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.
Following the Government’s consultation process after the Autumn 2024 Budget announcement, further details, including the draft legislation, have now been published regarding the upcoming reforms to inheritance tax (IHT) reliefs for business and agricultural property.
The Autumn 2024 Budget sent shockwaves through the business and farming communities with the unexpected announcement that Business Relief and Agricultural Relief from inheritance tax (IHT) will be drastically curtailed from April 2026.
Following the Autumn Budget on 30 October the Government have announced a huge restriction to the availability of the UK Inheritance Tax (“IHT”) Reliefs - Business Property Relief (“BPR”) and Agricultural Property Relief (“APR”).
The latest budget contained significant changes for the taxation of trusts and their settlors. The impact comes from the changes to the way in which non-UK domiciled individuals are taxed.
Following years of speculation and Government announcements the draft legislation has now been issued that details the significant changes to the taxation of non-UK domiciled individuals and their trusts, which will take effect from 6 April 2025.
The UK Chancellor's Autumn Budget on 30 October 2024 has ushered in a new era of tax reform under the Labour Government. This budget, a watershed moment, introduces sweeping changes that will impact UK resident, both domiciled and non-domiciled, businesses, property ownership, and trust structures.
For trustees and settlors, the upcoming changes to the UK tax regime pose significant challenges, particularly for those managing settlor-interested trusts. The impending reforms, combined with an intensified focus from HMRC on tax investigations, create a complex environment where strategic planning is more critical than ever.
For those who may be affected, the recent changes to the UK tax regime for resident non-domiciled individuals (RNDs) are significant. The announcements in the March Spring Budget and the new Labour Government’s proposals have created a pressing need for immediate and strategic planning.
