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| 4 minute read

Smorgasbord not showstopper: the UK Budget 2025

The November 2025 budget is here at last. During the months of speculation in the run-up to the big day, two possible futures emerged: a slate of headline-grabbing tax rises, or a broad range of narrower, targeted measures. Today the Chancellor opted firmly for the latter: offering a long list of changes to reliefs, new anti-avoidance rules and a sharpening of HMRC's administrative powers.

For many businesses, this will feel like continuity rather than a significant rupture. But buried in the detail are some significant changes for corporates and particular sectors, and a clear signal that more pressure will come through HMRC administration and enforcement rather than big rate increases.

Corporate taxes 

For corporates, the Budget largely represents a confirmation of the existing tax environment: headline rates have been left untouched, but there are some significant moves in the background rules. One of the flagship corporate reforms is a package to recast the UK rules on transfer pricing, permanent establishments and Diverted Profits Tax, with legislation in Finance Bill 2025-26 to apply from 1 January 2026. The stated aim is simplification and businesses should expect this to be an important rewrite of core UK international tax provisions. 

On the transactions side, the government will “modernise” the capital gains anti-avoidance rules for share exchanges and company reorganisations with immediate effect. The current rule focuses on the overall purpose of a reorganisation. The revised rule will more precisely target situations where, as part of a genuine commercial exchange or company reconstruction, additional arrangements have been introduced to secure a tax advantage. There is grandfathering of the current version of section 137 Taxation of Chargeable Gains Act 1992 for clearance applications received by HMRC before 26 November if certain conditions are satisfied.

There is also an intention to enhance the existing regime for uncertain tax treatments, with consultation in early 2026 on strengthening the notification rules for large businesses. In another targeted move, the government will also introduce a new anti avoidance rule denying tax relief for amounts arising from securitisation arrangements that depend on non-derecognition of transferred assets and related liabilities where a main purpose is to secure a tax advantage. 

On capital allowances, the Budget introduces a new 40% first year allowance for main rate expenditure, including most leased assets and spending by unincorporated businesses, from 1 January 2026, coupled with a reduction in main rate writing down allowances from 18% to 14% from April 2026, effectively front-loading relief while trimming the ongoing annual deduction. Finally, there is a new three-year exemption from Stamp Duty Reserve Tax for companies listing in the UK: see our post on that here

Sector specific taxes

The Chancellor has also announced certain tax measures that will have outsize impacts on particular industries.

British betting and gaming firms will have to brace for increased gambling duties. From April 2026, remote gaming duty will almost double from 21% to 40%. From April 2027, general betting duty of 25% will apply to remote betting, subject to some exclusions. These duties will exceed the standard rate of VAT (from which betting and gaming are exempt). There will be no changes for in-person betting or horse-racing, and bingo duty will be abolished. 

Despite extensive lobbying, the Energy Profits Levy was not mentioned in the Chancellor’s Budget speech and the windfall tax on oil and gas will remain in place until March 2030. However, the end of this windfall tax could still be brought forward if oil and gas prices were to fall below a certain level for two consecutive quarters. The government will commence engagement immediately on the draft legislation and implementation of the oil and gas price mechanism, to ensure the regime is ready to operate if required, and to consider the potential impacts of an early end to the EPL due to falling prices.

The “SHEIN” loophole will be closed for overseas retailers. Low value import relief will be axed, which means that packages worth less than £135 will no longer be sent to the UK free of customs duties.

The Tour Operators’ Margin Scheme will no longer be available for private-hire bookings. This means that companies like Uber and Bolt will no longer enjoy reduced VAT liabilities (and passengers will very likely see increased costs).

Business rates will be lowered for retail, hospitality, and leisure properties. Film studios will enjoy a one-year extension to their 40% business rates relief. And there will be 100% business rates relief for EV charging points for the next decade. However, properties with rateable values of £500,000 or more will be subject to higher multipliers set at 2.8p above the national standard multiplier (being 48p). UK airports will also see some transitional relief, with the increase to their business rates capped at 30% for the next year.

Tax administration

The other major theme of the Budget is tax administration, where we can see both a “carrot” and “stick” approach to the collection of taxes, including corporation tax. On the “carrot” side, HMRC will be able to pay significantly higher rewards to informants in high value cases, with the potential for a payment to the informant of up to 30 per cent of additional tax recovered where over £1.5 million is at stake.

More “sticks” come in to play from 1 April 2026. Finance Bill 2025-26 will double corporation tax late filing penalties, introduce enhanced powers and sanctions targeted at tax advisers who facilitate non-compliance, and pave the way for a modernised behavioural penalties regime for inaccuracies and failures to notify. New rules will also oblige taxpayers to correct known inaccuracies in returns, with the process to begin by a consultation on draft legislation in 2026.

Promoters and serious offenders remain in the crosshairs. New powers against promoters of marketed avoidance will be legislated for in Finance Bill 2025-26, followed by a further consultation on additional measures in early 2026. The government is also considering a new “recklessness” criminal offence for fraudulent evasion of direct taxes, to align with existing indirect tax offences. One interesting related development is the dropping of proposals for the formal regulation of tax advisers, with the government instead preferring to "work in partnership with the sector to raise standards in the tax advice market."

So for corporates, the overall message is stability on headline corporation tax policy coupled with a steady ratcheting up of enforcement, penalties and accountability. The real Budget story may sit in how, and how aggressively, HMRC will expect businesses and their advisers to manage risk and respond when things do go wrong.

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slaughterandmay, nhourihan, pfollan, uk tax, transfer pricing, capital allowances, oil and gas, gambling duties