Jamie Younger, Chairman of Scottish Land & Estates Taxation group and Partner of Saffery Champness, comments on today's Budget:
“The doubling of the Annual Investment Allowance (AIA) to £500,000 from its current level is to be welcomed. However, this relief is short lived as it then returns to £25,000 from 1 January 2016. The increase announced today effective from April 2014 will encourage investment in plant and machinery, and farm businesses should look at what equipment they wish to replace and plan accordingly over the next 21 months. However, such moves come with caveats – does the business have sufficient funds available to invest, will that investment turn profit into deficit, and if so will this loss be able to be rolled backwards or profits rolled forward? There are a number of permutations that will suit different businesses.
“In the renewables sector, the blocking of projects that are in receipt of Renewable Heat Incentive (RHI) or Renewables Obligations Certificates (ROCs) from the Enterprise Investment Scheme is a disappointment and will cause setback to the plans and viability of a number of ventures already on the drawing board.
“New proposals on pensions are interesting and should allow far more flexibility at retirement age, particularly the removal of the requirement to purchase an annuity. Many will also be relieved that they can continue to take a quarter of their pension pot as a tax-free lump sum payment.
“The law of unintended consequences will strike for those in the rural sector with their home or country house owned by a ‘non-natural person’. This measure implemented in 2013 was designed to impact on those placing high value city properties into corporate structures. However in the rural sector such structures have legitimately been used to hold estates and farms. Annual Tax on Enveloped Dwellings (ATED) is the annual charge on a fixed scale applied to properties valued at more than £2 million but that threshold has now dropped to £1 million from April next year and £500,000 from April 2016 bringing a lot more property into the net. The ATED rate for a £1 million house would be £7000 per annum, with £3500 for a property valued at £500,000.
“There was an exemption previously for houses occupied by working farmers and for country houses regularly open to the public where certain conditions are met, and it is hoped that these will be continued.
“Houses worth £500,000 or more bought through a ‘corporate envelope’ will also be liable to 15 per cent stamp duty going forward.”