Death and Taxes S5:E6 – Autumn Budget 2025

Season five has seen us back on the airwaves at a time of significant change in UK tax policy. And today’s episode is no different as we are recording this budget special the day after Rachel Reeve’s statement on the 26th of November. I’m glad to say there’s been no unofficial early release of this pod and I’m delighted to welcome back John Barnett, a Partner in the Private Client team, to Death and Taxes. John has been with the firm since 1995 and is a Partner in the Tax and Private Client teams. John is also the Vice President of the Chartered Institute of Taxation and chairs CIOT’s Technical Policy Committee and Oversight Committee. John and I are joined by Ed Hayes, who is also a Partner in the Private Client team. Many of Ed’s clients have international connections and have been impacted by the recent tax changes, and Ed is particularly experienced in navigating complex cross-border issues, often involving the use of trusts and family investment companies.

John, if I may, can we start with you? What are your initial thoughts on the announcements from yesterday?

John Barnett (01:13)

Well, we obviously knew quite a lot of it beforehand, certainly half an hour beforehand when the OBR released all of it. But as the weeks went on, I think the panic got slightly less. And actually on the day, it was much less drastic than some of the rumours from a few weeks before suggested. Helped no doubt by the OBR giving Rachel Reeves slightly better than expected figures.  There was, as always, a lot of detail behind the headlines.

So, when you go to the revenue website, you find 88 separate policy announcements, a lot of which weren’t trailed in the speech. But I think, you know, in terms of what there wasn’t there that we thought might be, you know, there were no material changes to Inheritance Tax and gifting, no changes to speak of to existing pension pots, Capital Gains Tax stayed largely the same. There’s no exit tax, no wealth tax, no stamp duty land tax, no LLPs.

No, so there was a lot that was rumoured that didn’t happen.

Guy Broadfield (02:14)

And I suppose many of our clients will come away from that with a sense of relief, but nonetheless, we would all agree that some of the announcements will still have a material impact.  And we can already see at this point how different forms of planning might have to adapt in response to what was announced yesterday. So, Ed, one of the key topics that was announced yesterday was this idea of a mansion tax or whatever you like to call it. Do you want to give us a brief idea of that and what your thoughts are on that policy announcement?

Ed Hayes (02:50)

Absolutely, the high value council tax surcharge, I think is the official name. And I think both mansion tax and council tax are probably misleading in what this actually is. I mean, it’s called council tax, but it’s quite different in practice. It’s going to be payable by owners, not occupiers, and the revenue raised is going to go to central government rather than local government. It kicks in from April 2028, so there’s a bit of time before this actually becomes a reality for people.

In terms of numbers, we’re looking at an annual charge of £2,500 for properties worth more than £2 million, rising up to £7,500 for properties worth more than £5 million. And those figures are also going to be linked to inflation and rise with the CPI. So, you can absolutely expect those to go on an upward trend, and we’ve seen that with other index-linked charges like the ATED. Now, there’s a consultation planned on this. So, we don’t yet have lots of the detail, but there are a few things we can pull out. Importantly, the government has said it’s going to use its own valuation service to work out which properties are within scope and which band they fall into. It’ll be interesting to see how they do that. We are aware that the Welsh government has been using AI tools for valuation and thinks that it’s had about a 95% accuracy rate with that. So presumably some form of technology will be used in that bracket. But we could still see an impact on the market as people are incentivised to bid slightly below some of those key thresholds. So, the bands for different charges are £2 million, £2.5 million, £3.5 million, and £5 million. So, you might see people being reluctant to bid over those on properties at the margins. And we can also see that the charge actually, relatively modest, I think, in comparison with certainly some other things. The ATED for similar value properties is much, much larger. It’s kind of £30,000 rather than a couple of thousand pounds.

We have also seen the government saying in the reference to a consultation, they’ll be looking at who would be appropriate to have some support with this. Presumably that is elderly pensioners, who have big houses but not much cash. They might not be bearing the full brunt. But there’s no mention at the moment of any relief or lettings. So, that combined with the increase to property income tax, if you have particularly valuable let properties, this will be a bit of a double whammy on profits.

Quickly, if I may, going on to that property income tax. The headlines there are a 2% increase on standard income tax rates on property income from April 2027. So basic rate becomes 22%, high rate 42%, and additional rate 47%. And that’s both on just outright lettings income from kind of personally held or directly held property, and also certain forms of return on collective investment schemes that go into property. It is worth flagging that that increase in rate is going to apply in England, Wales and Northern Ireland, but not automatically in Scotland. TBC on what the Scottish government wants to do with that because they’ve got devolved powers over property income. And John’s correctly pointed out in other settings that actually the impact on the Barnett formula is how much money Scotland gets, means that actually Scotland’s block grant would reduce if they don’t also raise their, kind of, taxes in line. And I think in terms of planning impact of all of this. It’s another incentive to incorporate your lettings business if that’s an option that’s kind of feasible and available to you because the gulf between the income tax payable on lettings income and corporation tax payable on lettings income is only getting wider and of course companies can make better use of deductions on mortgage interest. So, if that’s an option I think more people will be looking at that.

Guy Broadfield (06:36)

And the Barnett formula has nothing to do with you, John.

John Barnett (06:39)

No, completely unrelated. I wish I’d been Lord Barnett, but nothing to do with me and no relative.

Guy Broadfield (06:44)

Well, it might happen, John, all in good time.  Let’s see. But thanks, Ed, for talking about those property issues. I mean, in addition to property income tax and the additional increase there, there were, of course, increases to other rates on dividend and savings income. John, have you got any thoughts on the dividend income point?

John Barnett (07:08)

Yes, so dividend income happens sooner. So this is happening from April 2026, whereas for property and savings income, that’s from April 2027. So again, 2% more on the lower rate, it goes to 10.75%, I think, and the higher rate, which goes to 35.75%. Interestingly, the top rate of dividend tax, the additional dividend rate of 39.35%, stays the same.

And given that dividends are treated as the top slice of income, in practice actually for a lot of sort of high-net-worth, ultra-high-net-worth clients, actually probably the dividends will be the top bit of their income. So actually 39.35% stays the same. Now, there will be some interesting calculations as there always are for people who own their own businesses through companies as to whether you take salary out of that company or dividends out of that company.

And I think these new rates generally, until you get to the very upper rates, are probably increasingly favouring taking salary or bonus out of the company, but you need to do the calculations on those each and every time for your particular situation. So, don’t sort of take that as universally the case. On savings income, as I said, the rates won’t increase until April 2027. Up until now, there are certain types of investment where you could take a dividend from it, you could take interest from it, or you could choose your type of investment. That’s going to increasingly favour dividends rather than other forms of savings income. So, savings does go beyond just interest though. It also includes gains on offshore bonds, some returns from offshore funds, profits on deeply discounted securities, all of which probably go up to 47% at the upper end. There’s possibly a quirk though for gains on non-reporting funds, so-called offshore income gains, which are miscellaneous income according to the tax code. So, it looks as though, although this will be clarified in due course, those might stay at 45% rather than going up to 47%. So, there may be some questions to ask about whether you convert reporting funds into non-reporting funds to take advantage of that 2% difference. I think the general message is that investors should be reviewing their portfolios to consider what impact all of these rate changes have. The other small one is that the rate of relief for an investment in a Venture Capital Trust, a VCT, is going down from 30% to 20%.

Guy Broadfield (09:52)

Thanks John, I mean, we may touch on VCTs and EIS regimes a bit later on when it comes to entrepreneurs. So, I mean, that’s really dealt with the property and income taxes of a sort, in respect of savings. Clearly a large part of what we do is also focused on Inheritance Tax. And as with last year, there was a lot of speculation in the run up to the budget about exactly what might change, if anything. You might hear that one analysis of the budget yesterday was that it’s relatively, well, very quiet on this front in terms of the changes that were announced. But John, you pointed that whilst it was quiet in terms of headlines, there are a number of changes, in fact, on the Inheritance Tax side that we should consider going forward.

John Barnett (10:41)

Yeah, the good news on Inheritance Tax is the big-ticket changes, particularly to gifting, introducing some sort of lifetime gift tax or changing seven years to 10 years. All of those haven’t happened. But there were, I counted up about 11 different Inheritance Tax measures, everything from foreign diplomats to victims of infected blood scandal to agricultural land held by offshore companies. I’m not going to go through all of those at the moment. But I think it does make the general point that Inheritance Tax is an incredibly complicated tax and historically politicians have steered away from touching it and  last time around Rachel Reeves took the risk of touching Inheritance Tax particularly around pensions and agricultural and business property and now we’re seeing the outflowing of that in the all these other technical changes they feel they now have to make for it. Obviously the big one I guess was around agricultural and business property and I think that’s probably your area, Guy.

Guy Broadfield (11:41)

So yes, thanks, John. I mean, there was welcome news that the £1 million allowance will be transferable between spouses and civil partners if it’s not used on the death of the first partner.  Clearly a welcome clarification there to bring it in line with the nil rate band and the residence nil rate band. In many cases, clients were already reviewing their wills to make sure that they did bank the relief and use it rather than lose it. Those clients still need to review their affairs to make sure that their wills match their wishes. But I think it’s a pragmatic solution perhaps for those clients who weren’t taking advice and who may have lost out otherwise. The fact that you can claim any unused allowance on the second death has to be welcomed.

John Barnett (12:32)

And I think it’s right, Guy, isn’t it that actually if the first spouse has already died you will still be able to claim their allowance so there’s a slight element of helpful retroactivity about this as well.

Guy Broadfield (12:44)

There’s some speculation in commentary in the industry at the moment that do you need to have died owning at least some relievable property in order to be able to transfer the unused part of your allowance to your spouse? And the answer seems to be no. So in that sense, matches the residence nil rate band.

Ed Hayes (13:05)

Yes, I think the HMRC example and their guidance is quite helpful in this, isn’t it? And it seems to make clear that the first to die does not need to have owned APR or BPR property to effectively had a £1 million allowance and can have died before all this was announced. So, it does look as though effectively, as long as the first to die has not used it, whether they haven’t used it because they didn’t own anything, whether they’ve done something else with it, such as made it all spouse exempt, that threshold should carry over to the second couple. So, for most couples, you’ve effectively got £2 million of BPR property you can pass on tax free entirely. And then it’s only the value above that £2 million threshold that is subject to IHT. And even that gets a 50% relief still. So effectively, you’re looking at a 20% IHT tax on the figure above £2 million.

Guy Broadfield (13:51)

So, I mean, moving on from landowning and farming clients and indeed business owners, another category of clients that were impacted by the announcements yesterday were entrepreneurs. Some plus points here, some negative points. Overall, what do you think, John, a tough budget for entrepreneurs?

John Barnett (14:10)

I think when you look at the individual measures, yes, that’s probably right. But I think a big sort of encouraging point and certainly when you look at the numbers as to what the government are spending on this, what they’re doing around scale up businesses, extending enterprise management incentive in particular to those businesses, increasing the limits for enterprise investment scheme and VCT to invest in that sort of next chunk of businesses up after startup businesses. That is, sort of, the probably the single best thing that personally I think comes out of this budget, in that there will be better tax reliefs for those growing businesses and an incentive to allow people not just to start up their businesses but to keep them going as well.

Guy Broadfield (14:56)

Yeah, and listeners will be able to hopefully hear some more views from Nigel Watson in the Incentives team at Burges Salmon, possibly on a pod coming soon. Who knows?

Ed Hayes (15:05)

Just on the entrepreneur part, the way I’ve been describing it to one client this morning was actually that there’s almost three buckets of changes here for entrepreneurs and some of them positive, some of them negative. On the one hand, you’ve got changes to your bottom line, which are probably broadly unhelpful in terms of frozen NICs thresholds for employers, increased minimum wage and the increased dividend tax, none of which really help in terms of your overall profit. But then you’ve got the second bucket, changes which make hopefully getting investment and incentivising key people easier, which is the expansion, the EIS and VCT and the enterprise management incentives. And finally, on the exit, you’ve got a third bucket of changes which are probably broadly negative for entrepreneurs in terms of we’re going to see CGT relief on sales to employee ownership trusts be reduced. That was 100%, now it’ll be 50% and that change is immediate. So particularly unfortunate if you’re in the middle of that planning right now. And the previously announced increase in business asset disposal relief, which is the new version of the old entrepreneurs relief, that rate increased to 18% still going ahead from 2026. So, I think part of this, it is negative, but as John said, that actually some of the big changes are on kind of ongoing incentivisation investment, and hopefully those will be at least a silver lining for categories in that bracket.

Guy Broadfield (16:27)

Certainly those clients who are considering EOTs perhaps more with a view to the tax relief will have to consider the rationale for that planning. In effect, I imagine it will mean that those business owners who are really genuinely interested in benefiting their employees in that way will want to go down that route. But that remains to be seen. Linked to the world of work, there were a number of changes to the pension regime, which I’m sure we should touch on, if only briefly, and a lot of talk in the run-up to the budget about possible changes to the salary sacrifice regime. So, Ed, would you like to speak to those changes briefly?

Ed Hayes (17:10)

Yes, absolutely. I think the headline here is actually if you’ve got an existing sizeable pension pot, then you’ll probably be quite relieved because lots of things that were feared or threatened, however you view it, that could have impacted extracting value from those, particularly the loss of, or the restriction of the tax-free lump sum, those have not come to pass. So that’s good news. I mean, there’s also, it’s a technical point, but it’s quite a helpful one in practice, that some of the arrangements for charging Inheritance Tax on pensions are being amended. We’re still going to have Inheritance Tax on pensions and it’s still far from perfect, but it does appear the government’s listened to the private client industry and some of the risks on personal representatives and the executives and so forth who are having to deal with paying the Inheritance Tax on pensions, I think there have been some positive movements there, even if we’re far from the finished product. But the biggest headline, of course, was this change on national insurance contributions on salary sacrifice contributions. So, until now, if you sacrifice your salary in order to pay into your pension, you get kind of the double whammy benefits of the income tax relief on your contributions, but also there’s no employer NICs on those and that makes it kind of cheaper for everyone all around. So, losing the benefit of that for lots of people will be a blow. You can still make contributions up to £2,000 a year without being hit by this. But for most high-net-worth clients, it’s going to be something that if they were using this policy, they will get less out of it going forwards than they would have previously, albeit this is not an immediate change. So, I think this is coming in April 2029 from memory. So, there is a bit of time for employees and employers to work out how they will address it.

Guy Broadfield (18:56)

Thanks, Ed. I mean, you mentioned that might have limited impact on the high-net-worth community. I mean, one aspect to all of these recent changes, indeed changes to the tax code over the last 18 months, has been the new tax regime for international clients. John, you’ve picked up a number of announcements yesterday that refine or change some of those rules as we thought they would operate. So, summarise those.

John Barnett (19:21)

Yes, so we had a lot of changes for what we used to call non-doms last year in April 2025 and nobody’s come up with a better title for them so I’m still going to call them non-doms even though actually the technical phrase is probably non-long-term residents. We had most of the changes on that last year, the revenue accepted that some of the legislation from last year was wrong and we understood that there were about 40 technical fixes that the Chartered Institute of Tax and others were calling for.

On the last count, I haven’t been through all of them. I think they’ve only tackled 23 I can get to. So, there’s probably 17 missing changes that I need to work out what they are. Most of them are pretty technical. But there are a few bigger ticket ones. The biggest of which is for high-end trusts that used to qualify for excluded property status for Inheritance Tax. So, this is a trust set up by somebody before they were ever domiciled or deemed domiciled in the UK, set up before 30th of October 2024. Those trusts were brought into the Inheritance Tax regime by last year’s changes, but there is now going to be a cap of £5 million of Inheritance Tax every 10 years for those trusts.

It would have to be quite a big trust for 6% of it to equal £5 million. I think the trust needs to be worth more than £83.33 million or at least grow to that size over the course of each 10-year period. So, this is going to be quite a niche subject for many. But at the very upper end, obviously, they have listened to the criticism that the Inheritance Tax changes for non-doms last year were really scaring a lot of billionaires out of the UK.

Now, that is a relief per trust rather than the relief per settlor. So actually if you’ve got clients with sort of trusts worth more than £83 million, quite a lot of clients at that level will have multiple trust structures that all interact with each other. And I’m not even sure that amalgamating all of those will necessarily work. But anyway, there’s some thinking to be done there.

One bit of thinking around those are a lot of clients in response to last year’s changes collapsed some of the bigger trusts they had because they didn’t want to pay 6% Inheritance Tax every 10 years. May now wish that they hadn’t collapsed that. Now in certain situations, it’s possible if you’ve made a mistake about a tax position to go to the courts, particularly in somewhere like Jersey or Guernsey, who are often quite amenable to overturning something. I suspect that might be difficult on these grounds.

I think a misprediction of what future tax changes is not the same as a mistake. But anyway, there may be something there. Obviously, once you get above £83 million, if you can have as much wealth in there as you like, and it’s all free of Inheritance Tax. So, at that upper end, that’s a particularly valuable relief. So that’s one big ticket one. There’s a couple of other technical changes on what’s called the temporary repatriation facility. So this was again a facility introduced last year where non-doms and their trusts could pay a 12% rate of tax on Foreign Income and Gains personally or on the Income and Gains of trusts which were matched with payments or benefits out of the trust. So, as I said known as the temporary repatriation facility. Now there are a number of quirks in those rules and we then get into what I call either double foreign Income and Gains or quantum Foreign Income and Gains, which is some pretty weird concepts, but actually can be quite important. Now, trying to explain it is quite difficult, but let’s say you had a non-dom who had some unremitted Foreign Income and Gains, used that to fund a trust. The trust then grows in value, provides a benefit back to someone, let’s say it’s back to the original settlor just to make it easy.

Now, when the settlor takes the benefit out of the trust, that is matched to the trust’s Income and Gains, but the payment may also derive from the settlor’s Foreign Income and Gains. So, you can have two lots of foreign income and gains residing in the same payment out of a trust. Now, the legislation last year said that if you pay 12% tax on that once under the TRF, that absolves all income tax and CGT charges, which looked very generous. In fact, it looked probably slightly unduly generous. Now, this year’s Finance Act corrects that, but it does so with retrospective effect. So actually, if you’re now in that situation, you may have to pay up to 24% tax to clean out both the settlor’s original Foreign Income and Gains and the trust’s Foreign Income and Gains. Not unreasonable had they said that in the first place, but of course, this is retrospective legislation and some people in the meantime will have taken action in reliance on the fact that there was a 12% rate of tax and are now being told, terribly sorry, it should have been 24% all along. Now that’s genuinely retrospective legislation. There’s all sorts of human rights arguments around that. Naturally, the professional bodies will be going back on that.

You do get the opposite situation, which I call quantum Foreign Income and Gains, where the same Foreign Income and Gains can be in more than one place at the same time. So classic example of that, and this is getting quite technical. Let’s say a non-dom had some Foreign Income and Gains. They lent it to their own company. Now that Foreign Income and Gains is now sitting in the company, but it’s also sitting in the loan. So, it’s now in two places at the same time. And again, on last year’s legislation, it looked like even though it was only one lot of Foreign Income and Gains, you might have to pay 24% on that. So entirely the opposite of the situation we just described. That situation again, they have reversed that one. So that now says something more sensible. And again, they’ve done that one retrospectively as well. But because that’s in the taxpayer’s favour, I don’t think anybody’s going to complain about retrospective legislation on that point. So, some quite detailed technical points, a whole load of others in there as well. But in the interest of time, unless you have particular questions, I won’t go into them. The one other thing I might add though is around what’s called transfer of assets abroad and the Settlements Code. At the moment, there’s some very complicated rules for taxing offshore structures and there’s at least four different tax codes that can apply. The government announced a consultation on that last year. There’s been various representations from professional bodies on that in the meantime. The government have now said they are looking at developing proposals and are looking at a bold and substantial reform and bold and substantial simplification of those rules and they are going to look to co-create that with a small group from professional bodies. So, we’ll wait and see on that but that looked generally positive that they are  continuing with that because there was some suggestion that that was just going to get quietly forgotten.

Guy Broadfield (26:53)

Excellent, thanks, John.

I’d be interested to hear more about your quantum theory, but that might be a different podcast for a different time about physics or otherwise. But Ed, going back to some of the sort of more niche changes, there was a slight clarification on IHT changes to agricultural property. Would you like to just talk about that briefly?

Ed Hayes (27:17)

Yes, there’s a couple of changes made to the way that the situs of an asset, so where it is actually located, impacts its taxation, particularly when held in a trust. At the moment, broadly speaking, if an individual is not long-term resident, so generally that means they’ve been UK tax resident for fewer than 10 years, they and the trust that they’ve settled are only exposed to UK Inheritance Tax on UK situated assets and assets which derive their value from UK residential property. That second caveat is going to be expanded. So, we’ll have to tell clients that it’s assets which derive their value from UK residential property and/or UK agricultural land or buildings. So, there’ll be an additional kind of effectively Inheritance Tax charge if you hold UK farming land or buildings effectively.

Even if you hold them indirectly, they can give rise to an Inheritance Tax charge. And there was also, it is a very minor tweak, but a clarification as to how if a settlor who’s long-term resident ceases to be long-term resident, which can give rise to an exit charge on their trusts, how that works if the trust owns UK situated assets at the time. So actually the way the legislation had been drafted, it was only a problem if you had non-UK situated assets when the settlor ceased to be long-term residents. There was this idea that maybe you could make sure your trust owned only UK situated assets at that point and then swap them out for non-UK situated assets at a later date, but they’re going to amend that so that shouldn’t help, basically. And a few other kind of anti-avoidance things just to, we won’t go into the details of how they work, but just to flag that they were there. There were some kind of slight tweaks to the requirements for CGT relief on share for share exchanges and incorporations of businesses.

I think John would say they’re not really changes, they’re more just kind of making sure there’s clarity on how the tests work in practice. We’ve also seen a clarification on the way that Capital Gains Tax is going to apply to protected cell companies, so known as PCCs. Those have become, we’ve seen those marketed quite a bit in recent years. I think it’s fair to say we’ve always been slightly wary of using them, but there has been some merit in some cases, but the new rules will change how Capital Gains Tax works in relation to those, particularly when they hold UK  property. So, anyone with a PCC just needs to make sure that’s being reviewed. And on a positive side, it’s a minor tweak in the scheme of things, but will be very important potentially for people who are affected. The loan charge, which is this kind of historic issue of people who sometimes chose, sometimes were basically obliged, to provide their services via a personal services company and then took, you know, payments from that in the form of loans rather than dividends. Lots of those have had very difficult disclosure exercises with HMRC or inquiries from HMRC since and are facing very significant liabilities, in some cases bankruptcy and so forth. And there is this new proposal for a settlement regime which might help people in that scenario. So, anyone who’s impacted by the loan charge should have a look at that. And then alongside all this, lots of consultations either ongoing or announced, particularly several into penalties on failure to get your taxes right. So we wait and see exactly how those turn out. There are also some changes to the way that the temporary non-residents rules work. So, those are basically rules which apply if someone is non-UK resident for a relatively short period. So usually five tax years or fewer. And they generally apply to gains. So, if you realise gains on disposals of an asset whilst you’re outside of the UK in that temporary non-resident period, you could be taxable on the gain when you come back to the UK. But they also apply to certain limited forms of income that arise in that period. One of them has always been dividends arising from a close company, but there was an exception to that. That effectively meant that if the company generated profits and then the profits were generated in the period of non-residence, then a dividend of those profits in the period of non-residence would not be subject to income tax when the shareholder came home again or came back to the UK at the end of that period. The government’s referred to that as a loophole. I query whether that’s an accurate terminology, but nevertheless, that will be changing. So, if you have any dividend received from a close company during a period of temporary non-residence, you should probably assume that that’s going to be taxable going forwards.

Guy Broadfield (32:04)

Well, thanks, Ed and John. A considerable amount of detail there and perhaps not surprising if, John, as you mentioned there were 88 policy announcements in total yesterday. But with a view to the more practical advice to clients and advisors alike, what are the three main things that clients should be considering now in light of what Rachel Reeves said yesterday?

John Barnett (32:32)

So, I think definitely consider for our sort of clients, high-net-worth, ultra-high-net-worth individuals, looking over your investment portfolio and considering what changes to make before the new rates kick in. So particularly things like reporting funds, non-reporting funds, checking whether you’re getting dividend income or savings income or miscellaneous income, there’s going to be a whole lot more to check over there. So, work with your financial advisors, your bank, to make sure that your investment portfolio is properly constructed. There may be a case for bringing forward some dividends before April 2026 when the new dividend rates kick in. Although remember that the 39.35% at the top end doesn’t change. So that’s only going to really apply if you’re below £150,000 of income. Ed, do you have any other thoughts?

Ed Hayes (33:23)

Yes, I think just generally these changes are going to make planning, which involves corporate vehicles, more attractive because as we continue to see a divergence between the top rates of income tax and top rates of corporation tax, lots of people will start thinking, actually, well, if they can effectively pay corporation tax, that’s going to be more favourable. So do expect to see much more interest in things like family investment companies and incorporation of letting businesses. There’s lots of pros and cons to consider there in both cases.

I think we are particularly wary of either of those becoming commoditised planning options because actually there’s lots of pitfalls and traps you can fall into. But for the right clients, they can be very helpful planning options and actually their relative value is only increased by many of the announcements in this budget.

Guy Broadfield (34:12)

I think on my side, I would point out that clients who will be impacted by the changes to agricultural property relief and business property relief from next April and who haven’t yet implemented any planning, still have a window to consider their options ahead of next April, possibly transferring relevant assets into trusts before then.  But there is still time, albeit not much.  It’s time to get one’s ducks in a row over the next four months if they are affected by that and know where they stand ahead of next April.

Thanks again for listening to this bonus episode of Death and Taxes – and everything in between, the private wealth podcast from Burges Salmon. You can listen to our previous episodes and get in touch with the team at Burges-Salmon.com or on our LinkedIn page. Keep an eye out for new episodes coming in 2026, where our specialist team will bring you our views on the new rules and their practical implications for clients. So don’t forget to subscribe and thanks again for listening.