What It Means for UK & Channel Islands Business Owners,  UHNWIs, and UK-Connected Residents

The UK Autumn Budget is never just about UK tax; it's a global trigger for change. For our clients (UK business owners, internationally mobile families, and high-net-worth individuals with UK ties),  it is a critical juncture.

We see this Budget not as a burden, but as an option event. The headline changes signal a clear direction: more focus on residence, substance, and defensible planning.

Personal Taxes

See an extension of freezing thresholds until 2030-31, a 2% increase in the ordinary and upper rates in dividends from April 2026 and from April 2027, and a 2% increase in the rate of income tax on savings across all bands.  The cash ISA limit is reduced to £12k, with a further £8k available for stocks and shares.  Also, a cap of £2k per annum on salary sacrifice pension schemes.  An abolition of the dividend tax credit for non-UK residents

Property Taxes

The mansion tax (high-value council tax surcharge) from April 2028 on properties valued at £2m or above.

Business Taxes

First-year allowances at 100% for qualifying expenditure on zero-emission cars and charge points are to be extended for a further year. From April 2026, the main rate of writing down allowances will reduce from 18% to 14%, with a new 40% first-year allowance for main rate assets (excluding cars) from January 2026.

For disposals of shares to the trustees of employee ownership trusts on or after 26 November 2025, only 50% of the gain will be relieved, with the remaining 50% of the gain held over until future disposals by the trustees.

There is to be a doubling of the investment thresholds and gross asset tests for venture capital trusts and enterprise investment schemes,  and a reduction in upfront income tax relief for the former, all from April 2026.

Company eligibility for enterprise management incentives is to be expanded from April 2026

Some good news that tax benefits on employee car ownership schemes will remain until April 2030.

Other

Further anti-avoidance measures targeting promoters of tax avoidance schemes and tax advisers who facilitate non-compliance are to be introduced. All tax advisers who interact with HMRC on behalf of clients will need to be registered by May 2026 and meet minimum standards. 

All private jet passengers to pay double the rate of air passenger duty from 2027.

Here is our summary of the strategic implications and the planning opportunities you need to action now.

Three Headline Themes That Matter:

1. Exits are more expensive  Higher Capital Gains Tax (CGT) rates, and the narrowing of reliefs (BADR, Investors’ Relief) make business sales a higher-cost affair. Exit planning is no longer a last-minute calculation; it’s a non-negotiable risk management exercise.
2. Wealth planning is shifting to a residence. The abolition of the remittance basis and the introduction of a new residence-based Inheritance Tax (IHT) system from 6 April 2025 means your tax position is now primarily dictated by where you live, not your domicile.
3. Property and “passive balance sheets” are under pressure.  Property is subject to higher Stamp Duty Land Tax (SDLT) friction, and reforms to Business Property Relief (BPR) and Agricultural Property Relief (APR) signal that "passive balance sheets" are squarely in the Treasury’s sights.

Key Planning Opportunities for UK Business Owners

If your goal is a valuable, saleable business, the Budget reinforces five high-leverage moves that should be on your "do this next" list:

Exit-Readiness Health Check

If you are 12–36 months from a sale, you must re-check your trading status to protect critical reliefs. Audit your balance sheet immediately to clean up surplus cash, property, and non-core assets that could taint your relief eligibility.

Deal-Structure Modelling

Model all potential exit routes—Share Sale vs. Asset Sale, Earn-out vs. upfront consideration, and the reformed Employee Ownership Trust (EOT) route. The tax cost of a straight share sale has increased dramatically, making these alternatives more compelling.

Founder Remuneration Strategy

With CGT rates climbing from 20% to 24%, the historical “salary/dividends/capital” mix is no longer optimal. We need to revisit your entire remuneration strategy to maximise efficiency.

 IHT & Succession

With BPR/APR reforms coming in April 2026, succession planning for founders is no longer "set and forget." Audit your business's relievable status and align shareholder agreements, wills, and succession plans to the new commercial and tax reality.

Property Structure Review If you use a "holdco + opco + propertyco" structure, this is your cue to review whether it remains the optimal, tax-efficient vehicle given the new SDLT rates and the pressure on passive assets.

Strategic Moves for Internationally Mobile UHNWIs

The most profound change is the non-dom reform. For internationally mobile families and UHNWIs, a critical planning window is now open:

• Re-map Residency Timelines: The new 4-year Foreign Income and Gains (FIG) regime is a significant opportunity for new UK arrivals. We can help you re-map residency to maximise the tax-free window for foreign income and gains.
• Trust Governance & Substance: The shift to a residence-based system requires all trusts and holding structures to be reviewed. We must ensure your governance, decision-making, and "substance" are robust and defensible against future HMRC scrutiny.
• Asset Realisation Timing: Consider whether significant asset realisations should occur before UK residence begins, or specifically within the new 4-year FIG window.

Why Guernsey is the Solution for UK Residents

For UK residents who are considering an international move, the new residence-based regime makes Guernsey's position as a robust financial centre and a desirable place to live even more compelling.

Guernsey offers:

• A Tax-Efficient Jurisdiction: For those moving to Guernsey, the new UK non-dom reforms highlight the immense value of a clean, well-governed, and tax-neutral jurisdiction like Guernsey for managing international wealth and succession.
• A Clear Regime for UK Ties: While Channel Islands residents with UK interests (property, UK workdays, family ties) will face more focus on residence and documentation, Guernsey's position allows for clear planning. We can help you create a "UK exposure map" to ensure all UK-situs assets, income streams, and workdays are properly documented, making your planning defensible.
• Lifestyle and Stability: Beyond the fiscal benefits, Guernsey offers political and economic stability, a high quality of life, and a straightforward tax regime for residents, making it an attractive destination for those seeking a change of residence.

The new rules create a decisive break from the past. The planning window for the most generous outcomes is short. If you are considering a move from the UK, now is the time to act.

Schedule a Call with us to discuss how we can help you.