*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.
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.
Non-domiciled tax status, a political hot potato if ever there was one, has been around in one form or another since 1799. Since then, the regime has undergone a plethora of changes...
