约翰娜·雷加图索和哈里·斯威夫特编剧. 

Chancellor Jeremy Hunt has now delivered his statement on UK tax and spending. Out of the past five Chancellors, he is only the second to hold the iconic red box outside No. 唐宁街11号.

There has been very little in the press in the run-up to this Budget with many speculating that this is deliberate in order to give a message of stability following the recent turmoil in the Conservative Party.

Two of the three key announcements relating to personal tax changes are in respect of pensions, 而第三个则涉及附带权益:

• The pension contribution Annual Allowance has been increased from £40,000 to £60,000. 4月6日起, 2023, the Annual Allowance will be tapered if, broadly, your annual income is more than £260,000. The minimum tapered Annual Allowance you can have has been increased from £4,000 to £10,000. 与此一致, the Money Purchase Annual Allowance (applicable to those who have started to access their defined contribution plans or Qualifying Overseas Pension that has had UK tax relief) has also been increased from £4,000 to £10,000.
• The pension Lifetime Allowance has been abolished so there will be no limit on the amount that can be saved. 之前的限额是107万英镑.
• A proposal to include a provision in the Carried Interest legislation to enable “any individual who expects to receive carried interest to make a voluntary and irrevocable election for their carried interest to be taxed in the UK on an accruals basis”. This is intended to mitigate the potential double taxation that might otherwise arise when Carried Interest is recognized and charged to tax at different times in two jurisdictions.

As expected there appear to have been no changes to the measures already announced in 2022. 提醒一下, here are some of the headlines affecting individual taxpayers that would be part of the Finance Act 2023:

• Income tax basic rate thresholds the income tax basic rate band (income between £12,571英镑和50英镑,到4月6日为止将维持不变, 2028. 
• Income tax additional rate threshold: the income tax additional rate threshold, 从那时起，所得税开始征收45%, 会从150英镑降下来吗,000 to £125,140，由四月六日起生效, 2023.
• 个人所得税免税额(12英镑),(2022/23年度为570), National Insurance thresholds and Inheritance Tax threshold will be maintained until April 2028.
• Dividend allowance: The dividend allowance for income tax will be reduced from £2,000 to £1,由四月六日起生效, 然后在2024/25纳税年度再次降至500英镑.
• 资本利得税(CGT)年度免税额:将从12英镑减少,300 to £6,由四月六日起生效, 到2023年，将进一步降至3英镑,由四月六日起生效, 2024. 

US & 英国互动-规划机会

对于居住在英国的美国人来说，他们的全球收入都要纳税, the UK will continue to drive their tax exposure as the UK tax rates are generally higher compared to the US federal rates. 

It is as important as ever for people with dual US/UK tax exposure to seek advice to manage their tax positions. To achieve this we work closely with investment and wealth managers as well as other advisors to help our clients deal with the implications of being US and UK taxpayers.

Below we consider three common ways in which individuals might reduce their UK tax liability although, 在采取任何行动之前, appropriate advice should be sought regarding the potential US tax implications.

• Pension contributions: following the Chancellor’s announcement today people might want to increase their pension savings. 英国的税收减免适用于个人和雇主养老金缴款. 然而, 如果你是一个高收入者, 应注意不要超过增加的年度免税额.

US tax relief might also be available under the US/UK Double Taxation Agreement for contributions to UK pension plans. 根据条约要求扣除的好处似乎是显而易见的, 但在某些情况下, 放弃条约要求可能更有利. This could be an opportunity to utilize excess foreign tax credits to absorb the US tax on the contributions and result in a US tax-free basis in the pension. This could represent a significant tax saving at the distribution phase depending on how the pension is distributed and where you reside at the time.

Attention should be paid to US Owners of personal pension plans as they may trigger additional 申请要求. 

• Charitable giving – UK tax relief can be obtained for qualifying charitable donations. 对于拥有美英双重国籍的纳税人, we can assist with making dual-qualifying US-UK donations which are eligible for tax relief in both jurisdictions.

读米铁矿石 US & 英国慈善捐款的税务提示.

• Savings and investments – both the US and the UK have punitive tax rules for certain investments; the Passive Foreign Investment Company (“PFIC”) rules in the US and Offshore Income Gain (“OIG”) regime in the UK. It would be prudent to check whether these rules apply to you when making investment decisions, otherwise you might have an unexpected tax liability when you receive distributions or sell the investments.

如欲了解更多有关美国PFIC制度的信息，请访问 被动外国投资公司(PFIC).

• Tax-efficient investments – it is possible to make UK tax-efficient investments through the Enterprise Investment Scheme (“EIS”), Seed Enterprise Investment Scheme (“SEIS”) and Venture Capital Trust (“VCT”). The Chancellor confirmed today that the limits on these schemes will not be changed.

一如既往地, consideration should be given to the US tax impact and reporting obligations that might arise as a result of investing in these schemes. Making UK tax-efficient investments is likely to only reduce your UK tax liability and not your US liability, but this might create the opportunity to utilize otherwise unused Foreign Tax Credits on your US return.

如果您想讨论您在美国和英国的税务状况, 包括今天宣布的变化可能会对你的情况产生怎样的影响, 请 澳门官方老葡京.