Tax

On 26 November 2025, Chancellor Rachel Reeves delivered her Autumn Budget, following an intense period of speculation. Although personal tax measures took centre stage, key business tax announcements included the introduction of UK stamp duty reserve tax relief for UK-listed companies and an extension of the Enterprise Management Incentive share option scheme.

Below is a summary of the key tax announcements relevant to our clients. Please contact a member of the Weil London Tax team if you would like to discuss anything in further detail.

Business taxes

UK Listing Relief (Stamp Duty Reserve Tax (SDRT)):

A three-year exemption from SDRT for agreements to transfer shares in newly listed companies on UK regulated markets has been announced. Currently, when investors buy shares listed on the London Stock Exchange, they pay SDRT at 0.5%. This has been perceived to have a negative impact on the attractiveness of London as a listing venue and a major “con” in the related feasibility analysis for companies that have a choice of potential trading locations. The exemption will apply where the shares are newly listed on or after 27 November 2025.

Capital allowances:

From 1 April 2026, the main rate writing-down allowance for plant and machinery will be reduced from 18% to 14%. Additionally, a new 40% first-year allowance will apply to main rate expenditure incurred on or after 1 January 2026.

Oil & Gas measures:

Following a consultation launched in March 2025, the Government has confirmed details of a new and permanent windfall tax mechanism, the “Oil and Gas Price Mechanism” which will replace the existing Energy Profits Levy (EPL) when the EPL ends in March 2030 (or earlier than 2030 under the “Energy Security Investment Mechanism”, if prices drop below a certain level). The chosen mechanism for the new tax will be revenue-based (rather than profit based) with a proposed rate of 35% (the current EPL rate is 38%). The proposed trigger for the new tax to apply is $90/barrel (oil) and 90p/therm (gas). The thresholds will be adjusted annually in line with inflation for subsequent years.

Corporation tax rate:

As anticipated (and consistent with the “Corporate Tax Roadmap” published in Autumn 2024), the headline rate of corporation tax will remain at 25%.

Share schemes & venture capital schemes

EMI expansion:

The following amendments to the Enterprise Management Incentive (EMI) share option scheme will be introduced from 6 April 2026:

• the cap on the gross assets of the company has been quadrupled from £30 million to £120 million;
• the cap on the number of employees has been doubled from 250 to 500; and
• the cap on the aggregate of value of shares under option (measured at grant across all option holders) has been doubled from £3 million to £6 million.

Additionally, the maximum holding period, including in respect of existing EMI contracts, will be increased to 15 years and the EMI notification requirement will be removed. These changes will be legislated in the Finance Bills 2025-26 and 2026-27, respectively.

Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCTs):

From 6 April 2026, the maximum annual and lifetime investment amounts on which income tax relief can be claimed for both the EIS and VCTs will increase to £10 million and £24 million, respectively. The cap on a company’s gross assets will also be lifted to £30 million before share issue and £35 million after.

Income tax and capital gains tax (CGT)

Extension of freeze to Income Tax thresholds:

Current income tax and employer’s (secondary) National Insurance contributions thresholds will be frozen until 2031, a three-year extension of the freeze which is already in place until 2028.

Carried interest:

The government (re)confirmed today that, as was first announced by the Chancellor at Autumn Budget 2024, from 6 April 2026 the government will introduce a revised tax regime for carried interest which sits wholly within the Income Tax framework. Under the revised regime, the amount of carried interest subject to tax will be adjusted by a multiplier of 72.5% where qualifying conditions are met, delivering an effective tax rate of c. 34%. In addition, the government will implement the three statutory limitations on the territorial scope of the revised regime which were covered in the government’s policy update published in June 2025.

Dividend income:

From 6 April 2026, there will be a 2% increase to the basic and higher rates of tax on dividends, from 8.75% to 10.75%, and from 33.75% to 35.75%, respectively. The increase to the higher rate will also impact the corporation tax charge on loans to participators (i.e., the tax charge on certain loans made by a close company to its shareholders), which mirrors that rate.

Savings income:

From 6 April 2026, there will be a 2% increase to the basic, higher and additional rates of tax on savings, from 20% to 22%, 40% to 42% and 45% to 47%, respectively.

Property income:

From 6 April 2027, the government will introduce separate tax rates for property income across England, Wales and Northern Ireland. The property basic rate will be 22%, the higher rate will be 42% and the additional rate will be 47%.  

Property taxes

High Value Council Tax Surcharge (HVCTS):

From April 2028, the government will introduce a HVCTS on owners of residential properties in England valued at £2 million or more, based on updated valuations and charged in addition to existing council tax. The HVCTS will start at £2,500 per annum, and rise to £7,500 for properties valued above £5 million. The government will consult on the charge prior to implementation.

Pensions

Salary sacrifice for pensions:

From 6 April 2029, the government will cap National Insurance contributions (NICs) relief on pension salary sacrifice at £2,000 per employee per tax year; any amounts above £2,000 will attract employer and employee NICs in the usual way. The measure will be legislated for in due course.

Compliance and anti-avoidance

CGT anti-avoidance for share exchanges and reorganisations:

The government has announced that it will modernise anti-avoidance provisions that apply to the “rollover relief” provisions for share exchanges and reorganisations, with effect from 26 November 2025. While the focus of the current anti-avoidance provision looks at the overall reorganisation, the proposed revisions seek to target cases where, as part of a commercial exchange or company reconstruction, additional arrangements are put in place with a tax avoidance purpose.

Tax adviser registration:

Following a consultation which opened in July 2025, the government will require tax advisers to register with HMRC from May 2026. Legislation will be included in Finance Bill 2025-26.

Closing the tax gap:

The government announced a number of measures targeted at tackling anti-avoidance and increasing tax compliance, including enhancing HMRC’s powers and sanctions against tax adviser facilitated non-compliance, tackling promoters of marketed tax avoidance and anti-avoidance measures for certain arrangements where there is a non-derecognition liability (involving securitisation vehicles).

Consultations

The government has announced that further details regarding the “Advance Tax Certainty Service” for major investment projects will be legislated for in Finance Bill 2025-26 and launched in July 2026. The government has also announced 2026 consultations on, amongst other things, the reporting of transactions between close companies and their shareholders to HMRC, a new recklessness offence for fraudulently avoiding direct taxes and reform of UK law in relation to transfer pricing, permanent establishments and the Diverted Profits Tax.

Following an April 2025 consultation on modernising stamp taxes, the government has confirmed it will introduce powers in the Finance Bill 2025-26 to enable testing of the new digital service for the “Securities Transfer Charge”, a single tax on securities which is anticipated to replace the current framework of both Stamp Duty and Stamp Duty Reserve Tax.

Unaffected by today’s Budget

Also noteworthy are proposals which had been the subject of speculation, but were not ultimately included as follows:

Income tax & National Insurance contributions (NICs):

Rates of income tax will be maintained at 20% (basic rate), 40% (higher rate) and 45% (additional rate); rates of NICs also remain unchanged.

VAT:

No changes have been announced to the existing rates of VAT, or to the VAT registration threshold.

LLPs:

No changes have been announced regarding the taxation of LLPs or LLP members.

Banking taxes:

The government is not introducing any new banking levies or surcharges.