Mary Schofield

The tax position of a sale of a trading business to an EOT suffered a blow when the Chancellor introduced capital gains tax (CGT) on 50% of gains arising on or after 26 November 2026. Given the main rate of CGT is 24% and the terms of business asset disposal relief (BADR) are much less favourable than once they were, a sale to an EOT can still be a tax efficient route where the transaction is commercially justified.

EMI share options remain popular with start-up and entrepreneurial trading businesses through providing tax efficient remuneration to employees.

‘National Payroll Week’ runs from 1st - 5th of September 2025 and is a celebration of those individuals who help to get the nation paid on time.

Capital gains tax seems certain to be more onerous after the forthcoming Budget, says Mary Schofield.

The Chancellor should use her Autumn Budget to make off-payroll working rules 'fairer and more effective', according to the Association of Independent Professionals and the Self-Employed (IPSE).

The introduction of the new merged R&D tax relief scheme from 1 April 2024 has attempted to clarify the rules surrounding subcontracting expenditure.

As the number of companies benefiting from the Research and Development (R&D) Tax Credit system has grown, so have HMRC's efforts to prevent erroneous claims.

As part of the Autumn budget the Chancellor, Rachel Reeves announced that the government would “abolish the non-dom tax regime and remove the outdated concept of domicile from the tax system”.

Changes to capital allowances rules have for many years been a prominent feature of the annual announcements from the Chancellor, generating endless rate changes and transitional measures. These yoyoing rules and thresholds have made it particularly difficult for businesses to plan tax efficiently for capital expenditure.

Last week, HMRC published their draft rules and restrictions on contracted-out R&D and overseas workers. Overseas expenditure draft guidance has remained relatively similar to its original however there has been some significant and promising changes to contracted-out R&D compared to previous communications from HMRC.

HMRC is currently scrutinising claims for R&D tax relief, following increased media attention and parliament focus. The government has recently made its first steps towards reforming the R&D tax relief scheme, but the biggest changes are due to come into force on 8 August 2023.

The UK government has announced that they are going to issue a consultation on the use and effectiveness of Employee Ownership Trusts (EOTs). The focus seems to be ensuring these are primarily being used to incentivise employees.

For UK start-ups and small enterprises, the Chancellor significantly reduced R&D Tax Credits in his Autumn Statement.

As an employer, there are various ways to remunerate your team. Increasing salary may be enough to retain some staff whilst others want a ‘slice of the action’. Company share schemes are an increasingly common way to incentivise employees, and there are various different ways to achieve this, depending on your requirements, and theirs.