Tax Administration and Maintenance Day 2024

In recent years ‘Tax Administration and Maintenance Day’ (TAM Day) has become an annual event when the Government usually publishes a number of new consultations, consultation responses and new announcements. This year TAM Day was on 18 April 2024, however, it was a much lighter in content than usual and only four announcements were madeopens in a new tab, two of which were new consultations.

As anticipated, no further information was published on TAM Day about the current Government’s reform of the non-dom regime and the introduction, from April 2025, of the new four year Foreign Income and Gains (FIG) Regime for income tax and capital gains tax and the residency-based system for inheritance tax (IHT).

It is expected that HMRC will in due course publish a consultation on the new residency-based system for IHT and further details of the FIG Regime, such as the transitional rules including capital gains tax rebasing and the Temporary Repatriation Facility, and the eligibility criteria for Overseas Workday Relief. HMRC have now confirmed that they will be holding a series of ‘listening events’ between 13 and 31 May 2024. These sessions will provide an opportunity for interested parties to provide comments on the policy changes announced at the Spring Budget 2024. It is anticipated that HMRC may be in a position to confirm areas of focus in the next few months, that draft legislation will be published, and that consultation will take place over the summer. With Rachel Reeves’ response to the Budget announcements, clearly further changes may still be to come, with Party Manifestos expected later in the year.  

It is always challenging to estimate what the future impact of a proposed change to the tax regime will be, but the current uncertainty around the detail of what the actual changes will look like makes this even more difficult for individuals, trustees and employers. For those likely to be affected it will continue to be important to analyse the changes and monitor developments as they arise.

New consultations

Two consultations were published on TAM Day:

• Consultation on the VAT treatment of Private Hire Vehiclesopens in a new tab: Following recent Uber High Court judgments, this consultation seeks views on potential ways the Government may be able to mitigate unintended consequences on the Personal Hire Vehicle sector and passengers; and
• Mandating postcode provision for Freeports and Investment Zones National Insurance contributions reliefsopens in a new tab: This consultation seeks views on draft regulations which introduce a new reporting requirement for Freeport and Investment Zone employers who claim NIC reliefs to provide a workplace postcode for the employees they claim NIC relief for.

Other announcements

There were also two further announcements made on TAM Day:

•  VAT treatment of charitable donationsopens in a new tab: A consultation will be launched by 23 July on the introduction of a targeted VAT relief for low value goods donated by businesses to charities; and
• Tackling non-compliance in the umbrella companies marketopens in a new tab: The outcome of this consultation is still awaited. However, at TAM Day the Government announced it is minded to introduce a due diligence requirement to exclude non-compliant umbrella companies from labour supply chains. It will engage with key stakeholders, including the recruitment industry, on the details of this proposed statutory due diligence regime. The Government will also publish new guidance, including an online pay checking tool for workers, later this year. In the meantime, you can read our previous coverage of this consultation’s proposed changes to employment rights and to employment tax compliance obligations, and of previous guidance published by HMRC. 

For further information please contact:

• Tim Sarson
• Sharon Baynham