Why April 2026 more urgent than ever?

Tax structuring is most effective when started well in advance of a liquidity event. It is typically recommended for the entrepreneurs to begin planning at least 2 years before exit.

Key reasons include:

• Clarity on exposure – Understanding how your shareholdings will be taxed, including base cost history and eligibility for reliefs.
• Flexibility – Preserving the option to de-risk (bank some cash) versus reinvesting in a new structure – potentially rolling over an element of gain and deferring the tax.
• Improving the tax costs on exit – Corporate structures such as holding companies (PICs or FICs discussed below) together with HMRC clearance applications can support a smoother transaction from your current venture to the next.
• Team motivation – Reviewing and refining share option schemes to ensure alignment at exit.
• Philanthropy – Timing charitable donations to optimise position – obtaining relief from both capital gains tax as well as gift aid on the value of any shares donated to a UK registered charity.

April 2026: The “cliff edge” for Business Property Relief (BPR)

One of the most powerful planning tools currently available to entrepreneurs involves transferring shares into a trust while they still qualify for Business Property Relief (BPR). This allows unlimited value to be settled into trust without immediate inheritance tax charges, provided the shares qualify.

Trust structuring remains highly beneficial for a number of reasons. Trusts can allow the senior generations to retain control of assets such as shares in the family business, but without them being exposed to the 40% IHT charge on death. In addition, trusts:

• provide long-term governance and succession planning;
• ring-fence family assets for future generations;
• protect wealth in the event of divorce or creditor claims; and
• deliver controlled access to capital for designated beneficiaries such as children and/or grandchildren.

However, this opportunity to put unlimited business assets into trust will end on 5 April 2026. From that date, the BPR rules change — and the ability to transfer unlimited shares into trust free of inheritance tax will disappear. For many business owners, this could mean inheritance tax charges running into many millions of pounds that could otherwise have been avoided.

Residence and your relocation Strategy

Where you plan to live and work after exit is equally important. If you remain UK resident, your worldwide gains will be taxed here. If you relocate abroad, your gains may cease to be subject to UK tax although there are a number of pitfalls to be aware of.

Where a non-resident retains ongoing links to the UK — such as board roles or frequent visits — these need to be carefully mapped against the UK’s various taxing provisions. Early analysis can avoid unwelcome surprises later.

The end of “non-dom” story.

Another major change took place earlier in the year. Since 6 April 2025, exposure to UK tax is now determined solely by residence — not by domicile.

Previously, non-UK domiciled individuals could shelter non-UK income gains from UK income tax and capital gains tax. That opportunity, including associated planning, such as the use of protected trusts has now been abolished.

However, there are now Inheritance Tax mitigating opportunities for any UK domiciled entrepreneurs who plan to emigrate, which weren’t present previously and any ex-pats in this position should be reviewing their planning – particularly if they have family in the UK who are set to inherit wealth.

Corporate structuring options

For some shareholders, introducing a new holding company — subject to HMRC clearance — can create tax efficiencies. In certain circumstances, this may allow access to the Substantial Shareholding Exemption (a relief that can make certain corporate sales free of tax at the company level) and support tax-free exits, as well as potentially mitigating future UK inheritance tax.

Similarly, Family Investment Companies (FICs) and Personal Investment Companies (PICs) remain valuable vehicles for post-exit wealth management. They allow wealth to be preserved and grown in a
controlled, flexible, and tax-efficient way.