You will have seen our note on Thursday looking at the two key CGT changes from the Budget, being a reduction in the BADR limit to £500k (from 6 April 2027) and the proposed introduction of a new “Founders’ Relief” from that date also. As we said, the conditions for that new relief look very restrictive and it is hoped that the consultation process (which ends on 30 November 2026) will result in...
Read moreAlongside the headline measures, this week’s Budget contained some significant news for business owners: a generous (but tightly targeted) new capital gains tax relief for founders of high-growth companies, and a less welcome halving of the lifetime limit for business asset disposal relief (“BADR”). HM Treasury has also published a technical consultation on the detailed design of the new relief,...
Read moreHMRC recently published a wide-ranging consultation, "Modernising the taxation of distributions and repayments of capital from companies", available here. The consultation includes proposals on a number of areas that are of interest to those advising private companies and their shareholders, including around share buy-backs, distributions from non-UK companies, extending the close company loans...
Read moreIn 2027, stamp duty and stamp duty reserve tax on share transfers will be replaced by a single digitally administered tax, to be known as securities transfer tax (STT). The draft legislation was published in July for consultation and representations can be made until 7 September. Fundamentally, for private company share transfers we will still be looking at a 0.5% charge and with very similar...
Read moreTax Bite – The new share exchange / reconstruction anti-avoidance provisions – more detailed HMRC guidance In our Budget 2025 Tax Bite, we flagged the unexpected changes to the anti-avoidance rules for share for share / share for loan note exchanges and company reconstructions. Six months on (and notwithstanding the fact that the new rules came into effect on Budget day, subject to some limited...
Read moreTax Bite – Loan Notes in Share Sales In this Tax Bite, we briefly summarise the use of loan notes from an individual seller’s tax perspective in share sale transactions. Deferral of CGT (or not, if the seller prefers) Normally, if part of the consideration for a share sale is satisfied in loan notes issued by the buyer entity, the seller does not trigger capital gains tax on the gain attributable...
Read moreThis Tax Bite is a reminder of the welcome increases in EIS limits announced in the Autumn Budget, which took effect from 6 April 2026. From this date, the investment limits for EIS have roughly doubled, bringing larger and more mature businesses into the scheme and allowing qualifying companies to raise significantly more tax-advantaged capital. The EIS annual and lifetime investment limits and...
Read moreThose who advise regularly on M&A transactions will no doubt have come across situations where the shareholders of a company want to share sale proceeds otherwise than fully pro rata to their respective shareholdings and the rights attaching to the relevant share classes in the company’s Articles of Association. Typically, the intended “advantaged” shareholder will be an employee or director...
Read moreChanges to the thresholds contained in the EMI rules announced in the November 2025 Budget will come into effect shortly, on 6 April 2026. The effect of these changes is that some larger companies will be within (or back within) the EMI rules, meaning that they will be able to grant EMI options to their employees (either for the first time or once again). Generally these changes are to be...
Read moreThis week’s Budget was indeed a smorgasbord with a few surprise ingredients. Here are a few of the highlights:-You will be relieved to know that the trailed punitive tax measure to charge additional taxes on members of LLPs did not feature – a big relief for many and it shows that fierce lobbying by interested parties can sometimes do the trick. The tax relief on sales to EOTs will now be...
Read moreA recent case of a barrister being referred to the Bar Standards Board after being found to have relied on an AI tool without verifying the outputs, and citing non-existent cases in his pleadings, highlights the dangers practitioners can face when relying on AI. This will sound obvious to legal practitioners and tax advisers, but what about when members of the public or clients use AI? What...
Read moreAs has been widely reported on, the UK is introducing a new trading mechanism for private company shares – PISCES (Private Intermittent Securities and Capital Exchange System). Draft legislation has recently been published for Finance Bill 2026 which confirms that, for EMI and CSOP share options that are granted prior to Finance Bill 2026 receiving Royal Assent, it will be acceptable to make...
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