The Chancellor delivered the Autumn Budget on 28 October 2026. Most of the changes take effect from April 2027, with some later and a few immediate. Full detail is in HMRC’s Overview of Tax Legislation and Rates. This is a brief summary of the main measures.
Business Asset Disposal Relief and exit planning
The lifetime limit for Business Asset Disposal Relief (BADR) falls from £1,000,000 to £500,000 for disposals on or after 6 April 2027. Special provisions apply to contracts, share reorganisations and exchanges not completed by then, so exit timing matters.
A new lower Capital Gains Tax rate, Founders’ Relief, will apply to founders and early investors in high-growth companies for disposals from 6 April 2027. The rate has not yet been stated, and the technical consultation closes on 30 November 2026.
Gift holdover relief will also change from 6 April 2027, with the restriction formula now taking account of intangible fixed assets and assets qualifying for the substantial shareholding exemption (SSE).
The reform of distributions and capital repayments will go ahead with design changes, draft legislation in 2027 and effect from April 2028. The proposed new reporting requirement for payments to participators has been dropped for now.
Employee share schemes, EMI and Employee Ownership Trusts
All of the following apply from 6 April 2027:
- The Company Share Option Plan (CSOP) individual limit rises to £120,000, the exercise period extends to 15 years, and the combined CSOP/EMI limit is removed.
- The Employee Ownership Trust (EOT) exception now covers companies arranging to become EOT-controlled, which helps where EMI options are already in place ahead of an EOT sale.
- The EMI exercise window extends to 180 days after a disqualifying event.
- The separate notification of EMI grants is replaced by the end-of-year return, for options granted on or after 6 April 2027.
Income tax changes from April 2027
From 6 April 2027, savings income will be taxed at 24% (basic), 44% (higher) and 49% (additional). Property income will be taxed at the same rates in England, Wales and Northern Ireland.
The trading allowance rises from £1,000 to £3,000. Approved mileage rates above 10,000 miles rise from 25p to 35p. Payrolling of benefits in kind starts for cars, vans, fuel and medical benefits from 6 April 2027, with most other benefits following from 6 April 2028. Image rights payments will be taxed as employment income from 6 April 2028.
Corporation tax, capital allowances and R&D
For the 2028 financial year, the main rate stays at 25% and the small profits rate at 19%.
The first-year allowance for main rate assets rises to 50% for spending from 1 January 2027. The main rate writing down allowance falls to 12% from 1 April 2027 for corporation tax and 6 April 2027 for income tax.
The foreign permanent establishment exemption becomes mandatory for accounting periods beginning on or after 1 January 2027. The R&D Claim Notification Form is removed for claims from 1 April 2027, and the Advance Tax Certainty Service threshold drops from £1bn to £300m.
Property: SDLT, ATED and VAT on land
From 29 October 2026, winding up the vendor will no longer prevent clawback of SDLT group relief if the purchaser leaves the group within three years. SDLT on the rent element of assured tenancies is removed, with effect from 1 May 2026.
ATED charges rise by 3.5% from 1 April 2027. The High Value Council Tax Surcharge applies to residential property worth £2m or more from April 2028. Land sold to housing associations becomes zero-rated for VAT from 1 April 2027.
VAT changes
From April 2027, the reverse charge on overseas B2B services will apply only where the UK customer is VAT registered. Unregistered customers will be charged UK VAT by the overseas supplier. Online marketplace liability extends to UK sellers from October 2027, and e-invoicing becomes mandatory from April 2029.
Inheritance tax, trusts and pensions
From 6 April 2027, personal representatives can direct pension scheme administrators to pay any inheritance tax due. They can also choose how pension property is treated for the charity reduced rate.
From 28 October 2026, a new statutory rule and anti-avoidance provisions apply to trust liabilities funded from a beneficiary’s own estate. The two-year rule is removed for pension and lump sum death benefits paid from the same date. There is also an easement from the trust exit charge for trusts that are only temporarily UK resident because a trustee moved here.
Tax administration and compliance
- Self Assessment payments on account become more regular within the year from April 2029.
- Direct Debit becomes mandatory for VAT and PAYE return liabilities from April 2029.
- A duty to correct inaccuracies, with HMRC Customer Correction Notices, applies from 1 April 2028.
- No late submission penalty points will apply to Making Tax Digital for Income Tax quarterly updates for 2027-28.
Planning ahead
With several measures starting on 6 April 2027, business owners considering an exit, share scheme changes or major capital spending should review their plans now. Contact @taylor-rogers below about how the changes affect your position.