Settlements legislation.

This initiative aims to modernise and clarify complex rules, ensuring they remain robust and effective in today's interconnected financial environment. For individuals with offshore structures, this review may necessitate further adjustments to planning, as both current and future arrangements will need to comply with updated legislation.

Increased Resources for HMRC

HMRC has also released new data highlighting significant under-reporting of foreign income among UK residents. In response, the 2024 Budget allocates additional funding and resources to HMRC to intensify its focus on offshore tax non-compliance.

This is expected to lead to:

  • Increased scrutiny of cross-border transactions.
  • More targeted investigations.
  • Enhanced enforcement of anti-avoidance rules.

Given this intensified focus, it is essential for individuals with offshore interests to review their structures and reporting processes to ensure full compliance and reduce risk.

How Sandstone Tax Supports Affected Individuals

At Sandstone Tax, we are already working with clients to prepare for these upcoming changes and protect their long-term financial interests. Our specialist services include:

  • Reviewing and optimising existing offshore structures.
  • Advising on the restructuring of trusts, companies, and foundations.
  • Ensuring full compliance with global standards such as CRS and FATCA.
  • Designing tax-efficient strategies that are built to withstand regulatory change.

Conclusion

The 2024 Budget marks a significant shift for offshore tax planning, particularly for non-doms and individuals with complex international arrangements. With heightened scrutiny, evolving anti-avoidance rules, and increased HMRC resources, proactive planning has never been more important.

By partnering with Sandstone Tax, you gain access to deep expertise, strategic insight, and ongoing support to help you navigate these reforms with confidence.

Contact us today to discuss your offshore tax planning and ensure you are prepared for 2025 and beyond.