Autumn UK Budget 2025:
Insights and analysis

The Chancellor's speech noted that the Government will stick to its commitments, set out in the 2024 Corporate Tax Roadmap, to cap the headline rate of Corporation Tax at 25% and to maintain full expensing for this Parliament. However, a number of changes that will impact businesses were announced as set out below.

Capital allowances

From April 2026, the Government will decrease the rate of writing down allowances on the main pool of plant and machinery by 4% to 14% per year. In addition, from 1 January 2026 a new first-year allowance (FYA) of 40% for main rate expenditure will be introduced, with the aim of preserving incentives to invest. The Government's view is that the new FYA will be beneficial primarily where the £1 million Annual Investment Allowance or existing FYAs (such as full expensing) are unavailable or not preferred. Unlike full expensing, the new allowance will be available for unincorporated businesses and assets used for leasing, although cars, second-hand assets and assets for leasing overseas will not be eligible. Overall though these measures are expected to be tax raising, with the OBR forecasting that they will raise an additional £1.5 billion by 2029/30.

Capital gains tax anti-avoidance: share exchanges and reorganisations

The Government has announced changes to the capital gains avoidance rules applying to share exchanges and company reconstructions (ss127-139 Taxation of Chargeable Gains Act 1992 (TCGA)), alongside the publication of draft legislation.

The existing capital gains share reorganisation rules broadly apply where a company’s share capital is reorganised and are extended to where shares are issued to a person in exchange for shares in another company or its share capital is reconstructed. Under these rules, there is no immediate charge to Capital Gains Tax (CGT) or Corporation Tax on shareholders, but rather any gain is rolled over into the new shares.

The reorganisation provisions are subject to anti-avoidance rules (at ss137(1) and 139(5) (and s103K(1)) TCGA and a clearance procedure at s138 TCGA) such that the above rollover treatment may be denied if the exchange forms part of a scheme or arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to CGT or Corporation Tax.

Measures announced at Budget revise the anti-avoidance provisions so that, broadly, the "scheme or arrangements" in question may be taken to be a selected part or parts of an overall transaction, rather than the entirety of that transaction. Consequently, the revised anti-avoidance rule may be more likely to apply in circumstances where one component of an arrangement could be said to have a main tax avoidance purpose but the overall transaction of which it forms part has a commercial basis. Although not expressly set out in HMRC's announcement, it appears that this measure is a response to HMRC's defeat in the Court of Appeal in the 2023 case of Delinian Ltd (formerly Euromoney Institutional Investor plc) v HMRC [2023] EWCA Civ 1281.

In addition to the above change, the existing restriction on the anti-avoidance provision, which means that the provision does not apply if the taxpayer, either alone or with connected persons, holds 5% or less of, or of any class of, the issued share capital or debentures in the company being taken over, is omitted from the revised draft legislation, thereby widening the scope of application of the revised anti-avoidance measure.

UK Listing Relief

In an effort to ensure the competitiveness of UK capital markets, with effect from 27 November 2025, relief will be provided from the 0.5% Stamp Duty Reserve Tax (SDRT) charge on agreements to transfer securities of a company whose shares are newly listed on a UK regulated market. The relief will apply to the company’s securities for a three-year period from the listing of the company’s shares. Once in the post-listing period the exemption will apply to all of the company's securities (not just shares), as well as to depositary interests over a company’s securities where the depositary interests are newly listed. The exemption will not apply to the 1.5% SDRT charge (in respect of transfers to depositary receipt systems or unelected clearance services), or where the transfer forms part of a merger or takeover where there is a change of control. In addition, the exemption will not apply on the listing of a Special Purpose Acquisition Company (SPAC) (though it can apply when the SPAC subsequently takes control of an unlisted company).

Advance tax certainty service for major projects

The Government consulted earlier this year on the design of a new HMRC service to provide major investment projects with advance certainty as to how tax will apply to the project. The Government has now responded to this consultation, confirming that the Advance Tax Certainty Service will launch in July 2026 and providing further details of its operation.

In terms of eligibility for the service, although it was initially proposed that only entities that are or will be liable to UK Corporation Tax would be eligible to use it, it will now be open to any entity investing in a "major project", including both UK and non-UK resident entities. Additionally, joint applications may be made for a single clearance where applicants are investing in a joint project, including entities that may be under different ownership (such as members of a consortium or joint venture).

A major project is defined as a new investment planned on a specified project in the UK, which is not a continuation of ordinary spending. Applicants must incur in scope expenditure over the lifetime of the project of at least £1 billion in order to be able to utilise the service, and it is therefore expected to be available only in respect of significant projects. This threshold, along with other aspects of the service, will be reviewed following the service's first year of operation.

As to the scope of the service, clearances may cover issues relating to Corporation Tax, VAT, stamp taxes, PAYE and the Construction Industry Scheme only – a welcome wider range of taxes than envisaged in the original consultation document. HMRC notes that purpose tests, including the loan relationships unallowable purpose test, will be excluded from the advance clearance, although HMRC may be willing to offer a view that there is a low risk of a future compliance intervention in relation to a purpose test.

Any clearance issued will represent a binding decision on HMRC's view of the law, as applied to fully disclosed facts, subject to changes in case law and/or legislation. The clearance will not, however, bind the applicant and the Government will only be bound to an aspect of the clearance where the applicant makes its tax return on the basis set out in the clearance.

Details of the process involved in an application are provided in the response document. A fee will not be charged for the service. Further details of the service in the form of draft legislation and technical guidance will be published shortly.

Tax support for entrepreneurs

The Government states that it is "focussed on making the UK the most attractive place in the world for founders to start and scale their businesses to success". With this aim in mind, a Call for Evidence has been published seeking views on the effectiveness of existing tax incentives (including the Seed Enterprise Investment Scheme, the Enterprise Investment Scheme and Venture Capital Trusts), along with the wider tax system, for business founders and scaling firms. The Government is seeking to understand how the UK can better support these companies to start, scale and stay in the UK. Responses to the Call for Evidence will be considered by the Government when developing further potential reforms to tax in support of entrepreneurs.

Non-discretionary tax-advantaged share schemes

A consultation was published by the previous government in 2023 regarding the two available nondiscretionary tax-advantaged employee share schemes: Share Incentive Plans (SIP) and Save As You Earn (SAYE), both of which enable companies to incentivise and reward employees by offering a direct stake in a company and its potential success.

The Government has now published a summary of the consultation responses received. The response document does not include a commitment to any firm action on the part of the Government, but it is noted that the Government will consider the responses and make any future tax policy decisions in the usual way at fiscal events, and will additionally review HMRC's guidance on the schemes in order to make any necessary changes. Enterprise Management Incentives scheme,

Enterprise Investment Scheme and Venture Capital Trusts

The Government has announced an increase to the company eligibility limits for the Enterprise Management Incentives scheme (EMI) to allow scale-ups to join start-ups in offering tax-advantaged shares to employees. For eligible companies, the following changes to limits will apply to EMI contracts granted on or after 6 April 2026:

• Company options will be increased from £3 million to £6 million.
• Gross assets will be increased from £30 million to £120 million.
• The number of employees will be increased from 250 to 500.

In addition, the limit on the exercise period will be increased from 10 years to 15 years for EMI contracts granted on or after 6 April 2026 and also for existing EMI contracts which have not already expired or been exercised.

The Government is also increasing the Venture Capital Trust (VCT) and Enterprise Investment Scheme (EIS) limits to allow investors to follow-on as companies grow beyond the start-up phase, including increasing the gross assets requirement that a company must not exceed, from £15 million to £30 million immediately before the issue of the shares and securities, and from £16 million to £35 million immediately after the issue. With the stated aims of better balancing the amount of upfront tax relief offered by VCTs compared to the EIS, and incentivising funds to support high-growth companies, the Government is, however, reducing the upfront VCT Income Tax relief from 30% to 20%.

The reform of transfer pricing, permanent establishments and Diverted Profits Tax

Following policy and technical consultations, the Government has now confirmed that it will legislate in Finance Bill 2026 to reform the UK law in relation to transfer pricing, permanent establishments and Diverted Profits Tax. The legislation will aim to simplify the taxation of related party transactions, non-resident companies trading in the UK, and profits diverted from the UK, for chargeable periods beginning on or after 1 January 2026. A detailed summary of responses to the Government's latest technical consultation from April 2025 has now been published.

Incorporation relief claims

A new requirement will be introduced for taxpayers to actively claim incorporation relief for transfers of a business to a company on or after 6 April 2026. The claim will need to be made by the transferor providing details of the transaction, the tax computations and the type of business transferred in their Self Assessment return for the tax year in which the transfer takes place. The relief currently applies automatically.

Employee ownership trusts

The Government has announced a restriction on the amount of relief from CGT available on qualifying disposals of shares to the trustees of an Employee Ownership Trust. The current relief, available in respect of 100% of the gain, will be reduced so that, with effect from 26 November 2025, 50% of the gain will be treated as the disposer's chargeable gain for CGT purposes. The remaining 50% of the gain will not be chargeable at the time of disposal but will continue to be held over to come into charge on any future disposal of the shares by the trustees of the Employee Ownership Trust.

Cross-border VAT grouping

HMRC has published a Brief setting out its updated position on the UK VAT treatment of intra-entity services involving establishments located in an EU member state that are part of a UK VAT group.

Under HMRC's previous policy, most recently set out in Revenue and Customs Briefs 18 and 23 (2015), UK businesses were required to account for VAT under the reverse charge mechanism on certain intra-group services. With effect from 26 November 2025, HMRC has revised its interpretation of this aspect of existing UK VAT law such that the position set out in these Briefs is no longer effective. HMRC now considers that an overseas establishment of a business VAT grouped in the UK should be treated as part of that VAT group, even when located in an EU member state that does not operate 'whole entity' VAT grouping. This means that multiple businesses under shared control with a UK presence can be treated as a single entity for VAT purposes, regardless of the location of the overseas businesses.

HMRC acknowledges that some VAT groups may have accounted for VAT in line with the previous guidance and may now be eligible to submit an error correction notification to reclaim any overpaid VAT.

Freezing of allowances and thresholds

The Government has stuck to its 2024 election manifesto pledge not to raise the rates of Income Tax, National Insurance and VAT. However, it has secured increased future tax revenues by extending the existing freeze on allowances and thresholds. The following measures have been announced:

• Income Tax – The Income Tax Personal Allowance of £12,570, the higher rate threshold of £50,270 and the additional rate threshold of £125,140, currently frozen until 2028, will remain frozen for a further three years to April 2031.
• National Insurance contributions (NICs) – In relation to Class 1 and Class 4 NICs for employees and the self-employed, the following annual limits, currently frozen until 2028, will remain frozen until April 2031:
  • The Primary Threshold and the Lower Profits Limit (above which employees and the self-employed start paying Class 1 and Class 4 NICs respectively) of £12,570.
  • The Upper Earnings Limit and Upper Profits Limit (above which employees and the self-employed pay a lower rate of Class 1 and Class 4 NICs respectively) of £50,270.
  • The Secondary Threshold (above which employers start paying Class 1 Secondary NICs) of £96 per week. 
• Inheritance Tax – The Inheritance Tax nil-rate band of £325,000, the residence nil-rate band of £175,000 and the residence nil-rate band taper, starting at £2 million, all of which are currently frozen until April 2030, will remain frozen for a further year until April 2031. As previously announced, from April 2026 a new combined allowance of £1 million (transferable between spouses/civil partners) will apply to assets eligible for the 100% rate of agricultural property relief and business property relief (currently, qualifying agricultural and business property can attract 100% relief without any cap). This combined allowance will also be frozen at £1 million for a further year until April 2031.

Taxation of income from assets: property, savings and dividend income

Increases to the rates of tax payable on the receipt of income by individuals from property, dividends and savings have been announced. The Government's stated aim in making these changes is to more closely align the taxation of income from assets (which is not subject to NICs or any equivalent) with the taxation of income from employment and self-employment, thereby "addressing unfairness in how different forms of income are taxed". The following changes will be made: 

• Property income – Separate tax rates will be created for property income. From April 2027, the property basic rate will be 22%, the property higher rate will be 42%, and the property additional rate will be 47%. These rates will apply across England, Wales and Northern Ireland (the Government will engage with the devolved governments of Scotland and Wales to provide them with the ability to set property income rates in line with their current Income Tax powers). Consequent on these changes:
  • Relief for residential finance costs will be calculated at the property basic rate of 22%.
  • The Non-Resident Landlords Scheme (NRLS) rate of withholding tax will be the property basic rate of 22%.
  • The rate of withholding tax on property income distributions from real estate investment trusts (REITs) and property authorised investment funds (PAIFs) will be the property basic rate of 22%.
• Dividend income – From April 2026, tax on dividend income will increase by 2%, so that the ordinary rate (payable by basic rate taxpayers) will increase from 8.75% to 10.75% and the upper rate (payable by higher rate taxpayers) will increase from 33.75% to 35.75%. The additional rate will remain unchanged at 39.35%. The annual dividend allowance will remain at £500.
• Savings income – Tax on savings income will increase by 2% across all bands. The basic rate will rise from 20% to 22%, the higher rate from 40% to 42%, and the additional rate from 45% to 47% from April 2027.

Salary sacrifice for pension contributions

With the stated aim of curbing tax reliefs that disproportionately benefit the wealthy and high earners, the Government has announced that employer and employee Class 1 NICs will be charged on employee pension contributions above £2,000 per year made via salary sacrifice, with effect from April 2029. Contributions will remain exempt from Income Tax (subject to the usual limits).

Individual Savings Accounts (ISAs)

As part of the Government's wider strategy to develop a retail investment culture and improve investment education, from April 2027 the annual cash ISA limit will be set at £12,000, within the overall annual ISA limit of £20,000. Savers over the age of 65 will continue to be able to save up to £20,000 in a cash ISA each year.

High value council tax surcharge

As part of the Government's move to raise revenue from sources of wealth, a new High Value Council Tax Surcharge will be introduced. This will take the form of a charge on owners of residential property in England worth £2 million or more, to be implemented from April 2028. The charge will be based on updated valuations to identify properties above the threshold and will be payable in addition to existing Council Tax (the new charge will be collected by local authorities but this will be on behalf of central Government). The Surcharge will start at £2,500 per year, rising to £7,500 per year for properties valued above £5 million, and will be levied on property owners rather than occupiers.

Business rates

Call for Evidence and rates changes As part of its multi-year project to transform the business rates system, the Government has published a Call for Evidence exploring how moving to a marginal tax rate, where successive bands are taxed at increasing rates, may be beneficial for investment. Views are also sought on the overall role business rates play in investment, as well as the impact that the receipts and expenditure (R&E) methodology has on investment decisions.

More generally, whilst the Chancellor announced a targeted reduction for business rates on retail, hospitality and leisure properties with rateable values below £500,000, there was an increase in business rates for properties of £500,000 and above. Whilst the Chancellor in her speech linked the increase to warehouses and distribution centres for online retailers, in practice it is an across-the-board increase on properties above this valuation threshold.

Withholding taxes for non-residents

As noted under the heading 'Taxation of income from assets: property, savings and dividend income' above, separate tax rates will be created for property income, such that from April 2027, property income will be taxed at rates of 22%, 42% and 47%. Consequently, the Non-Resident Landlords Scheme (NRLS) rate of withholding tax will be the property basic rate of 22% and the rate of withholding tax on property income distributions from real estate investment trusts (REITs) and property authorised investment funds (PAIFs) will also be the property basic rate of 22%.

Oil and Gas Price Mechanism

As confirmed at Autumn Budget 2024, the existing Energy Profits Levy (EPL) will remain in place until 31 March 2030 at the latest but will end at an earlier date if the EPL’s price floor (the Energy Security Investment Mechanism) is triggered.

Once the EPL ends, the Government is committed to ensuring that there is a new mechanism in place to respond to future oil and gas price shocks. Consultation on this mechanism took place earlier this year and the Government has now published its response.

The Government has confirmed that a new permanent Oil and Gas Profits Mechanism (OGPM) will act as a new 'windfall tax' when oil and gas prices are unusually high. The OGPM will be revenue-based and will apply an additional tax rate of 35% above price thresholds of $90/barrel for oil and 90p/therm for gas. Legislation for the OGPM will be included in Finance Bill 2027.

This will come as a disappointment to those in the oil and gas industry who had been hoping for the EPL to be scrapped and not to be replaced, arguing that it has created a disincentive for investment in the North Sea.

Carbon Border Adjustment Mechanism

Following a number of policy and technical consultations, the Government has confirmed that a UK Carbon Border Adjustment Mechanism (CBAM) will be introduced. This will be a new tax which will ensure that highly traded, carbon intensive goods which are imported into the UK face a comparable carbon price to that paid by manufacturers producing the same goods in the UK (including under the UK Emissions Trading Scheme (ETS)).

The UK CBAM will apply from 1 January 2027 to goods from sectors including aluminium, cement, fertiliser, hydrogen, iron and steel. While noting that refineries play a role in energy security and the UK's industrial base, the Government will also consider whether to include refined products in the CBAM.

The Government has announced a number of measures in its continued effort to raise tax revenue by closing the tax gap – defined as the difference between the amount of tax that should, in theory, be paid and what is actually paid. In June 2025, HMRC announced that the tax gap for 2023/24 stood at £46.8 billion. Key measures announced are set out below.

Strengthened Reward Scheme

The Government will introduce, with immediate effect, the Strengthened Reward Scheme for informants providing information which allows HMRC to tackle high-value tax avoidance or evasion, implemented with immediate effect. For cases where tax over £1.5 million is recovered, HMRC will pay rewards of up to 30% of the additional tax collected.

Tackling promoters of marketed tax avoidance

Further measures to tackle promoters of marketed tax avoidance will be introduced, including the introduction of new powers to ban the promotion of avoidance arrangements that have no realistic prospect of success and a new power for HMRC to directly issue penalties under the Disclosure of Tax Avoidance Schemes (DOTAS) regime without the need to seek tribunal approval. The Government will publish a consultation on further measures to tackle promoters in early 2026.

Tackling tax adviser facilitated non-compliance

Enhanced HMRC powers and sanctions to tackle tax advisers who intentionally facilitate non-compliance will be introduced from April 2026. Measures will include changes allowing HMRC to request information from tax advisers where there is reasonable suspicion of sanctionable conduct and penalties for tax advisers who engage in sanctionable conduct, calculated based on the tax loss.

Mandatory tax adviser registration

Following an earlier consultation, HMRC has confirmed that tax advisers who interact with HMRC on behalf of clients will be required to register with HMRC and meet minimum standards before doing so, with effect from May 2026 (subject to a transitional period of at least three months). Guidance will be provided by HMRC in advance of implementation.

Non-resident capital gains

Various changes will be made to the capital gains rules that apply to disposals of UK land and property by non-UK resident persons (non-resident capital gains). Broadly, these measures will:

• amend the definition of a UK property rich entity to provide that in the case of protected cell companies (PCC) it is an individual PCC cell that is to be looked at for the purposes of the property richness and substantial indirect interest tests, rather than the PCC itself, with effect from 26 November 2025; and 
• formalise the existing Extra-Statutory Concession that applies to non-UK resident individuals who have invested in Collective Investment Vehicles and exempts them from the requirement to make a double taxation treaty claim by return, with effect from April 2026.

Behavioural penalties reform

The Government consulted in March 2025 on the potential reform of financial penalties applying when inaccuracies are found in returns and documents submitted to HMRC, and where taxpayers do not meet their obligations to notify HMRC of circumstances that affect their tax liability. In its response document, published with the Budget, HMRC notes there is a "strong case" for simplifying and strengthening such behavioural penalties. Consequently, HMRC will develop proposals to improve its existing penalty regime, rather than seeking to develop a new alternative regime, and will draft legislation accordingly. Proposals to be considered by HMRC include replacing financial penalties with warnings for first, careless inaccuracies, and strengthening sanctions for taxpayers who seek to evade tax including tougher penalties for deliberate behaviour.

Construction Industry Scheme

A new measure will be introduced to strengthen HMRC's powers to tackle fraud within the Construction Industry Scheme (CIS). From 6 April 2026, where it can be shown that a business knew or ought to have known that it entered into a transaction that was connected with the fraudulent evasion of tax, HMRC will be able to immediately remove Gross Payment Status (GPS), assess the business for the related tax loss and charge a penalty of 30%, which can apply to the business or its officers. In addition, those who have GPS removed immediately due to fraud or serious non-compliance will be prevented from reapplying for GPS for a period of five years.

Digital Services Tax

In compliance with a statutory requirement to do so, the Government has published a report on the UK's Digital Services Tax (DST). The DST is charged at a rate of 2% on the revenues of large businesses (generating more than £500 million in global digital services revenues and £25 million in UK digital services revenues in a relevant accounting period) that provide social media services, internet search engines or online marketplaces (excluding financial marketplaces and payment services providers).

The Government's intention remains that the DST is an interim measure, implemented in response to the challenges posed by the digitalisation of the economy to the international corporation tax system. The UK’s position remains that the DST will be abolished once an appropriate global solution that would address these challenges is in place (this was intended to be the OECD's 'Pillar One' project but there is now significant uncertainty regarding its future). In the meantime, there is likely to be continued pressure from the current US administration to remove the DST.

Tax treatment of gambling

Earlier this year, the Government consulted on proposals for a new single remote betting and gaming duty. In its response document, published with the Budget, the Government has confirmed that it will not proceed with this proposal, but will instead raise duties on online gambling, with a larger increase on gaming, as follows: 

• Remote Gaming Duty will increase from 21% to 40% from April 2026.
• A new remote betting rate of 25% will be introduced within General Betting Duty from April 2027. This new rate will not apply to bets placed via self-service betting terminals, spread betting or pool betting. Remote bets on horseracing will be excluded and remain taxed at 15%.

Electric Vehicle Excise Duty

The Government will introduce a new Electric Vehicle Excise Duty (eVED) from April 2028. This will take the form of a mileage charge for electric and plug-in hybrid cars, payable by drivers alongside their existing Vehicle Excise Duty.

In order to ensure that driving an electric vehicle remains an attractive choice for consumers, the new eVED will be around half the fuel duty rate paid by the average petrol/diesel driver, with a reduced rate for plug-in hybrid drivers: the rates of tax will be 3p per mile for fully electric cars and 1.5p per mile for hybrid cars. Certain vehicle types, such as vans, buses, motorcycles, coaches and HGVs, will be out of scope of eVED.

The Government has published a consultation which provides further detail on how eVED will work and seeks views on its implementation.

Extension of Air Passenger Duty

At present, only a small number of private jets currently pay the higher rate of Air Passenger Duty (APD). Following an earlier consultation, the Government will extend the scope of the APD higher rate to cover all private jets above 5.7 tonnes from April 2027.