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.
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.
*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.
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