Corporate Tax Winter Update - 2026 Virtual Conference

Introduction

With the Autumn Budget 2026 shaping client conversations and the 5 April 2027 tax year end approaching, accountants in practice need clear and workable answers on what to advise next. Leading tax specialists who deal with these questions every day will give you the practical detail you need to advise clients.

Topics include guiding owner managers through exits and profit extraction, structuring reorganisations that stand up to HMRC scrutiny and handling R&D claims under the merged regime with confidence. You will also hear how to respond when HMRC opens an enquiry or raises a discovery assessment.

Practical guidance on spotting risk early, building stronger evidence and having the right conversations with clients before problems arise, so you can put what you learn into practice straight away.

Conference Agenda

This live and interactive 5-hour conference will cover the following:

10am-11am: Section 137 TCGA 1992: Commercial Purpose, Clearances & HMRC Challenge in Practice

Philip Ridgway, Temple Tax Chambers

This session provides a focused and practical examination of Section 137 TCGA 1992 and its role in determining whether share exchanges and corporate reorganisations qualify for tax neutral treatment. It will explore HMRC’s current approach to the commercial purpose test, the types of transactions that most commonly attract scrutiny, and the evidential standards expected in clearance applications.

It is designed to equip accountants in practice with clear, actionable guidance to help them identify risk early, structure transactions effectively and support clients through reorganisations in the post Budget environment.

Learning Outcomes:

• Evaluate how HMRC applies the commercial purpose test and identify features that increase the likelihood of challenge under Section 137
• Recognise common pitfalls in share exchanges and reorganisations that can undermine tax neutral treatment
• Apply best practice approaches to preparing clearance applications and evidencing commercial purpose in client transactions

Morning Break

11:10am-12:10pm: Exit Planning for Owner-Managed Businesses After the Autumn Budget 2026: Trade Sales, Buyouts & Employee Ownership Trusts

Nick Wright, Jerroms Miller

With CGT on business disposals already higher and the Autumn Budget due on 28 October, owner-managers are asking whether to sell, wind up or hand over the business and whether to act before 5 April 2027.

This session sets out the main exit routes and compares their tax outcomes in light of the Budget announcements. It looks at trade sales, buyouts and Employee Ownership Trusts, with a focus on Business Asset Disposal Relief, timing and the points that most often go wrong.

It also covers the legal and commercial issues advisers should raise early, such as deal structure, warranties and deferred consideration. The aim is to give advisers a clear framework for steering clients to the right exit route at the right time.

What It Will Cover:

• The main exit routes (trade sale, buyouts and EOT) and how their tax outcomes compare
• The impact of the Autumn Budget 2026 and recent CGT changes, including timing around 5 April 2027
• Business Asset Disposal Relief and the conditions most often missed
• Practical deal points that affect the tax result, such as deferred and contingent consideration
• The questions advisers should ask clients early and the common pitfalls

Break for lunch

12:10pm-1:10pm: Profit Extraction & Share Planning for Owner-Managed Businesses: Alphabet Shares, Growth Shares & Family Investment Companies

Nick Wright, Jerroms Miller

Owner-managed businesses face recurring questions on how to extract profits efficiently and how to structure share capital for family members, key employees and long-term wealth planning.

This session examines the main profit extraction routes and compares their tax outcomes, before turning to share-based planning. It covers alphabet shares and the settlements legislation, growth shares and the employment-related securities rules and the use of Family Investment Companies as a vehicle for surplus profits and succession.

The session is practical in focus, highlighting where HMRC challenge arises and the planning points advisers should raise with clients.

Learning Outcomes:

• Compare the tax cost of salary, dividends and other extraction routes and identify when each is appropriate
• Recognise the settlements and employment-related securities risks in alphabet and growth share structures and how to mitigate them
• Understand when a Family Investment Company is suitable, how it is typically structured and funded and the key tax points on setup and operation

Break for lunch

2-3pm: HMRC Enforcement & Discovery: Current Risks & Practical Responses

Waqar Shah, Partner, Kingsley Napley LLP

HMRC's approach to enforcement and discovery has become notably more aggressive, with increased use of discovery assessments, wider information requests and a lower threshold for challenging positions that would previously have gone unchecked.

This session looks at where HMRC is currently focusing its enforcement activity, the practical risks this creates for clients and their advisers and how best to respond when a discovery assessment or enquiry lands.

Drawing on recent cases and current HMRC practice, the session will set out practical steps accountants, tax advisers, or in-house tax teams can take to manage risk before and during an enquiry.

By the end of this session, delegates will:

• Understand HMRC's current enforcement priorities and the areas attracting the greatest scrutiny
• Recognise the circumstances in which a discovery assessment can validly be raised and the common grounds for challenge
• Be able to identify practical steps to reduce risk before an enquiry begins
• Gain practical guidance on managing client responses once an enquiry or discovery assessment has been raised

Afternoon break

3:15-4:15pm: R&D Tax Relief: Navigating the Merged Schemes, Managing Risk & Delivering Value

Jennifer Tragner, S&W

This session offers practical guidance to help advisers operate confidently within the reformed R&D tax relief regime. It will cover key complexities arising from recent legislative changes, including assessing R&D intensity, interpreting contractual arrangements and determining when overseas R&D activity can qualify, alongside the administrative requirements for submitting valid claims.

With HMRC applying significantly greater scrutiny on R&D claims, the risk profile for advisers has increased. The session will explore how to manage that risk effectively, focusing on claim methodologies, evidence requirements and delivering value to clients in a more challenging compliance environment.

Learning Outcomes:

• Greater understanding of the major recent changes to R&D tax relief
• Awareness of common complexities and where to find useful guidance
• More confidence in managing risk and evidence requirements for HMRC compliance

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.