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Editor's note

Posted on 11 February 2026

Tax Aware - Mishcon de Reya

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: our latest edition of Tax Aware (Issue 23) gives you a quick, digestible snapshot of some of the key ones.

This Issue begins with an exploration of the significant changes to the taxation of employee ownership trusts (EOT) which will no longer provide sellers with a full exemption from capital gains tax. We then provide an update on the latest business property relief (BPR) and agricultural property relief (APR) reforms, this time with some more positive changes. Next, we examine the practical implications of the looming changes to inheritance tax (IHT) on pensions, which will see most unused pension funds included in a person's estate for IHT purposes from April 2027. We then consider the most significant expansion of the Enterprise Management Incentive (EMI) scheme in years, with the headcount cap doubling to 500 and the gross assets threshold quadrupling to £120 million from April 2026. This is followed by a review of a lesser known IHT relief that utilises surplus income, which can be used for tax efficient trust planning. We then weigh up the advantages and potential pitfalls of family investment companies (FICs) as alternative succession vehicles to the traditional trust structure. Finally, we close our Issue with an examination of the changes to IHT relief on testamentary charitable gifts, which will no longer apply to unregistered charitable trusts from 6 April 2026.

Please do let us know if you'd like us to consider anything in particular for the next Tax Aware.

For now, we hope you enjoy this Issue, and thank you for your continued support and readership.

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