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In effect from
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Topic
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Description
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Reference
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15 May 2025
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Company Share Option Plan (CSOP) & Enterprise Management Incentives (EMI): Private Intermittent Securities and Capital Exchange System (PISCES)
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Allows existing CSOP and EMI option agreements to be amended (on or after 15 May 2025) to include a PISCES trading event as an exercisable event, without losing scheme tax advantages. The CSOP or EMI option must be granted before 6 April 2028.
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FA 2026, s 16
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26 November 2025
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Employee-Ownership Trusts (EOT): Restriction of relief on disposals
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Reduces amount of relief available on disposal of shares to the trustees of an EOT by treating 50% of the gain on disposal as a chargeable gain.
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FA 2026, s 35
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26 November 2025
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Reconstructions & reorganisations
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Amends the reorganisations anti-avoidance rule applying to share exchanges, company reconstructions, collective investment schemes reconstructions, and reconstructions involving transfer of business. The focus of HMRC counteraction will now be on arrangements that have a main purpose of reducing or avoiding a liability to tax, rather than the purpose of the reconstruction.
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FA 2026, ss 36-38
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26 November 2025
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Non-Resident Capital Gains (NRCG): Protected Cell Companies (PCCs)
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Extends NRGC rules that tax the disposal of UK land (and shares in a UK property rich company) by non-UK persons to PCCs by providing that each cell in a PCC should be looked at individually for the purposes of assessing UK property richness.
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FA 2026, s 40
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27 November 2025
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Stamp duty reserve tax: UK listing relief
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Introduces exemption 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 exemption applies for a 3-year period from the listing of the company’s shares (or depositary interests(over the company’s shares).
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FA 2026, s 85
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31 December 2025
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Pillar Two: Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT)
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Updates UK MTT and DTT legislation in line with administrative guidance published by the OECD.
Changes include:
· How pre-regime deferred tax assets should be treated (for accounting periods ending on or after 21 July 2025)
· Application of the clawback provisions for tax equity partnerships
· A simplified safe harbour calculation for non-material members
· How profits of a flow through ultimate parent entity can be reduced
· Operation of the election to exclude intragroup transactions
· Method of allocation of the DTT
· Testing whether de-merged groups meet the revenue threshold
· Method of converting Domestic Top-up Tax amounts into sterling
· Application of the MTT to permanent establishments, and
· Testing whether an instrument is regarded as equity or debt.
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FA 2026, s 50 & Sch.8
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1 January 2026
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Capital allowances: First-year allowance (FYA) for main rate expenditure on plant or machinery
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Introduces new 40% FYA for certain main rate expenditure incurred on plant or machinery (including expenditure on plant or machinery for UK leasing).
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FA 2026, s 29
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1 January 2026
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Transfer pricing: Unassessed transfer pricing profits (UTPP)
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The UTPP replaces the diverted profits tax (DPT) (in relation to accounting periods beginning on or after 1 January 2026) by creating a new charging provision within corporation tax. The UTPP targets structured arrangements designed to erode the UK tax base by omitting profits that are subject to transfer pricing.
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FA 2026, s 46 & Sch.5
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1 January 2026
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Transfer pricing: Reform
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Changes (in relation to accounting periods beginning on or after 1 January 2026) to align UK rules with international standards.
Amendments include:
· Broadening the participation condition
· Re-introducing an exemption for UK-to-UK arrangements (subject to exceptions)
· Introducing a single arms-length valuation standard for Intangible fixed assets
· Applying the principles in the OECD Transfer Pricing Guidelines to financial transactions.
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FA 2026, s 47 & Sch.6
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1 January 2026
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Permanent establishments
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Changes (in relation to accounting periods beginning on or after 1 January 2026) to:
· Align the UK domestic law definition of permanent establishment more closely with that in Article 5 of the OECD Model Tax Convention (MTC)
· Align the UK's attribution of profits rules more closely with Article 7 of the OECD MTC
· Revise the Investment Manager Exemption (IME) making it an optional 'safe harbour, expanding its scope, and removing the '20% rule', and
· Allow a UK-resident company to claim relief when a transfer pricing adjustment is made to a connected foreign company that relates to a UK permanent establishment.
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FA 2026, s 49 & Sch.7
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18 March 2026
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Annual tax on enveloped dwellings (ATED): Out of time claims to relief
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Ensures relief from ATED is available to businesses holding residential property for a commercial purpose with the time limit to claim relief from ATED removed. The change is treated as always having been in force.
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FA 2026, s 114
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31 March 2026
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Corporate Interest Restriction (CIR): Simplification
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Changes Corporate Interest Restriction (CIR) rules to simplify administration for reporting companies, including:
· Removing the time limit to appoint a reporting company
· Removing the requirement for the appointment to be made ‘by notice’ to HMRC.
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FA 2026, ss 61-62
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1 April 2026
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Capital allowances: Main rate writing-down allowance (WDA) for expenditure on plant or machinery
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Reduces the main rate of WDA from 18% to 14% for chargeable periods starting on or after 1 April 2026 (for corporation tax).
(For income tax, the reduced rate applies from 6 April 2026.)
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FA 2026, s 28
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1 April 2026
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Economic Crime: Increases rates of Economic Crime (Anti Money Laundering) Levy
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Restructures the Economic Crime (AML) Levy across four Bands, A to D:
· Band A: UK revenue £10.2m to £36.0m - ECL payable of £10,200
· Band B: UK revenue £36.0m to £500.0m - ECL payable of £36,000
· Band C: UK revenue £500.0m to £1bn - ECL payable of £500,000
· Band D: UK revenue more than £1bn - ECL payable of £1m
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FA 2026, s 113
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1 April 2026
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Corporation Tax: Penalties for failing to deliver company tax returns
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Increases penalties for companies who do not file Corporation Tax returns at the required time:
· Return late: £200 (up from £100)
· Return more than 3 months late: £400 (up from £200)
· Three successive failures (return late): £1,000 (up from £500)
· Three successive failures (return more than 3 months late: £2,000 (up from £1,000)
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FA 2026, s 265
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5 April 2026
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Withholding Tax: Concession for withholding tax on interest errors paused
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Last day to make a voluntary disclosure and an application for 'late payment interest only' concessionary treatment in respect of administrative failures to withhold income tax from payments of UK source yearly interest to overseas lenders in 2021/22 and later years.
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INTM413205
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6 April 2026
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Business Asset Disposal Relief (BADR): Rate increase
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Increases the BADR rate on qualifying gains for disposals occurring on or after 6 April 2026 to 18%.
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FA 2025, s 8
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6 April 2026
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Income tax: Dividend income ordinary & upper rates
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Increases:
· Dividend ordinary rate from 8.75% to 10.75%, and
· Dividend higher rate from 33.75% to 35.75%.
Rate increase also impacts tax charged on:
· Loans to participators of close companies, and
· Dividends paid to estates of deceased persons.
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FA 2026, s 4
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6 April 2026
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Enterprise management incentives (EMI)
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Increases EMI scheme limits:
· Limit on company options increased to £6m
· Limit on gross assets increased to £120m
· Limit on the number of employees increased to under500, and
· Limit on the exercise period increased to 15 years (existing fixed date options can be amended).
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FA 2026, s 13
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6 April 2026
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Umbrella companies
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Makes:
· Recruitment agencies jointly and severally liable to pay any amount payable under PAYE when they supply workers via umbrella companies, and
· The end client jointly and severally liable to pay any amount payable under PAYE where no agency is involved in the supply of the worker (or the agency and umbrella are connected or the agency is overseas).
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FA 2026, s 24
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6 April 2026
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Incorporation relief: Requirement to claim
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· Introduces requirement for taxpayers to claim incorporation relief for transfers of a business to a company, and
· Removes ability of taxpayers to make an election to disapply the relief.
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FA 2026, s 39
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6 April 2026
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Non-residents: Dividend tax credit
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Abolishes notional tax credit received by non-resident individuals for tax treated as being paid on dividends received from UK companies.
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FA 2026, s 42
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6 April 2026
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Carried interest: Reform
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Introduces a revised regime for the tax treatment of carried interest, which sits wholly within the Income Tax framework. All carried interest will be treated as trading profits and subject to Income Tax and Class 4 NICs.
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FA 2026, s 58 & Sch.11
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6 April 2026
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Inheritance Tax: Agricultural property relief and business property relief limit
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Limits the value of property in an estate qualifying for 100% agricultural property relief (APR) and/or business property relief (BPR) to £2.5m (fixed until 5 April 2031). Relief will be reduced to 50% on property values above the £2.5m threshold.
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FA 2026, s 65 & Sch.12, para.4
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6 April 2026
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Inheritance Tax: Business property relief – Shares traded on Alternative Investment Market (AIM)
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Reduces business property relief (BPR) from 100% to 50% for:
· shares traded on but not listed on the markets of recognised stock exchanges (such as the Alternative Investment Market (AIM)), and
· qualifying shares listed on foreign exchanges which are not a recognised stock exchange.
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FA 2026, s 65 & Sch.12, para.12
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6 April 2026
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Construction industry scheme (CIS): Deliberate failure to comply
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Introduces new HMRC powers to:
· Remove Gross Payment Status (GPS) immediately,
· Assess the business for the tax lost, and
· Charge a penalty of up to 30% on the business or the business’ officers
Powers apply where a business makes or receives a payment they knew or should have known was connected to deliberate failures to comply with the CIS.
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FA 2026, ss 220-222
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6 April 2026
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Construction industry scheme (CIS): Simplification
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Changes the operation of the CIS to:
· Exempt payments made to local authorities or public bodies from scope of the CIS, and
· Reintroduce require for construction contractors to file a 'nil return' when they have not paid any subcontractors (unless they have notified HMRC in advance that they will not make any such payments).
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Income Tax (CIS) (Amendment) Regulations 2026,
SI 2026/289
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18 May 2026
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Mandatory Tax Advisor Registration (TAR)
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Introduces a new mandatory registration regime for tax advisers who, as part of their business, interact with HMRC on behalf of their clients. Tax advisers will need to meet minimum standards to register.
HMRC have agreed to pause the implementation for impacted financial services businesses until the end of March 2027.
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FA 2026, ss 223-249 & Schs.16-19
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From July 2026
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Advance tax clearance: Large UK investment projects
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Introduces new HMRC advance clearance service for major investment projects (with qualifying project expenditure of at least £1bn) for Corporation Tax, VAT, Stamp taxes, PAYE, and Construction Industry Scheme.
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FA 2026, ss 266-274
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1 January 2027
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Carbon Border Adjustment Mechanism (CBAM)
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Introduces a new tax called the carbon border adjustment mechanism (CBAM). CBAM places a carbon price on emissions embodied in goods imported into the UK from the aluminium, cement, fertiliser, hydrogen, iron and steel industrial sectors.
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FA 2026, ss 142-158 & Schs.20-21
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