Autumn Budget 2025 — Employee Ownership Trust capital gains tax changes explained

We explore the Chancellor’s decision to change the capital gains tax (CGT) relief available for disposals to Employee Ownership Trusts (EOTs).
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Our specialist tax lawyers solve complex issues related to corporate transactions, M&A, private equity investments, international matters & HMRC disputes.
Whether you’re navigating complex corporate transactions, managing cross-border exposure or facing HMRC scrutiny, our multidisciplinary team provides clear, pragmatic advice that safeguards your position and helps to achieve your goals.
In our experience, complex tax problems are rarely solved by technical expertise alone — commerciality and judgement matter just as much. We speak the language of business, not just tax, with an approach that’s centred on clear communication and speedy resolution. The earlier we’re involved, the better the outcome.
We work with a wide range of clients, from corporates and private equity investors to owner-managed businesses and entrepreneurs, high-net-worth individuals and families, real estate investors and developers as well as anyone facing an investigation or dispute with HMRC.
Whether you’re concerned about making a structural decision, how to manage residence, domicile and double‑tax‑treaty interactions or any other tax issue, we’re here to help.
Talk to us today by calling 0333 004 4488, emailing hello@brabners.com or completing our contact form.

“Euri Yoon’s ability to explain sensitive and complex tax matters in clear, layman’s terms made a real difference. As an overseas company with UK operations, our questions covered a broad range of tax and operational issues, yet Euri responded promptly and thoroughly to both major and minor matters, with consistent follow-through.”
Finance Director, global biotech company
“We've worked with Brabners' corporate team [and] Sam Mabon for over ten years on all our acquisitions... The team understands our sector and the regulatory landscape, which is invaluable to mitigate risk and maximise ROI. The longstanding relationship means we know and trust that Brabners protects our interests while taking a commercial approach to negotiations. The team drives the transaction and ensures that it completes within the agreed timeframe.”
Legal & Regulatory Director, Chase de Vere
“NWF Group plc has worked with Rupert Gill and the wider team at Brabners for over 25 years. During that time, Brabners has worked on circa 40 corporate transactions for us, sometimes several in any given year. The knowledge that the team has gained of our businesses and how we operate has helped to smooth the acquisition process. Their use of standard documents and a reporting process that we know helps to reduce the management time involved.”
CEO, NWF Group plc
“We've worked with Brabners for more than five years on a number of major corporate, commercial and financing projects. Brabners helps us to identify and address relevant legal issues early. The team is proactive, pragmatic, commercial and works seamlessly with our in-house legal team and other advisers. Put simply, Brabners provides exemplary, cost-effective support.”
Richard May, Partner, General Counsel & Head of Compliance, Omni Partners
“Praised for its ability to go 'go above and beyond' and 'outstanding industry knowledge', Brabners... [handles] the full scope of corporate and commercial matters... Feedback from clients has always been favourable... consistently high-quality level of service.”
The Legal 500 2026

Working closely alongside our ‘top tier’ corporate team, our tax specialists help clients to navigate complex UK and international tax rules during transactions.
We’re often called on to manage the tax risk profile on M&A deals (especially cross‑border deals) — providing fast, commercially sound solutions that don’t ‘kill the deal’.
Our services include:

Amid increasing HMRC scrutiny, data matching and sophisticated investigation tools, many businesses are anxious about reputational risks, financial penalties and criminal exposure.
Part of our corporate defence and compliance team, our proactive tax disputes experts are here to make sure that you’re compliant and secure. However, if the worst happens, we’re known for our calm and strategic approach to handling HMRC investigations and high-stakes disputes.
We’ll guide you throughout the lifecycle of a tax investigation with minimal disruption and represent you during civil and criminal HMRC enquiries.

Our team is led by Solicitor, Chartered Tax Advisor (CTA) and Associate Chartered Management Accountant (ACMA) Euri Yoon. A specialist in corporate and commercial tax, Euri advises on complex and often cross-border M&A work as well as private equity transactions, corporate reorganisations and more. She offers a rare combination of expertise in legal, tax and accounting as well as vast experience from her days at Samsung, British Airways and City and international law firms.
Andy Horsfield leads our tax disputes practice. He has acted in some of the most complex VAT and tax dispute matters in the UK and brings significant experience within Big Four and major advisory roles. With an established track record of resolving high value HMRC disputes efficiently, Andy is an essential contact for anyone facing regulatory scrutiny.
We’re proud members of the Chartered Institute of Taxation (CIOT) and the Chartered Institute of Management Accountants (CIMA).
Multinational companies
Provided cross border tax, social security and employment structuring advice to multinational companies, delivered in close coordination with legal teams in other jurisdictions.
Landfill site acquisition
Advised on the acquisition of a landfill site, acting for the buyer on the tax aspects of the transaction. Work included preparing and negotiating a bespoke tax provisions including landfill tax, environmental taxes and restoration-related liabilities.
Regulated water services business
Advised on the acquisition of a regulated water services business supporting industrial and infrastructure operations across strategic transport and logistics assets.
UK-Hong Kong consolidation
Advised a founder-led business on UK-Hong Kong consolidation prior to external investment.
Multi‑party land and leasing structure
Provided SDLT and VAT planning advice on a multi‑party land and leasing structure for a complex development.
EMI option re-alignment
Guided a company through a complex EMI option re-alignment after a share reorganisation, preserving tax advantages while resetting management equity to agreed commercial outcomes.
Complex VAT dispute
Successfully resolving a complex VAT dispute involving multi-entity supply chains.

We explore the Chancellor’s decision to change the capital gains tax (CGT) relief available for disposals to Employee Ownership Trusts (EOTs).
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Here, Steven Appleton from our estate planning team and Amy Harris from our family law team explain the options available to family business owners, including sensible steps to take to secure your estate from future divorce or separation.
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Discover 3 expert strategies from our Brabners Personal estate planning lawyers to help family business owners minimise the financial impact of upcoming inheritance tax changes.
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Our lawyers reflect on the key trends from 2024 and look ahead to predict what 2025 may look like in the world of mergers and acquisition.
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Our Brabners Personal team explain how the Autumn Budget affects business owners — including six key steps to take now to ensure that your assets pass on in-line with your wishes and goals.
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Our Brabners Personal lawyers explain how the Autumn Budget affects high-net-worth individuals — from inheritance tax changes to the use of offshore trusts.
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Nationally recognised dental practice sale expert Nicola Lomas offers five key reasons why now might be the right time for you to incorporate.
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Our private client law team explore the proposed changes to the non-dom regime and how they could impact sportspeople.
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