FT : Rachel Reeves to soften UK non-dom tax reforms

Rachel Reeves to soften UK non-dom tax reforms
Chancellor tells Davos crowd that government had been ‘listening to concerns’

Rachel Reeves is set to make a change to the UK government’s crackdown on non-domiciled residents in an attempt to allay concerns about the tax reforms announced in October’s Budget. 

The chancellor told a fringe event at the World Economic Forum in Davos on Thursday that the government would soon table an amendment to its own finance bill. 

This will enable easier access to the temporary repatriation facility, which allows non-doms to bring foreign income and gains made before April 2025 into the UK and pay tax at a discounted rate of 12 per cent in the 2025-26 and 2026-27 tax years, rising to 15 per cent in 2027-28 — compared with the maximum income tax rate of 45 per cent. 

The change planned by the government would make it easier for certain funds to access the facility’s flat tax rates. But while the measure may be useful for some non-doms, it is unlikely to move the dial for many.

Reeves said at The Wall Street Journal’s Davos event on Thursday the government had been “listening to the concerns that have been raised by the non-dom community”, responding to a question about an increase in the net number of millionaires leaving the UK in recent months.

Jonathan Reynolds, business secretary, later confirmed the planned change, first reported by The Times, telling journalists in the Swiss mountain resort: “There is a tweak to the finance bill . . . when you’re changing a tax regime, people will want to know, and there’ll be some uncertainty there, so we’ve got to get that message out.”

Reeves announced in the Budget that she was abolishing the non-dom regime, which allows UK tax residents whose permanent home or “domicile” is overseas to avoid paying British tax on their foreign income or capital gains for 15 years. 

It will be replaced from April 6 2025 by a four-year residence-based scheme to offer “internationally competitive arrangements for people coming to the UK on a temporary basis”.

Downing Street said the change would not lead to a fall in the tax take from replacing the non-dom regime, and the Treasury still expects to raise £33.8bn over the next five years from the reforms.  

Non-doms have been most concerned about changes to inheritance tax on existing trusts, with the issue often mentioned as the key factor driving them to leave the country.

Rachel de Souza, tax partner at RSM UK, said that while an increase to the temporary repatriation facility was “a good move” it is “woefully inadequate” to prevent wealthy non-doms from leaving the UK.

“The way to stem this exodus would be to maintain the exemption from IHT to offshore trusts but also reverse the proposed changes to agricultural and business property relief which impacts the farmers and entrepreneurs.”

Robert Brodrick, a partner at law firm Payne Hicks Beach, said: “It’s reassuring to see that they are at last responding to the concerns of the many people who are affected by this, but I don’t think this is going to be enough to stem the tide . . . It’s helpful but the inheritance tax exposure is the biggest nail in the coffin.”

The chancellor also said on Thursday she wanted to allay concerns from countries including India that the rules changes would not affect double-taxation agreements: “That’s not the case: we are not going to be changing those double-taxation conventions.”

A Treasury figure said: “We’re always interested in hearing ideas for making our tax regime more attractive to talented entrepreneurs and business leaders from around the world to help create jobs and wealth in the UK.”

>>> US Research Calls I

Research Calls I
  • Upgrades:
    • Aptiv (APTV) upgraded to Neutral from Underweight at Piper Sandler; tgt raised to $65
    • Boot Barn Holdings (BOOT) upgraded to Overweight from Sector Weight at KeyBanc Capital Markets; tgt $190
    • Chewy (CHWY) upgraded to Buy from Hold at Argus
    • First Community (FCCO) upgraded to Strong Buy from Outperform at Raymond James; tgt raised to $30
    • Logitech Int'l SA (LOGI) upgraded to Equal-Weight from Underweight at Morgan Stanley; tgt $92
    • Netflix (NFLX) upgraded to Neutral from Sell at Arete
    • Netflix (NFLX) upgraded to Outperform from Peer Perform at Wolfe Research; tgt $1100
    • Option Care Health (OPCH) upgraded to Buy from Hold at Jefferies; tgt raised to $35
    • Revolve Group (RVLV) upgraded to Overweight from Sector Weight at KeyBanc Capital Markets; tgt $37
    • Trupanion (TRUP) upgraded to Overweight from Neutral at Piper Sandler; tgt $57
  • Downgrades:
    • Acushnet (GOLF) downgraded to Underweight from Neutral at JP Morgan; tgt lowered to $64
    • American Homes 4 Rent (AMH) downgraded to Sector Perform from Sector Outperform at Scotiabank; tgt $38
    • Boston Beer Co (SAM) downgraded to Neutral from Overweight at Piper Sandler; tgt lowered to $275
    • Casella Waste (CWST) downgraded to Hold from Buy at Jefferies; tgt lowered to $113
    • Dentsply Sirona (XRAY) downgraded to Hold from Buy at Jefferies; tgt lowered to $20
    • Electronic Arts (EA) downgraded to Neutral from Buy at BofA Securities; tgt lowered to $130
    • Electronic Arts (EA) downgraded to Market Perform from Outperform at BMO Capital Markets; tgt lowered to $145
    • Electronic Arts (EA) downgraded to Mkt Perform from Outperform at Raymond James
    • FirstEnergy (FE) downgraded to Peer Perform from Outperform at Wolfe Research
    • Liberty Global (LBTYA) downgraded to Mkt Perform from Outperform at Bernstein; tgt lowered to $12.40
    • Parsons (PSN) downgraded to Mkt Perform from Outperform at William Blair
    • Veeva Systems (VEEV) downgraded to Sell from Buy at Goldman; tgt lowered to $200
  • Others:
    • Aflac (AFL) initiated with a Market Perform at BMO Capital Markets; tgt $111
    • Blue Owl Capital (OWL) resumed with a Buy at Citigroup; tgt $30
    • Bright Minds Biosciences (DRUG) initiated with an Overweight at Piper Sandler; tgt $93
    • CNO Financial (CNO) initiated with a Market Perform at BMO Capital Markets; tgt $38
    • Corebridge Financial (CRBG) initiated with an Outperform at BMO Capital Markets; tgt $43
    • Electrovaya (ELVA) initiated with a Strong Buy at Raymond James; tgt $4.50
    • Equitable Holdings (EQH) initiated with an Outperform at BMO Capital Markets; tgt $70
    • Exact Sciences (EXAS) initiated with an Overweight at Barclays; tgt $70
    • Exodus Movement (EXOD) initiated with a Buy at H.C. Wainwright; tgt $50
    • Globe Life (GL) initiated with a Market Perform at BMO Capital Markets; tgt $114
    • Guardant Health (GH) initiated with an Overweight at Barclays; tgt $60
    • Guidewire Software (GWRE) initiated with a Buy at Goldman; tgt $210
    • Inneventure (INV) initiated with a Buy at ROTH MKM; tgt $16
    • MetLife (MET) initiated with a Market Perform at BMO Capital Markets; tgt $97
    • Mobile Infrastructure Corporation (BEEP) initiated with a Buy at B. Riley Securities; tgt $5
    • Mobile Infrastructure Corporation (BEEP) initiated with an Overweight at Piper Sandler; tgt $5
    • Natera (NTRA) initiated with an Overweight at Barclays; tgt $200
    • Primerica (PRI) initiated with a Market Perform at BMO Capital Markets; tgt $311
    • Principal Fincl (PFG) initiated with a Market Perform at BMO Capital Markets; tgt $93
    • Prudential (PRU) initiated with an Underperform at BMO Capital Markets; tgt $101
    • Unum Group (UNM) initiated with an Outperform at BMO Capital Markets; tgt $91

>>> US Gapping down

Gapping down
In reaction to earnings/guidance
:
  • EA -16.1%, PLXS -9.1%, AAL -7.6%, RLI -6.1%, NBBK -4.3%, CATY -3.6%, CVBF -3.3%, AUB -2.8%, HXL -2.1%, AA -1.2%
Other news:
  • EVTL -31.8% (priced underwritten public offering of $90 mln units at $6.00 per unit; expected to close on or about January 24) ASTS -16.5% (prices offering of $400.0 million 4.25% convertible senior notes due 2032)
  • LAKE -15.7% (stock offering)
  • BTG -5.4% ($350 mln convertible notes offering)
  • GLSI -3.9% (announces additions of Harvard and Johns Hopkins to Flamingo-01)
  • IRON -3% (prices upside offering of common stock and pre-funded warrants)
  • KMPR -2.7% (estimates minimal California wildfire losses)
  • QUBT -2.4% (stock offering by selling shareholders)
  • TTWO -2.3% (in sympathy with EA guidance)
  • OLP -2.3% (purchases two industrial properties for $49 mln)
  • PSN -1.6% (enters into R&D agreement with US Army)
  • UAL -1.5% (in sympathy with AAL)
  • WBD -1.4% (CNN planning to lay off hundreds of employees this week, according to CNBC)
  • SSL -1.2% (reports H1 production and sales update)
  • DAL -1.1% (in sympathy with AAL)

>>> US Gapping up

Gapping up
In reaction to earnings/guidance
:
  • NFBK +10.3%, NBHC +10.2%, TAL +9.3%, WSBC +7.1%, KNX +6.6%, PPBI +6.4%, GE +5.4%, ELV +4.7%, BANR +4%, SLG +3.4%, ALK +2.6%, BANC +2.4%, FBP +1.9%, VLY +1.7%, AMAL +1.1%, DFS +1%, IPAR +1%, WNS +1%,
Other news:
  • BETR +15.9% (authorizes new $25 mln share repurchase program)
  • GWRE +4.6% (to join S&P MidCap 400)
  • ARDX +4% (Director disclosed the purchase of 199,000 shares worth approx. $993K)
  • NFE +2% (gas supply agreement with Energiza)
  • ARWR +1.9% (to move to S&P SmallCap 600 from S&P MidCap 400)
  • BLBD +1.4% (names new CEO)

>>> US Early premarket gappers

Early premarket gappers
  • Gapping up:
    • BETR +16.4%, TAL +10.5%, NFBK +10.3%, NBHC +10.2%, KNX +6.6%, PPBI +6.4%, GE +6.4%, ELV +6%, GWRE +4.4%, ARDX +4.2%, BANR +4%, ALK +3.9%, NFE +3.7%, BANC +3.7%, WNS +3%, SLG +2.4%, ARWR +1.9%, DFS +1.6%, BLBD +1.4%, MMYT +1.4%, IPAR +1%, CACI +0.8%
  • Gapping down:
    • EVTL -30.6%, LAKE -15.8%, EA -14.9%, ASTS -13.5%, PLXS -6.6%, OLP -6.5%, CVBF -6.3%, RLI -6.2%, BTG -5.4%, CATY -4.8%, HXL -4.3%, NBBK -4.3%, GLSI -3.9%, TOWN -3.9%, QUBT -3.7%, KMPR -2.7%, WSBC -2.3%, MKC -2.3%, IRON -2.2%, ZLAB -2%, TTWO -1.7%, AA -1.7%, SSL -1.6%, PSN -1.5%, WBD -1.4%, ALTR -1%, CON -0.9%, RBCAA -0.9%, TRNS -0.8%

>>> What to look at today - 23rd of December 2024

Stocks in Asia rose after Chinese officials reassured investors of the government’s commitment to supporting the market and boosting share prices. China’s benchmark CSI 300 Index advanced as much as 1.8%, hitting its highest level in almost three weeks before paring some of its gains. The Hang Seng China Enterprises Index, tracks mainland stocks listed in Hong Kong, erased an intraday gain of 1.6% as some investors viewed Beijing’s measures as a temporary stimulus. The MSCI Asia Pacific index climbed for the fourth session, set for the longest winning run in nearly a month.  The gains in Chinese benchmarks came after a briefing hosted by China’s securities regulator, which said local insurers and mutual funds should add to their equity holdings. The move helped improve the mood among Chinese investors, after a tariff threat from US President Donald Trump earlier this week weighed on sentiment. The briefing was held by China Securities Regulatory Commission Chairman Wu Qing, Deputy Finance Minister Liao Min and central bank official Zou Lan, a sign that boosting China’s equity market is seen by Beijing as a government-wide effort rather than simply a problem for the securities regulator. Yields on 10 year Treasuries were little changed at around 4.60%. The dollar consolidated with major currencies in a tight range. Asian markets are still digesting the impact of Trump’s first few days in office, which have sent mixed signals to investors. Trump has reiterated a tariff threat against China but has largely spared the world’s second-largest economy from a feared escalation of the trade war. The S&P 500 came close to an all-time high on Wednesday, after a three-day rally that has been fueled in part by Trump’s moves to boost spending on artificial intelligence. Earlier this week, the president unveiled a joint venture with SoftBank Group Corp., OpenAI, and Oracle Corp. that could spend billions of AI infrastructure.
SoftBank’s shares rallied in the wake of the news, and continued to move higher on Thursday. They are now up around 17% since the start of the year. But other Asian tech stocks didn’t fare as well. Shares of Korean chipmaker SK Hynix Inc. tumbled as much as 4.7% after its record quarterly profit and modest capex plans failed to impress investors. South Korea’s economy continued to sputter in the last quarter, with gross domestic product growth missing estimates. The nation plans to issue up to 20 trillion won ($13.9 billion) in special bonds from Thursday, dusting off a tool last used 21 years ago to help stabilize its currency. Hyundai Motor reported operating profit for the fourth quarter that missed the average analyst estimate. Elsewhere in Asia, Philippine’s JG Summit Holdings shares slumped as much as 8.5%, the biggest one-day fall since March 2023, on concerns that the firm may be removed from MSCI indexes.  The Bank of Japan is on track to raise interest rates to the highest level since 2008 on Friday, as the central bank makes steady progress toward normalization just as the Federal Reserve and the European Central Bank start to mull a pause in their easing cycles.  In commodities, oil edged lower after an industry report pointed to the first gain in US crude stockpiles since mid-November, as the market watched for further pledges on global trade from President Trump. Gold held near the highest level since October. US After Hours EA -10.6%, PLXS -9.5%, CATY -7.1% lower on earnings/guidance; KNX +6%, WSBC +4%, ALK +3.1% higher on earnings; GWRE +4.4% to join S&P MidCap 400.

Nikkei +0.92% Hang Seng -0.35% CSI +0.30% Shanghai +0.67% Shenzen +0.00%

Eur$ 1.0415 CNH 7.2825 CNY 7.2794 JPY 156.49 GBP 1.2316 CHF 0.9063 RUB 99.2088 TRY 35.6623 WTI$ 75.09 -0.46% Gold 2,751.50 -0.07% BTC 102,585 -1.40% ETH 3,212 -1.4%

S&P -0.08% Nasdaq -0.18% EuroStoxx -0.19% FTSE -0.31% Dax -0.02% SMI

Macro :
- Huge New LA Fire Prompts Evacuations After Weeks of Blazes (1)
- Israel-Hezbollah Truce Set to Be Extended Beyond Next Week
- US Power-Grid Operator MISO Issues Cold Weather Alerts
- Musk, Altman Spar Over $100 Billion AI Effort Hyped by Trump
- SoftBank, OpenAI Eye $19 Billion for US AI, Information Says (1)

Keep an eye on :
- AA US : Alcoa 4Q Adjusted Ebitda Beats Estimates -- +5%
- ALTER EGO IPO : Alter Ego Media IPO Price at €4 Per Share, Raising €57m
- AAPL US : Samsung to Beat Apple to Ultrathin Phone With Galaxy S25 Edge
- ASML NA : Trump to Push Hard on ASML Export Controls, Dutch Premier Says
- ASTS US : AST SpaceMobile Offers Convertibles at Up to 4.25% Coupon: Terms -- -9%
- CBK GY : Commerzbank Calls UniCredit’s Approach ‘Hostile’
- EDP PL : EDP Renovaveis Says 2024 Electricity Generation Rises 6%
- ESSITYA SS : Essity CEO Magnus Groth to Step Down During 2025
- EUROB GA : Eurobank Offering by Fairfax Prices at €2.33/Share, Terms Show
- GALE SW : Galenica FY Sales Meets Estimates
- HER IM : Italy Utility Hera Signs Deal to Increase Stake in Aimag to 41%
- HUBN SW : Huber+Suhner FY Revenue Beats Estimates
- ITALMACH IPO : Bain Said to Mull €1.5 Billion Sale of Chemicals Firm Italmatch
- LLOY LN : Lloyds Hires CIBC’s Merali for North America Corporate Banking
- NOHAL NO : Nordic Halibut Places Offering of 14.25m Shares at NOK20/Share
- NVDA US : Nvidia Partner SK Hynix’s Profit Fails to Impress AI Chip Bulls
- PLTR US : Palantir Gets Street-High Price Target From Wedbush on AI Growth
- PUM GY : Puma Drops on Weak Net Income, Margin Target Delay: Street Wrap
- 000660 KS : Nvidia Partner SK Hynix’s Profit Fails to Impress AI Chip Bulls
- 9984 JP : SoftBank, OpenAI Eye $19 Billion for US AI, Information Says (1)
- SPOT US : Spotify CEO’s Startup Neko Raises $260m For US Expansion: FT
- SWEDA SS : Swedbank 4Q Net Income Beats Estimates (1)
- TIT IM : Telecom Italia Agrees on Extension for €700m Sparkle Bid (1)
- TSLA US : Musk, Altman Spar Over $100 Billion AI Effort Hyped by Trump (2)
- TRYG DC : Tryg 4Q Pretax Profit Misses Estimates
- UBI FP : *ELECTRONIC ARTS SEES FY NET BOOKINGS $7B-$7.15B,SAW $7.5B-$7.8B
- VLA FP : Valneva Reports Positive Chikungunya Vaccine Phase 2 Results
- VLTSA FP : Voltalia Signs Maintenance Contract With Copel in Brazil
- VOLCARB SS : Volvo Car Says No Talks Yet Over New Swedish Battery Partner: SRand
- WPP LN : WPP plans US expansion having ‘looked at’ New York listing

>>> Europe : Brokers Upgrades & Downgrades - 23rd of January 2025

>>> Up
* Auto Trader Raised to Buy at Citi; PT 946 pence
* FirstGroup Raised to Buy at HSBC; PT 190 pence
* Fondia Raised to Buy at Inderes; PT 5.60 euros
* Kesko Raised to Accumulate at Inderes; PT 19.50 euros
* Logitech Raised to Equal-Weight at Morgan Stanley
* Netflix Raised to Outperform at Wolfe; PT $1,100
* Rotork Raised to Buy at Kepler Cheuvreux
* TotalEnergies Raised to Buy at Redburn; PT 73 euros
* Vicat Raised to Overweight at Barclays; PT 47 euros

>>> Down
* ASML Cut to Sell at Aletheia Capital; PT 500 euros
* ASML ADRs Cut to Sell at Aletheia Capital; PT $525
* Electronic Arts Cut to Market Perform at BMO; PT $145
* Evolution Cut to Sell at Deutsche Bank; PT 798 kronor
* Galapagos Cut to Underweight at Barclays; PT 22 euros
* Heidelberg Materials Cut to Equal-Weight at Barclays
* Inchcape Cut to Neutral at JPMorgan; PT 800 pence
* INVISIO AB Cut to Hold at SEB Equities; PT 345 kronor
* Ithaca Energy Cut to Neutral at Goldman; PT 160 pence
* Nemetschek Cut to Add at Baader Helvea; PT 120 euros
* Novartis Cut to Hold at Intron Health; PT 110 Swiss francs
* Proximus Cut to Neutral at Oddo BHF; PT 7 euros

>>> Initiation
* Ahold Delhaize Reinstated Neutral at Citi; PT 37 euros
* Alpha Group Internationa Rated New Buy at HSBC; PT 2,855 pence
* Norsk Hydro Re-Initiated Buy at Kepler Cheuvreux; PT 88 kroner

>>> Call
* Palantir Gets Street-High Price Target From Wedbush on AI Growth

FT : Daniel Ek’s Neko raises $260mn in push to be ‘Apple’ of healthcare

Daniel Ek’s Neko raises $260mn in push to be ‘Apple’ of healthcare
Spotify founder’s body-scanning start-up valued at $1.7bn in new funding round

Daniel Ek’s body-scanning start-up Neko Health has raised $260mn in new capital to fuel expansion of its clinics to the US, as the Spotify founder aims to build what he called the Apple of healthcare.

Ek co-founded Neko in Sweden alongside entrepreneur Hjalmar Nilsonne, its chief executive, in 2018, financing the venture for its first five years through his investment firm Prima Materia.

“I think we have a shot of changing the biggest industry on earth and accomplish a win-win-win where we reduce costs for society, we reduce suffering and we can create a fantastic business,” Ek told the Financial Times.

“The companies we compare ourselves with are the Apples or Teslas of the world, but we’re applying it to a very different domain, which is healthcare.”

The start-up’s funding round announced on Thursday values Neko at $1.7bn, according to people familiar with the terms. The investment will help it expand to more countries, including the US, when it receives the necessary regulatory approvals.

The deal is led by Lightspeed Venture Partners, a backer of Elon Musk’s xAI, Stripe and Epic Games, with other investors including Lakestar, Atomico, General Catalyst and OG Venture Partners.

Neko’s first clinics launched in Stockholm in 2023, when it also raised $65mn from outside investors. It expanded to London last year, offering hour-long health check-ups that include high-resolution skin scans, blood tests and a doctor’s consultation for £299.

“We are now at an inflection point where we have proven that we can build an amazing experience and we’ve proven we can get it to work . . . in one of the most difficult markets, the UK,” Ek said.

Critics of preventive care companies say that they can generate “false positives” or alarm patients, which public healthcare services such as the NHS then have to pay to deal with.

Neko’s fee includes follow-up appointments to verify any potential problems that its initial scan detects.

Other preventive health scanning start-ups include Ezra and Prenuvo, while OpenAI chief Sam Altman has invested about $180mn into Retro Biosciences, which aims to extend human lifespan by a decade.

Unlike most other preventive health services, Neko has engineered much of its own diagnostic stack, which includes high-resolution imaging, cardiovascular assessment and blood tests, producing millions of data points.

Nilsonne said about three-quarters of the data generated by each scan came from its own medical devices, while other off-the-shelf equipment was also integrated into a system that was designed to run as many tests in as short a time as possible.

More than 90 per cent of customers opt to allow Neko to apply AI to the roughly 15 gigabytes of data produced in each scan, offering patients personalised insights and recommendations, while also helping the company to improve its algorithms.

“We are building up a much more comprehensive [health] data set than anyone else is doing,” Nilsonne said.

Ek compares Neko’s “vertical integration” to the way in which Apple and Tesla design many of their own components and tightly control their supply chains, from chips and batteries to software and services.

Like those companies, Neko can continuously improve not only its sensors and software, but the overall customer experience, which the founders see as key to attracting customers who would not otherwise want to pay for preventive care.

Neko has completed 10,000 scans to date and more than 100,000 people have signed up for its waiting list. The private company did not disclose any financial information, but Nilsonne said the group did not lose money on each scan thanks to the degree of automation involved, pointing to “very solid unit economics”.

Lightspeed partner Bejul Somaia, who is joining Neko’s board, said its level of repeat bookings and waiting list gave him a “high level of confidence” that the business model was working.

“The investment would have been much tougher for us — though probably I would still have done it because of the team — than if you were taking a total leap of faith on whether people actually want this,” he said.

Neko’s check-ups happen in a spa-like environment, bathed in pastel hues and soundtracked by soothing music, with a mixture of staff and voice-overs explaining each step of the process.

The results are presented immediately after the scan by a doctor, visualised on a 3D avatar of the patient’s body and benchmarking their health metrics against those of other Neko customers and clinical studies.

“We’re not selling a product, we’re selling an experience. This experience will keep on improving,” Ek said. “Where we are today, I like to believe that we will look back at this as the first iPod.”