A small but important amendment to Incorporation Relief was included in the Autumn 2025 Budget, and many businesses may not yet be aware of its implications.
Following Ray McCann’s review of the Loan Charge and the recommendations set out within it, HMRC has now started to contact taxpayers who fall within scope of the new settlement terms.
The outbreak of conflict involving the US, Israel and Iran on 28 February 2026, and the wider instability that has followed across the region, has prompted many individuals and families living in the UAE to reassess their position.
The conflict began with coordinated US-Israeli strikes on Iran on 28 February, and that it has since widened, affecting the Gulf more broadly and disrupting normal assumptions around regional stability.
For many internationally mobile families, the question is no longer simply whether the UAE has been an effective base. It is whether, in light of recent events, they should remain where they are, relocate elsewhere, or return to the UK — and what UK tax consequences may follow from that next step, even if the relocation is only temporary.
That is not a question to answer casually.
In November HMRC announced further details of its Strengthened Reward Scheme, following similar initiatives overseas. The scheme offers significant financial rewards for individuals who report serious tax avoidance or evasion.
What was trailed, what was dropped, what was announced and what has happened since?
With the benefit of hindsight, the Autumn Budget 2025 now reads less like a single fiscal event and more like a prolonged period of policy signalling, retrenchment and quiet recalibration. In the months leading up to the Budget, a wide range of radical measures were trailed, many of which were ultimately abandoned before Budget Day itself. Others emerged only after the event, including material changes announced just before Christmas that fundamentally altered the inheritance tax landscape for farm and business owners.
The inheritance tax treatment of pension wealth has undergone a fundamental and far-reaching change.
Following the latest Budget, there has been a collective sense of relief that some of the more extreme measures trailed in advance — wealth taxes, exit charges and similar proposals — did not ultimately make their way into legislation. However, that relief should not be mistaken for a return to the status quo. While confidence was undoubtedly damaged by the pre-Budget whispering campaign and selective leaks, the reality is that one of the most significant changes to long-established estate planning assumptions has already been set in motion: pensions are no longer sacrosanct from inheritance tax.
Following the budget last week, HMRC published both Ray McCann’s review of the loan charge, and the government’s response, confirming that there will be new settlement terms offered to individuals caught by the loan charge in the new year.
Today’s Budget confirmed what many suspected after the OBR’s unprecedented early leak: a statement built around higher taxation of income from assets, tighter anti-avoidance measures and welfare reforms, with comparatively modest measures aimed at stimulating long-term growth.
*We have now seen a number of settlement proposals from HMRC in relation to Employee Benefit Trusts, “EBTs”, where the deduction for Corporation Tax has been disallowed.*
*This is in line with the decision made in the case of Wired Orthodontics Ltd & Ors v HMRC \[2023] UKFTT 17 (TC), which concerned a PAYE assessment on funds routed through an EBT.*
An IPO or trade sale is a transformational event in the life of any business owner. It represents the culmination of years of effort, and the beginning of an equally important new phase for you, your family, and your company.
Alongside the commercial and operational challenges, ensuring your tax affairs are structured correctly can make a significant difference to the outcome. The right planning can protect value, reduce risk, and provide flexibility for your future. The wrong approach — or leaving things too late — can limit options and create unexpected costs.
And today, timing matters more than ever. With major UK tax reforms scheduled from April 2026, the window for certain planning opportunities is closing fast.
