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Tax Aware

Issue 23: February 2026

Tax Aware

Editor's note

Harry Hart

Whilst the 2025 Autumn Budget may not have delivered quite the seismic shock of last year's reforms, there are nevertheless some significant changes on the horizon. This Issue begins with an exploration of the significant changes to the employee ownership trusts an update on the latest business property relief (BPR) and agricultural property relief (APR) reforms, examine practical implications of the looming changes to inheritance tax (IHT) on pensions, consider the most significant expansion of the Enterprise Management Incentive (EMI) scheme in years, a review of a lesser known IHT relief that utilises surplus income, the advantages and potential pitfalls of family investment companies examination of the changes to IHT relief on testamentary charitable gifts.

Read the full note

News
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Navigating business succession: Budget 2025 changes to EOT relief

Over the past decade, employee ownership trusts became a popular route for business ownership succession. However, the Autumn Budget 2025 heralded a significant shift: from 26 November 2025, the capital gains tax relief on qualifying disposals to EOTs was reduced from 100% to 50%.

News
A person's hands

Looming changes to inheritance tax on pensions: what you need to know

From April 2027, most unused pension funds and pension death benefits will be included in a person's estate for inheritance tax, even if scheme administrators or trustees have discretion over payments. This is a major change, where currently pension assets remain protected from IHT and involve minimal administration.

News
interior gold ornament

Tax efficient trust planning with surplus income

Trusts are well established as a cornerstone of succession planning. However, for UK based individuals that are long-term resident, there are limited options for adding assets to trusts without triggering prohibitive tax charges. However, there is a lesser known exemption for gifts made out of surplus income, which represents a valuable opportunity to fund a trust over multiple years without the IHT entry charge.

News
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The advantages of family investment companies - but beware of getting stung

Family investment companies are popular succession planning vehicles, enabling clients to pass wealth to the next generation whilst ensuring they retain control. They are increasingly being considered as alternatives to trusts, however, using them could saddle you with higher overall tax rates compared to personal holdings, and multi-generational tax planning complications.

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