The Finance Act 2026: what actually changed, and what it means for promoters
A close reading of the year's tax legislation, written for the people who have to live with it.
Every Finance Act produces a flood of commentary in its first week. Most of it ages badly. Our practice is to wait a month, read the memorandum twice, and then write a partner's view that we are willing to stand behind for the rest of the year.
This year's Act is, on balance, a quiet one. There are no new rate brackets, no surprises on capital gains, and no rewrite of the search-and-seizure machinery. What it does do — and this is where promoters should pay attention — is rewire several long-standing provisions on holding structures and capital gains on slump sales.
The changes are not flashy. They are foundational. Read together with the prior year's amendments, they signal a deliberate move toward consolidating the tax base around economic substance, not legal form. For any promoter sitting on a multi-layered holding structure, this is the year to commission a fresh structure paper.