Lee Nuttall
Partner
Head of UK Tax and Head of Private Funds
Article
2
We have had to look hard for the stand-outs on the taxing side. But there are a few.
There's welcome confirmation that the 'business tax road map' is to be retained and implemented, including (of course) reducing the corporation tax rate to 17%. Stability and certainty is key here.
Building out from the Finance Act 2016 tax rules brought in for non-resident developers/traders in UK land, it looks like any non-resident company with UK-source income will be brought into the UK corporation tax net.
There's welcome news for pension funds and other exempt investors in authorised investment funds (AIFs): on receipt of dividends, they will be able to obtain credit for tax paid by the AIF - but not yet.
We expected the abolition of tax advantages associated with Employee Shareholder Status - this is a good scheme in theory, but misused in practice.
It is disappointing that, in a speech that acknowledged the UK's housing challenge and paucity of housing supply, the Chancellor did not reduce the SDLT surcharge on those institutional and other large investors who are looking to increase supply in the housing rental market. I hope that the new Housing White Paper will take a broader view of the fiscal barriers (including the surcharge) to increasing supply in this market.
NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.
Gowling WLG is an international law firm comprising the members of Gowling WLG International Limited, an English Company Limited by Guarantee, and their respective affiliates. Each member and affiliate is an autonomous and independent entity. Gowling WLG International Limited promotes, facilitates and co-ordinates the activities of its members but does not itself provide services to clients. Our structure is explained in more detail on our Legal Information page.
© 2026 Gowling WLG All rights reserved.