Key provisions. Budget Statement 26 November 2025

The Chancellor’s latest Budget arrived after an unusually turbulent build-up. In the hours leading to the speech, numerous supposed “leaks” circulated—many of which ultimately proved inaccurate. This chaotic pre-Budget period left advisers and taxpayers attempting to interpret potential policy shifts that never materialised. One silver lining: several of the most concerning proposals did not go ahead. In particular:

• No restrictions will be placed on lifetime gifting for inheritance tax (IHT) planning.
• Partners in LLPs avoided the predicted National Insurance (NI) hike.
• Pensions, aside from a tightening of salary sacrifice rules, emerged largely unscathed.
• ISA limits have been adjusted only lightly, rather than overhauled.
• The property tax system avoided an anticipated full-scale redesign.

The Government’s stated ambition is to stimulate economic growth and re-establish the UK as an attractive jurisdiction for investment and business development. While some reforms support that vision—notably enhancements to EMI and EIS—others are more challenging for business owners and high-net-worth individuals. Dividend tax rises, changes to salary sacrifice rules, and the withdrawal of the CGT exemption on Employee Ownership Trust (EOT) sales will increase tax burdens for many.

We also note new annual charges for owners of £2m+ homes, additional obligations for non-residents, and a new IHT framework affecting offshore agricultural ownership—changes which are unlikely to persuade internationally mobile clients to return.

The detailed technical commentary below sets out the key provisions from Budget.

Contents

1. Personal Tax Rates
2. Salary Sacrifice Restrictions
3. New “Mansion Tax” – High Value Council Tax Surcharge
4. Inheritance Tax (IHT) Changes
5. Capital Gains Tax
6. Non-Resident Measures
7. Impact on Entrepreneurs and UK Businesses
8. Employee Share Schemes
9. EIS & VCT Overhauls
10. Capital Allowances
11. Corporation Tax
12. Charity Tax Changes
13. Loan Scheme Settlement Opportunity
14. Compliance & Enforcement
15. Additional Measures

1. Personal Tax Rates

Although major income tax rate increases were widely forecast, the Chancellor instead opted to raise revenue through two mechanisms:

Frozen thresholds

Personal tax allowances and bands will remain frozen until April 2031, extending the existing freeze by three additional years.

Tax increases on investment and property income

Income Type	Effective From	Basic Rate	Higher Rate	Additional Rate
Dividends	Apr 2026	10.75%	35.75%	39.35%
Currently	—	8.75%	33.75%	39.35%
Savings Income	Apr 2027	22%	42%	47%
Currently	—	20%	40%	45%
Property Income	Apr 2027	22%	42%	47%
Currently	—	20%	40%	45%

These property rates apply to England, Wales, and Northern Ireland, but not Scotland.

Dividend and savings income tax rises apply UK-wide.

2. Salary Sacrifice and Pension Contributions

Employers have traditionally been able to support pension saving in two main ways, but only salary sacrifice has offered National Insurance (NIC) savings for both sides. The government now plans to remove that advantage in the name of aligning the two methods—though the chosen approach will ultimately increase overall NIC revenues.

Salary sacrifice works by allowing an employee to exchange part of their contractual pay for an equivalent employer pension contribution. Because this contribution is made before income tax and NICs are calculated, both the employee and employer currently benefit from NIC relief.

From April 2029, income tax relief on these contributions will remain unchanged, but the NIC position will shift. Only the first £2,000 of salary sacrificed each year will continue to attract NIC savings. Any contributions above that cap will be subject to NICs in the same way as standard employee pension contributions.

For a higher-rate taxpayer, this effectively introduces a 2% NIC charge on the portion of sacrificed salary exceeding £2,000. Employers will also incur 15% employer NICs on the same amount—a cost that many currently reinvest into employees’ pensions, but which they may need to reconsider once the new rules take effect.

3. High Value Council Tax Surcharge (“Mansion Tax”)

The government has confirmed plans to introduce a new annual levy—the High Value Council Tax Surcharge (HVCTS)—for owners of residential properties worth more than £2 million. The Valuation Office Agency will carry out valuation exercises to determine which properties fall within scope, with the charge scheduled to apply from April 2028.

Properties captured by the regime will be allocated to value bands, each attracting a fixed annual charge:

Property Value	Annual Charge
£2.0m – £2.5m	£2,500
£2.5m – £3.5m	£3,500
£3.5m – £5.0m	£5,000
£5.0m+	£7,500

From 2029–30, these amounts will rise annually in line with CPI.

A full consultation is expected in early 2026 and will explore the scope of the surcharge in more detail, including potential reliefs and exemptions and how the rules should apply to more complex ownership arrangements. One point that remains uncertain is the interaction with the existing ATED regime. Early indications evoke comparisons with the introduction of ATED, where both thresholds and charges became increasingly expansive over time, so further developments will be closely watched.

4. Inheritance Tax (IHT)

Budget 2025 has not delivered the large-scale overhaul to IHT seen in the previous year. Instead, a number of targeted adjustments have been introduced which refine, rather than reshape, the existing framework.

Pensions: Unused Funds and Death Benefits

Unused pension funds and lump-sum death benefits will in future fall within the scope of IHT, even where the pension scheme trustees have discretion over how the benefits are distributed. The long-standing exemptions for payments to spouses, civil partners and registered charities will continue.

Death-in-service payments made from registered pension schemes—whether the scheme operates on a discretionary or non-discretionary basis—will remain outside the IHT regime.

To improve compliance and information flow, a new process will allow personal representatives and pension scheme administrators to exchange data relating to IHT and, where applicable, income tax on pension distributions.

Personal representatives will also gain the power to instruct pension administrators to retain up to 50% of a beneficiary’s entitlement for as long as 15 months, ensuring sufficient funds are held back to settle any IHT due. Beneficiaries will share joint liability for IHT on pension funds identified during the administration of the estate and will carry sole liability where additional pension entitlements come to light after HMRC has issued clearance.

Agricultural Property Relief (APR) and Business Property Relief (BPR)

Despite continued pressure from the agricultural sector, the family farm tax has not been withdrawn. However, the government has introduced a long-requested enhancement to the APR/BPR framework. Any unused portion of the £1 million relief cap will become transferable between spouses or civil partners. Importantly, where the first death occurred before 6 April 2026, the full allowance will still pass to the survivor.

IHT Treatment of UK Agricultural Property Held Offshore

Rules originally introduced in 2017 to bring offshore corporate ownership of UK residential property into the IHT net are now being extended to companies holding UK agricultural land. As a result, shares in a non-UK entity deriving most of their value from UK agricultural property will be treated as UK-situs assets.

This change primarily affects:

• Individuals who are not long-term UK residents but hold such shares, and
• Trustees where the settlor is not a long-term UK resident.

These shares will now be included in the individual’s estate on death or within the trust’s 10-year charge regime. APR may mitigate the liability—up to 100% on the first £1 million of value and 50% on the amount above that threshold. Broadly:

• Individuals could face an effective 20% IHT charge on value above £1 million on death.
• Trustees could see roughly 3% due at each 10-year anniversary on the excess, with the first charge reduced proportionally to reflect the commencement date of the new rules.

Capping Trust Charges for Certain Non-Dom Structures

In an effort to moderate the impact of the forthcoming residence-based IHT regime, the government has announced that some trusts established by individuals who previously held non-UK domicile status will have their 10-year charges capped at £5 million per event. This will apply retrospectively from 6 April 2025.

The cap is limited to trusts that held excluded property on 30 October 2024, meaning only very large structures—those worth broadly £83 million or more—will benefit. While helpful to some long-standing non-dom families, the measure is unlikely to reverse the broader trend of relocation that has accelerated since the earlier IHT reforms.

Settlors Becoming Non-Long-Term Residents

A planning route used by certain trusts—retaining UK-situs assets at the point a settlor transitions to non-long-term resident status—has now been closed. Going forward, trusts in this position will generally be encouraged to dispose of UK-situs assets promptly, as holding them will no longer provide protection from exit-type charges under the revised regime.

5. Capital Gains Tax

Share-for-Share Exchanges

Although not highlighted in the Chancellor’s speech, one of the more significant technical changes appears tucked away in the supporting Budget papers: an amendment to the long-standing rules governing share-for-share CGT relief.

Share-for-share relief prevents a capital gain from arising when a shareholder exchanges shares in one company for shares in another, provided certain conditions are met. Instead of treating the exchange as a disposal, the rules allow the new shares to inherit the base cost and acquisition history of the original shares. This avoids a dry tax charge on transactions that often generate no immediate liquidity, such as corporate reorganisations, mergers, demergers, or the creation of new holding structures.

Historically, the relief has been subject to an anti-avoidance condition requiring that the transaction be undertaken for genuine commercial reasons and not form part of a scheme where one of the main purposes is the avoidance of CGT or corporation tax. The government now intends to tighten this test. The revised approach will move away from assessing the purpose of the overall transaction and will instead focus on whether any element of the arrangements has been inserted with a main purpose of securing a tax benefit that would not otherwise be available.

In practice, this means that even where the principal transaction is commercially driven, auxiliary steps bolted on to obtain a tax advantage may disqualify the parties from relief. As a result, obtaining HMRC clearance—already common practice—will become even more important for transactions involving reorganisations or share exchanges.

Applications for clearance submitted on or before 26 November 2025 will continue to be assessed under the current legislation, provided the new shares or debentures are issued within 60 days of today’s announcement or, if later, within 60 days of receiving HMRC’s response.

6. Changes for Non-Residents

Temporary Non-Residence (TNR) and Post-Departure Trade Profits

The government is revising the temporary non-residence rules by removing the concept of “post-departure trade profits”—profits treated as arising after an individual leaves the UK. Under the current rules, distributions or dividends paid out of such profits are not subject to a TNR tax charge.

For individuals who resume UK residence on or after 6 April 2026, this exemption will no longer apply. Any distributions or dividends received from a UK close company during a period of temporary non-residence will once again be reportable to HMRC where they fall within scope of the TNR regime, as was the case before the now-repealed provision was introduced. To prevent double taxation, credit will be available for foreign taxes paid on those amounts while the individual was temporarily non-resident.

Withdrawal of the Notional Dividend Tax Credit for Non-Residents

To create consistency between UK-resident and non-UK-resident taxpayers, the longstanding notional tax credit previously attached to UK dividends received by non-residents is being abolished. Non-resident individuals will therefore no longer benefit from a deemed credit when calculating tax liabilities in their home jurisdiction.

Voluntary National Insurance Contributions for Periods Spent Overseas

Individuals who work or live abroad can make voluntary National Insurance contributions (NICs) to bolster their UK state pension record. At present, those working overseas can often pay at the lower Class 2 rate (£3.50 per week), rather than the higher Class 3 rate (£17.75 per week).

From April 2026, this preferential Class 2 rate will be withdrawn. All non-residents—whether working or not—will only be eligible to make Class 3 voluntary contributions for periods abroad.

New applicants from April 2026 will additionally need to meet one of the following conditions:

• They must have lived in the UK for 10 consecutive years, or
• They must have paid at least 10 years’ worth of UK NICs.

These changes will not affect voluntary contributions made in respect of time spent abroad before 6 April 2026. The government has confirmed that transitional arrangements will be introduced, with details to follow.

7. Impact on Entrepreneurs and UK Business Owners

Impacts for Entrepreneurs and Businesses

Although the Chancellor opened her Budget statement by reaffirming the ambition to make the UK “the best place in the world to start up, scale up and stay,” the package of measures announced—together with those trailed in the Spring Statement—paint a more mixed picture. Many of today’s announcements appear at odds with the stated commitment to attracting and retaining entrepreneurial talent and high-growth businesses.

Alongside the Budget, the Treasury released a separate policy paper outlining its intention to ensure the UK remains a competitive environment by improving access to capital, strengthening the talent pipeline and streamlining regulation. Whether these aspirations translate into changes sufficient to keep founders domiciled in the UK remains uncertain. The key developments include:

Positive Measures

• New UK Listing Relief from Stamp Duty Reserve Tax
  Introduced to reduce friction for companies seeking to access public markets.
• Expanded eligibility for the Enterprise Management Incentive (EMI) scheme
  Allowing larger companies to issue share options to help attract and retain key employees.
• Broader eligibility for EIS and VCT investment
  The rules will now accommodate somewhat more mature companies, widening access to growth capital. However, the downside is that tax relief for individual VCT investors will be trimmed back.
• Advanced Tax Certainty for Major Projects
  The government plans to offer clearer, earlier tax certainty to support large investments.
• Call for Evidence on Supporting UK Entrepreneurship
  A consultation has been launched to gather views on how existing incentives are working and what further measures might help founders and investors.

Less Favourable Measures

• Restriction of CGT relief on disposals to Employee Ownership Trusts
  A significant reduction in the generosity of this previously valuable exit route.
• Higher dividend tax rates from April 2026
  Particularly damaging for owner-managed businesses, where directors commonly take income via a blend of salary and dividends.
• Changes to salary sacrifice pension arrangements
  From 2029, contributions above £2,000 will trigger employer and employee NICs, raising staffing costs for businesses offering these schemes and reducing net benefits for employees.
• Reduction in main rate capital allowances
  The writing-down allowance will fall from 18% to 14% from April 2026, slowing tax relief for investment in plant and machinery.

 

Other Measures Raising Questions

The government is also exploring whether to introduce statutory caps on non-compete clauses in employment contracts, with the aim of encouraging spin-outs and new venture creation. While the intention is to stimulate innovation, larger employers may see this as weakening their ability to protect key intellectual property and talent—potentially undermining the very ecosystem the government wants to foster. Whether new start-ups will flourish under these conditions is equally debatable.

8. Employee Share Schemes

Employee Share Schemes

Enterprise Management Incentives (EMI)

The EMI regime remains one of the most attractive ways for growing companies to reward and retain key employees. It allows qualifying businesses to grant share options that give employees a stake in the company’s future value, with any gain on eventual sale typically subject to capital gains tax (CGT) rather than income tax—a significant advantage given that higher CGT stands at 24%, compared with income tax rates of 40% or 45%.

Currently, only companies below specific size thresholds can use EMI. From April 2026, these limits will increase for new options granted after that date:

Description	Current Threshold	New Threshold from April 2026
Maximum number of employees	250	500
Gross assets limit	£30 million	£120 million
Maximum value of EMI options in issue	£3 million	£6 million
Maximum option term (applies to all existing and future options unless already exercised or expired)	10 years	15 years

These expanded thresholds mean that companies will be able to continue using EMI as they scale, ensuring they can offer competitive, tax-efficient incentives to attract and retain the talent needed for long-term growth.

EMI options remain subject to strict compliance rules, including accurate valuations and timely reporting. Companies are strongly encouraged to agree valuations with HMRC before granting options.

Share Incentive Plans (SIP) and Save As You Earn (SAYE)

Unlike EMI, which can be targeted at selected employees, SIP and SAYE arrangements must be made available to the entire workforce. Both provide tax-advantaged routes for employees to acquire shares and are commonly adopted by larger companies or those that do not meet EMI qualification criteria.

A government call for evidence was launched in 2023 to assess how well these schemes operate. The summary of responses—published today—indicates broad support for both SIP and SAYE, though respondents identified several areas where improvements could be made. While the government has acknowledged this feedback and expressed willingness to explore enhancements, no specific policy changes have been announced at this stage.

9. Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCT)

Expanded Limits for Companies

To encourage entrepreneurial activity and retain growing businesses in the UK, the Chancellor has announced increases to the annual, lifetime, and gross asset thresholds for companies raising investment through EIS and VCT schemes.

Both schemes provide valuable tax incentives to investors in higher-risk or early-stage companies. Currently, investors can claim 30% income tax relief on qualifying investments. From 6 April 2026, however, the income tax relief rate for VCT investors will decrease to 20%, reflecting a recalibration of the scheme.

The updated limits for EIS and VCT schemes are as follows:

Limit Description	Current Limits	New Limits from 6 April 2026
Maximum company gross assets	£15 million before share issue / £16 million after	£30 million before share issue / £35 million after
Annual investment a company can raise	£5 million (£10 million for knowledge-intensive companies)	£10 million (£20 million for knowledge-intensive companies)
Lifetime investment a company can raise	£12 million (£20 million for knowledge-intensive companies)	£24 million (£40 million for knowledge-intensive companies)

These changes are designed to support early-stage companies seeking external investment, providing greater flexibility and funding capacity to help them grow.

Companies planning to raise finance through EIS should consider applying for advance assurance from HMRC. This ensures that the shares issued will qualify for the associated income tax relief, and further HMRC submissions are required after share issuance to allow investors to claim their relief.

10. Capital Allowances

Updates to Capital Allowances

Writing-Down Allowances (WDA)

The main rate of writing-down allowances (WDA) will be reduced from 18% to 14%. While businesses can still claim relief for qualifying capital expenditure, the deduction will be spread over a longer period due to the slower rate of relief. This change takes effect from 1 April 2026 for incorporated companies and 6 April 2026 for unincorporated businesses.

New 40% First Year Allowance (FYA)

A new 40% First Year Allowance will be introduced for expenditure eligible at the main rate. This allowance is designed to cover expenditure not already qualifying for other allowances, such as leased assets, providing additional flexibility. The 40% FYA will be available for both incorporated and unincorporated businesses on qualifying expenditure incurred from 1 January 2026 onwards. This allowance is in addition to the existing Annual Investment Allowance regime.

First Year Allowances for Zero-Emission Cars and Chargepoints

The current 100% FYA for new zero-emission cars will be extended by one year. Similarly, the 100% FYA for electric vehicle chargepoints will also be extended. These allowances will remain available until 31 March 2027 for companies and 5 April 2027 for unincorporated businesses, supporting investment in environmentally friendly vehicles and infrastructure.

11. Corporation Tax

Corporation Tax

Corporate Interest Restriction (CIR)

The Corporate Interest Restriction limits the extent to which companies can reduce taxable profits by claiming relief on excessive UK interest and other financing costs. The rules apply to companies subject to UK corporation tax whose net interest and financing costs exceed £2 million per year.

Simplifications are being introduced to the CIR regime, including the removal of the time limit for appointing a reporting company and the requirement to notify HMRC of the appointment. These changes will apply to CIR returns for periods ending on or after 31 March 2026.

Advance Tax Certainty for Major Projects

A new service will launch in July 2026, offering businesses a binding view on how tax rules will apply to significant investment projects in the UK before substantial expenditure occurs. While HMRC’s clearance will bind the government on the interpretation of tax law, it will not prevent changes due to case law or legislation.

• Clearances will be valid for five years initially, with a pragmatic approach to extensions for longer projects.
• Applications can be made by any entity, including non-UK residents, and jointly by multiple investors on the same project.
• Projects must involve new investment in a UK project, not routine expenditure.
• Taxes covered include Corporation Tax, VAT, Stamp Taxes, PAYE, and CIS, with a target turnaround of 90 days.
• Initially, the service is for projects with in-scope UK expenditure over £1 billion, excluding financing costs or acquisitions of shares, but its scope may expand after the first year.

 

Pillar 2 Multinational Top-Up Tax (MTT) and Domestic Top-Up Tax (DTT)

The MTT and DTT ensure multinational groups with global revenue exceeding €750 million pay a minimum 15% corporate tax rate. Technical amendments to the calculation rules will take effect for accounting periods beginning on or after 31 December 2025.

Transfer Pricing, Permanent Establishments, and Diverted Profits Tax Reforms

The government will introduce primary legislation in the Finance Bill 2025-26, effective for periods starting 1 January 2026, covering:

Transfer Pricing (TP)

• UK-UK transactions within a corporate group may now be exempt from TP rules where no tax loss arises.
• Simplification of intangible transactions and adjustments to participation rules are also included.

Permanent Establishment (PE)

• UK PE rules will be aligned with internationally accepted definitions.
• Existing UK double taxation treaties remain unaffected.

Diverted Profits Tax (DPT)

• DPT will be withdrawn as a separate tax and incorporated into corporation tax while retaining the key features of the DPT regime.

International Controlled Transactions Schedule (ICTS)

• Multinationals within TP rules must annually file an ICTS if they have cross-border related-party transactions and are:
  • A UK resident within TP rules,
  • A UK resident with a foreign PE, or
  • A foreign entity with a UK PE.
• Filing will be annual, with the effective date expected for periods beginning on or after 1 January 2027.

12. Charity Taxation

Changes to Charity Tax Rules

VAT Relief on Business Donations to Charities

Currently, businesses donating goods to charities are only able to apply zero-rated VAT treatment in limited circumstances.

From 1 April 2026, a new exception will apply to the deemed supply rules for business donations of goods to charities. Eligible donated goods intended for distribution to people in need or for use in charitable services will no longer require businesses to account for VAT on these items in their VAT returns.

Other Charity Compliance Changes

Four significant updates to charity tax rules will also take effect for transactions on or after 1 April 2026. Draft legislation was previously published in July 2025.

1. Tainted Donations to Charities
The Tainted Charity Donation rules ensure tax relief does not apply when donations are made in exchange for financial advantage. From April 2026, HMRC will consider both the financial outcome and the donor’s motivation when determining whether a donation is tainted.

2. Approved Charitable Investments
Currently, only one of the twelve approved charitable investment types is required to be made for the benefit of the charity rather than for tax avoidance purposes. This will change so that all twelve investment types must meet this condition, ensuring consistent treatment.

3. Attributable Income
Gifts left to charity in a will must be used for the charity’s charitable purposes, or the gift may become subject to a tax charge. Professional bodies have raised concerns that this could discourage future bequests, particularly because the legislation does not currently define the timeframe for funds to be applied. This is likely to have significant implications for endowment funds.

4. Sanctions for Non-Compliance
Further measures are expected from April 2026 to strengthen HMRC’s powers over charities that fail to meet tax obligations or filing requirements. These powers could include restrictions on claiming tax reliefs such as Gift Aid, although further details are yet to be published.

13. Loan Schemes Settlement Opportunity

Loan Schemes Settlement Opportunity

Loan schemes were historically used to provide employees with benefits under the assumption that the loans would not be subject to income tax. Over time, multiple versions of these schemes emerged, resulting in significant disputes and concerns that HMRC had been attempting to apply rules retrospectively. The government now appears intent on resolving the matter promptly, rather than allowing prolonged litigation.

Following a review conducted by Ray McCann, the government has accepted the report’s recommendations, which aim to encourage settlements and bring this long-running issue to a close. In its response, the government acknowledges missteps by HMRC, which may be seen as a near-apology to affected taxpayers.

Key recommendations include:

• Introduction of a new settlement opportunity with suspended penalties and interest, and lower tax rates.
• An additional reduction of £5,000 from the settlement liability, effectively removing those with the lowest liabilities from any tax charge.
• Measures to restrict promoters of tax avoidance schemes from providing services such as tax return preparation, aiming to reduce the risk of similar issues in the future.

While the full details of the scheme are yet to be published, it is intended to provide taxpayers with certainty and closure after years of uncertainty. HMRC has not yet implemented the proposals, and current guidance only pertains to the existing settlement opportunity.

14. Compliance & Enforcement

Compliance and Enforcement

Capital Gains Tax – Non-Resident CGT
New legislation will clarify that, for the purposes of the non-resident Capital Gains Tax (CGT) charge, determining whether a company is “property rich” must be done at the level of the individual cell in a Protected Cell Company (PCC), rather than assessing the company as a whole.

Promoters of Tax Schemes
The government continues to focus on stopping promoters of tax avoidance schemes from profiting from arrangements that lack genuine effectiveness. HMRC is expected to receive expanded powers to intervene where schemes have no realistic prospect of success. Additional civil and criminal penalties will also be introduced. Despite longstanding attempts to curb such activities, these promoters persist, highlighting the importance of robust enforcement and adequate resources for HMRC to protect taxpayers from exploitative schemes.

Facilitating Non-Compliance
Certain professional firms have been found to enable or even encourage non-compliance, prompting the government to grant HMRC powers to obtain information from advisers suspected of deliberately facilitating tax non-compliance. New penalties will apply for failing to comply with these information requests.

Personal Tax – Offshore Anti-Avoidance
Budget 2024 highlighted the need to update the current offshore anti-avoidance rules, which are complex and sometimes contradictory. While today’s announcement did not include detailed policy changes, the government has committed to continued engagement with stakeholders and representative bodies, with updates and wider consultations planned. Further details will be provided once available.

15. Additional Measures

Sundry Updates

Low-Value Import Relief Removal
Currently, individual consignments valued under £136 benefit from a full customs duty relief. This relief will be withdrawn from March 2029, meaning all imports, regardless of value, will be subject to standard customs duties.

Cryptoasset Reporting Framework
In response to the growing use of cryptoassets, the UK government is collaborating with the OECD and other jurisdictions to facilitate information sharing. UK-based cryptoasset service providers will be required to collect and report data on their UK-resident customers.

Stamp Duty – UK Listing Relief
A temporary exemption from the 0.5% Stamp Duty Reserve Tax (SDRT) will apply for three years following a company’s listing on a UK regulated market. This exemption applies to all post-listing transfers of securities and aims to encourage secondary market trading. The relief will apply to companies newly listed on or after 27 November 2025.

Modernisation of Stamp Duties
The government is planning to consolidate Stamp Duty and SDRT into a single tax on the transfer of securities. A new digital reporting service is being developed to support off-market transfers. No implementation date has been confirmed, but it is likely to follow the pattern of the Making Tax Digital programme and may take several years before launch.

Electronic Invoicing (E-Invoicing)
From 2029, VAT invoices in the UK must be generated and transmitted via e-invoicing. E-invoicing involves the digital exchange of invoice data between the financial systems of buyers and sellers, even when systems differ. A roadmap outlining the phased introduction of e-invoicing will be published in 2026.

Corporation Tax – Late Filing Penalties
Penalties for late corporation tax returns will increase as follows, effective for returns due on or after 1 April 2026:

Situation	Current Penalty	New Penalty
Return late	£100	£200
More than 3 months late	Additional £100	Additional £200
3 successive late returns	£500	£1,000
3 successive late returns over 3 months	£1,000	£2,000

Winter Fuel Payments Charge
From the 2025/26 tax year, pensioners with total annual income exceeding £35,000 who receive Winter Fuel Payments will be subject to a charge equal to the full payment amount. HMRC will collect this automatically via PAYE codes unless the pensioner files a Self-Assessment return. Pensioners anticipating income above the threshold may opt out of receiving the payment.