At the general level, there were no changes to corporation tax rates or the rates of incentive for research and development (R&D) spend, but there was a reduction announced to the writing down allowance (WDA) main rate. The Budget announced a reduction to the WDA main rate from 18% to 14% from April 2026, alongside a new 40% first-year allowance from January 2026. This is expected to raise £1.5 billion in 2029-30. This measure changes the capital allowance rates, for both corporation tax paying companies and unincorporated businesses in the self-assessment regime, on expenditure that does not claim full expensing.
The Government will pilot a targeted advance assurance service from spring 2026, enabling small and medium-sized enterprises to gain clarity on key aspects of their R&D tax relief claims before submitting to HMRC.
The Government will legislate in Finance Bill 2025-26 to simplify the taxation of related party transactions, non-resident companies trading in the UK and profits diverted from the UK, for chargeable periods beginning on or after 1 January 2026. This measure will simplify the UK transfer pricing rules in a number of areas, including the participation condition, intangibles, commissioners’ sanctions, UK-to-UK transfer pricing, financial transactions and interpretation, in accordance with Organisation for Economic Co-operation and Development (OECD) principles.
It will also look to bring the UK’s permanent establishment rules in line with the latest international consensus on the definition of a permanent establishment and allocation of profits to a permanent establishment. In addition, it will update the legislation and Statement of Practice on the Investment Manager Exemption and introduce a new way for a UK-resident company to claim relief where a transfer pricing adjustment is made to a connected foreign company that relates to a UK permanent establishment.
The legislation also creates a new charging provision for unassessed transfer pricing profits within Corporation Tax. This repeals the diverted profits tax, which is currently a standalone tax, in its entirety, whilst retaining the essential features of the regime.
The Government will legislate to require in-scope multinationals to submit an International Controlled Transaction Schedule (ICTS), which will report information annually on cross-border related party transactions. This measure is expected to take effect for accounting periods beginning on or after 1 January 2027. Technical consultation on its design will take place in spring 2026.
There will be technical amendments to the UK’s Pillar Two legislation to incorporate the latest published international updates and the Government will work with stakeholders to explore targeted legislative changes aimed at ensuring the qualifying asset holding company (QAHC) regime continues to operate effectively. Any legislative changes will be introduced in a future Finance Bill.
There are to be changes clarifying the tax treatment of payments made between group companies in return for either surrendered Research and Development Expenditure Credit (RDEC), Audio-Visual Expenditure Credit (AVEC) or Video Games Expenditure Credit (VGEC). There will also be an update to the transitional rules between Video Games Tax Relief and VGEC.
There will also be legislation in Finance Bill 2025-26 to simplify administration in relation to reporting companies under the corporate interest restriction (CIR) regime. Most of the changes take effect for periods ending on or after 31 March 2026. There will also be technical amendments to CIR in respect of relief for certain capital expenditure. These changes take effect for periods ending on or after 31 December 2021.
In another simplification measure, the Government will legislate through statutory instrument to repeal the shadow advance corporation tax (ACT) rules with effect from 1 April 2026 and will consult on the future of the remaining ACT regime in early 2026.
The Government will also legislate in Finance Bill 2025-26 for the payment of interest on amounts collected from taxpayers and now repayable following a successful challenge to the State Aid application to the financing rules in the UK’s controlled foreign companies regime.
In terms of anti-avoidance, the Government will modernise the anti-avoidance provisions that apply to share exchanges and company reorganisations with immediate effect and introduce a new anti-avoidance provision from the same time relating to certain arrangements where there is a non-derecognition liability (particularly aimed at arrangements avoiding a charge under section 455 CTA 2010). This will take effect from 26 November 2025.
There will be changes to the eligibility criteria for the Enterprise Management Incentives (EMI) rules to allow scale-ups, as well as start-ups, to access the scheme from 6 April 2026. The Venture Capital Trust (VCT) scheme and the Enterprise Investment Scheme (EIS) annual and lifetime investment limits and the gross assets test from 6 April 2026 will be increased, but there will be a reduction in the VCT scheme income tax relief from 6 April 2026.
The Government has also launched a Call for Evidence, seeking views on the effectiveness of existing tax incentives, and the wider tax system, for business founders and scaling firms, and how the UK can better support these companies to start, scale and stay in the UK. The Call for Evidence will close on 28 February 2026.
The Government has confirmed that the ‘Advance Tax Certainty Service’ (ATCS) will launch in July 2026 and provide clearances on corporation tax, stamp taxes, VAT, PAYE and the construction industry scheme, where there is no existing statutory route to certainty. The financial threshold will be set at £1 billion over the lifetime of the project. The Government will review the service after it has been in operation for one year, including to assess whether it will be possible to increase capacity and lower the financial threshold.