UK Autumn Budget 2025 – Corporates

The key announcements for corporates are as follows:

• Corporation Tax – rates remain unchanged – 25% main rate (19% for profits up to GBP50,000 and a sliding scale between GBP50,000 and GBP250,000).
  
  
• Stamp Duty Reserve Tax Relief – to boost the London Stock Market from 27 November 2025 agreements to transfer securities of a company whose shares are newly-listed on a UK regulated market will be exempt from the 0.5% SDRT charge for the first three years after listing.
  
  
• Enterprise Management Incentive (EMI) Share Options – from April 2026 the employee limit and the company share option limit will both double to 500 employees and GBP6 million respectively, and the gross assets test will quadruple to GBP120 million. The maximum holding period will also be increased to 15 years (and this can be applied to existing as well as new EMI options).
  
  
• Enterprise Investment Scheme and VCT – also from April 2026 key limits will be increased substantially: maximum gross assets from GBP15 million pre-investment and GBP16 million post-investment to GBP30 million and GBP35 million respectively. A company’s annual limits on investment (GBP10 million for “knowledge intensive” businesses and GBP5 million for others) will be doubled to GBP20 million and GBP10 million respectively, as will the company’s lifetime limit (GBP20 million to GBP40 million for knowledge intensive businesses and GBP12 million to GBP24 million for others), but the income tax relief for VCT income will be reduced to 20% from 30%).
  
  
• Capital Allowances – from April 2026 writing down allowances for “main pool” plant and machinery will be reduced from 18% to 14%, but a new first year allowance of 40% will be introduced (in addition to the Annual Investment Allowance on the first GBP1 million). For companies, full expensing for new plant and machinery (excluding cars and leased assets) continues.
  
  
• Employee Ownership Trusts – the CGT relief on sales to EOTs is reduced from 100% to 50% with immediate effect.
  
  
• Transfer Pricing, Permanent Establishment and Diverted Profits Tax – following extensive consultation legislation has been published to amend the UK’s transfer pricing and permanent establishment rules, and replacing the ‘diverted profits tax’, all with the intention of simplifying the UK’s international tax rules or aligning them more closely with obligations under double tax treaties.
  
  
• Business Rates – there is a proposed reduction in rates for retail hospitality and leisure (RHL) premises worth GBP500 or less partly funded by an increase in rates for non-RHL premises with a value in excess of GBP500 million (both changes from April 2026).
  
  
• Cryptoassets –
  • As announced, the government will introduce legislation in the Finance Bill 2025-26 requiring UK Reporting Cryptoasset Service Providers to report on their UK tax resident customers under the Crypto Asset Reporting Framework (this is in addition to reporting on non-UK tax resident customers which is already required under CARF). First reports to HMRC are required by 31 May 2027 for information collected from 1 January 2026 to 31 December 2026.
  • The government has published a summary of responses to the consultation on the taxation of decentralised finance (DeFi) involving the lending and staking of crypto assets. The document also sets out a potential approach that the government is considering.
    
    
• Key Personal and Employee Tax measures –
  • Income tax thresholds will be frozen at their current levels until at least the end of fiscal year 2030/31, a year longer than expected.
  • Personal income tax rates will be increased by 2% in the case of property, savings and (save for additional rate taxpayers) dividend income. In the latter case, the rise will apply from April 2026, whilst the other increases will not come into effect until 2027.
  • National insurance will be imposed on pension contributions in excess of GBP2,000 per year made by way of “salary sacrifice” from 2029.
    
    
• Indirect Taxes –
  • Remote Gaming Duty is to be increased from 21% to 40% (from April 2026) and General Betting Duty on remote (online) betting from 15% to 25% (from April 2027).
  • The GBP135 low value imports exemption from Customs Duty is to be removed no later than 2029.
  • A new annual duty will be introduced for EV drivers, imposed on a mileage basis (at 3p a mile for true EVs and 1.5p a mile for plug in hybrids).
  • A vaping products duty will be introduced from 1 October 2026.
    
    
• High Value Residential Property – a council tax surcharge (of GBP2,500 to GBP7,500) will be imposed on homes worth over GBP2 million from 2028.
  
  
• Key Consultations – results published –
  • Oil and Gas Price Mechanism – consultation (when the energy price levy ceases the government wants to put in place a mechanism to address future price shocks).
  • Advance Certainty for Major Projects – effectively a tax clearance/ advance assurance service for major projects.

Entrepreneurship in the UK – a policy paper, but with a linked call for evidence on taxation and entrepreneurship.

Should you have any queries on the UK Autumn Budget, please reach out to your usual UK tax contact or the following: