Author: Glenn

Thinking of transferring your sole trader or partnership business into a limited company? Incorporation Relief can help defer any capital gains tax on assets like goodwill. If the entire business is transferred in exchange for shares, the relief applies automatically, no claim needed. Make sure you understand the rules and deadlines, especially if you plan to opt out.

When a sole trader or partnership transfers their business into a company, a capital gain may arise. The gain is based on the market value of the business assets (including goodwill) at the time of incorporation, compared to their original cost.

However, businesses incorporated in this way may qualify for Incorporation Relief. To benefit from this relief, the entire business, along with all its assets (excluding cash, if applicable), must be transferred as a going concern in exchange, wholly or partly, for shares in the new company.

Incorporation Relief is automatic if the conditions are met. There is no need to submit a claim. The relief defers the capital gain by reducing the base cost of the new shares by the amount of the deferred gain, effectively postponing any tax until the shares are sold.

Although the relief applies automatically, a taxpayer can elect for it not to apply. This must be done in writing, and the election must be submitted by 31 January, two years after the end of the tax year in which the incorporation occurred. For example, for a transfer in the current 2025–26 tax year, the election deadline is 31 January 2029. The election deadline is reduced by one year if the shares are disposed of in the year following that in which the business was incorporated.

From 6 April 2025, the remittance basis for non-doms is abolished. A new UK tax regime now applies to non-domiciled individuals, focused solely on residence. New arrivals can benefit from a 4-year exemption on foreign income and gains, but action is needed. CGT rebasing, Overseas Workday Relief, and a limited-time 12%–15% repatriation facility could all offer planning opportunities. Review your position now.

Since 6 April 2025, significant changes to the UK tax status for non-UK domiciled individuals have come into force. The remittance basis of taxation has been abolished, and a simplified, residence-based regime is now in place. This marks a fundamental shift in how foreign income and gains (FIG) are taxed for individuals living in the UK.

Under the new system, a 4-year FIG regime has been introduced. Individuals newly arriving in the UK, who have not been UK tax residents in the previous ten consecutive years, can claim 100% tax relief on their foreign income and gains for their first four years of UK residence.

To ease the transition, Capital Gains Tax (CGT) rebasing is available. Those who previously used the remittance basis may rebase personally held foreign assets to their 5 April 2017 value, subject to conditions.

Overseas Workday Relief has also been extended to a four-year term, matching the FIG regime. From now on, this relief no longer requires employment income to remain offshore.

A Temporary Repatriation Facility (TRF) has also been launched. Running for three years from April 2025, it allows individuals taxed under the old remittance rules to bring in pre-reform foreign income and gains at reduced tax rates—12% for the first two years and 15% in the final year. This includes income and gains held in trust structures that were previously untaxed.

Parents of 16–19-year-olds: confirm your child’s continued education or training by 31 August 2025 to keep Child Benefit payments going. Last year, over 870,000 families updated HMRC, most online. It only takes a few minutes and helps avoid missed payments. If your child is still in approved education, act now to stay on track.

Taxpayers entitled to the child benefit should be aware that HMRC usually stop paying child benefit on the 31 August following a child’s 16th Birthday. Under qualifying circumstances, the child benefit payment can continue until a child reaches their 20th birthday if they stay in approved education or training. This must be confirmed to HMRC, or payments will stop.

Approved education must be full-time, with more than 12 hours per week of supervised study or course-related work experience. Approved education includes A levels, T levels, Scottish Highers, NVQs up to Level 3, home education (if started before 16 or after 16 with special educational needs), study programmes in England, and pre-apprenticeships. The course must be started before the child turns 19.

Child Benefit cannot be claimed if your child is:

• Studying for a university degree or BTEC Higher National Certificate (advanced course).
• On an apprenticeship (unless it’s a Foundation Apprenticeship in Wales).
• Undertaking a course with an employer’s agreement (e.g., to secure a job or gain skills for an existing job).

Approved training should be unpaid and can include:

• Wales: Foundation Apprenticeships, Traineeships, or the Jobs Growth Wales+ scheme.
• Scotland: The No One Left Behind programme.
• Northern Ireland: PEACEPLUS Youth Programme 3.2, Training for Success, or Skills for Life and Work.

Courses that are part of a job contract are not approved.

HMRC sends a letter in your child’s last year at school asking you to confirm their plans. The letters include a QR code which, when scanned, directs them straight to GOV.UK to update their claim quickly and easily online. This can also be done on the HMRC app.

Parents have until 31 August 2025 to tell HMRC that their 16-year-old is continuing their education or training, in order to continue receiving Child Benefit. No child benefit is payable after a young person reaches the age of 20 years.

Child Benefit is paid at a weekly rate of £26.05 for the only or eldest child, and £17.25 for each additional child. However, families where either parent earns over £60,000 a year may be affected by the High Income Child Benefit Charge (HICBC). This means they may have to pay back some or all of the benefit through their income tax return. If income exceeds £80,000, the full amount of Child Benefit must be repaid. Families can still choose to receive the benefit and pay the charge or opt out of receiving payments to avoid the charge altogether.

From April 2025, Agricultural Property Relief from Inheritance Tax now extends to land under qualifying environmental agreements. This means landowners entering long-term stewardship schemes will not lose IHT relief. From April 2026, a new £1 million limit will apply to combined APR and BPR claims—making timely planning more important than ever.

Agricultural Property Relief (APR) is a relief from Inheritance Tax (IHT) that reduces the taxable value of agricultural land and property when it is passed on, either during a person’s lifetime or after death. It allows up to 100% relief on qualifying agricultural land used for farming.

The scope of APR was extended from 6 April 2025 to land managed under an environmental agreement with, or on behalf of, the UK government, devolved governments, public bodies, local authorities, or relevant approved responsible bodies. This expansion of the relief helps to better support environmental land management without penalising landowners for switching from farming to environmental use.

The new rules will benefit individuals, estates, and personal representatives where agricultural land is shifted to long-term environmental use under formal agreements. Previously, land removed from active farming for environmental schemes could have lost eligibility for APR.

From 6 April 2026, broader reforms to Agricultural Property Relief and Business Property Relief are set to take effect. While relief of up to 100% will still be available, it will apply only to the first £1 million of combined agricultural and business property. Beyond that threshold, the relief will be reduced to 50%.

Running more than one self-employed business? HMRC will not always treat them as separate. Whether they are taxed as one combined trade or multiple depends on how your activities relate to each other. It is not a matter of choice, it is about how your business is run in practice. Get it right to avoid costly mistakes.

When someone has more than one self-employed income, one of the key issues to consider is whether to combine all profits under a single business activity or treat each separately. This depends on the nature and relationship of the activities. HMRC’s manuals set out three possible scenarios:

1. Separate Trades

If the new activity is run independently, with different staff, stock, or customers, it is treated as a separate trade. This means each business is taxed individually, and the commencement rules apply to the new one. No merging takes place unless operations later combine in substance.

2. A New Single Trade

If the new activity transforms the original business significantly, so much so that the old trade effectively ends, then both are treated as forming a new trade. The cessation rules apply to the original trade, and commencement rules apply to the new, combined business.

3. Continuation of Existing Trade

If the new activity merely expands the existing business without fundamentally changing its nature, it is treated as a continuation. Profits are combined and taxed as one ongoing trade, with no change in basis.

Understanding whether activities form one trade or multiple is crucial for correct tax treatment. It’s not just a matter of choice. It also depends on the facts and how the businesses operate and interact.

We would be happy to help you review the structure of your business to ensure compliance with HMRC guidance and avoid unexpected tax consequences.