Published: Dec 5, 2025 | Authors: Kieran Duffy, Stephen Dowds, Martin Wilson
Chancellor Rachel Reeves unveiled a £26bn tax increase package with significant implications for high-net-worth families and business leaders:
1. Business Disposals & Exit Structuring
Business Asset Disposal Relief (BADR) rises from 10% to 14% in April 2025, and to 18% in April 2026. For founders planning exits, timing and structural rollover become paramount. The 100% CGT exemption on Employee Ownership Trusts (EOT) was restricted immediately on Budget Day to a 50% relief cap.
2. Estate Planning & Pensions in IHT
From April 2027, unspent defined contribution pension pots will fall within the scope of UK Inheritance Tax. Additionally, from April 2026, the £1m 100% APR/BPR allowance will be transferable between spouses, with 50% relief applied above the threshold.
3. Recommended Action Steps
We encourage clients to review their current will covenants, spousal asset distributions, and family investment company holding vehicles with our wealth structuring team before the April 2026 and 2027 transition dates.