Modernising the distributions framework (response):
The Government will proceed with all seven proposals though these have been modified where appropriate to reflect the evidence received during the consultation, including to ensure the continued attractiveness of the UK as a global financial centre. We are working through the new proposals, although some detail on the possible targeted reliefs is not available. The Government intends to carry out a full technical consultation on the draft legislation in 2027 and for the changes to apply prospectively from April 2028, following completion of the technical consultation.
Founders’ Relief (new):
Founders’ Relief will allow for a reduced 10% rate of CGT on qualifying disposals, up to a lifetime cap of £10 million. The limit will apply per individual, so more than one individual could claim in respect of the same company. The relief will apply for qualifying disposals made on or after 6 April 2027. This consultation seeks views on how the proposed individual, company and growth and innovation conditions will work in practice. It also covers administrative and compliance considerations. Responses are sought by 30 November 2026.
Sovereign immunity (new):
From 1 January 2029, the current non-codified sovereign immunity from direct tax regime will be modernised with a new sovereign tax status. Under this new regime, foreign sovereigns will be primarily brought into the charge to UK tax on certain UK real estate income and gains but given bespoke access to the Real Estate Investment Trust regime with provision for a 15% rate on income and gains from both controlled and uncontrolled UK real estate investments. Investment management activities undertaken by sovereign investment offices and gains arising to State-operated Overseas Pension Funds will also be exempt from tax. Comments are sought by 20 January 2027.
Corporate Tax Simplification for Business Investment (new):
This consultation identifies areas of the Corporate Tax system where targeted simplification could improve certainty and support investment, growth and competitiveness. The Government will work with stakeholders over the next year to develop and prioritise reforms.
Predevelopment costs (response):
In its response to the consultation published in July 2026 , the Government has committed to providing greater clarity on the current tax treatment of predevelopment costs. It will explore whether further changes to guidance can be made via the work on Corporate Tax Simplification for Business Investment, including more worked examples, clearer principles and improved apportionment rules to simplify the process of determining whether capital expenditure is eligible for capital allowances and provide more certainty for businesses. If necessary, the Government will explore legislative changes to provide more certainty and clarity for businesses.
Tax Support for Entrepreneurs (response):
As part of its response, the Government has promised to legislate in Finance Bill 2026-27 for a package of targeted changes across SEIS, EIS and VCTs with the aim of making the schemes simpler, more consistent and easier to operate. As far as R&D claims are concerned the Government will remove the R&D Claim Notification Form requirement for claims made on or after 1 April 2027, and, from Autumn 2027, simplify the Additional Information Form (AIF).