Autumn Budget 2026 · Selling and succession

What did the Budget change for selling my company to an employee ownership trust?

The capital gains tax relief on a sale to an employee ownership trust decides what the owner keeps from an EOT exit. This page shows the position after the Budget for a £3m engineering firm selling a controlling stake in 2027.

By Alan Davidson | Last updated

A worked example

The owner sells 100% of the company to an employee ownership trust for £3 million in 2027: the same price as the trade sale on the selling your business page, so the two compare. The shares cost next to nothing, the owner's other income uses up the basic rate band, so the taxed gain is all at 24%, and every condition for the relief is met.

Sale to the trust in 2027Before the BudgetAfter the BudgetDifference
Gain£3,000,000.00£3,000,000.00
Chargeable: 50% of the gain£1,500,000.00£1,500,000.00
Less the £3,000 annual exempt amount, taxed at 24%£1,497,000.00£1,497,000.00
Capital gains tax£359,280.00£359,280.00£0.00
Kept from the £3 million£2,640,720.00£2,640,720.00£0.00
Held over: reduces the trustees' base cost£1,500,000.00£1,500,000.00

Business Asset Disposal Relief cannot be claimed with the trust relief, so its new £500,000 limit does not touch this sale. It does change the trade sale on the selling your business page, from 6 April 2027:

£3 million sale from 6 April 2027Before the BudgetAfter the BudgetDifference
Trade sale with BADR£659,280.00£689,280.00+£30,000.00
Sale to an employee ownership trust£359,280.00£359,280.00£0.00
Gap between the two£300,000.00£330,000.00+£30,000.00

A trade sale made before 6 April 2027 is still under the £1 million BADR limit, so for that sale the gap stays at £300,000.

Separately, from 6 April 2027 a company arranging to become controlled by an employee ownership trust keeps access to EMI share options for its staff, as companies already controlled by one do.

When it takes effect

The trust relief is unchanged, so nothing new starts for it. The BADR limit applies to disposals from 6 April 2027, and the EMI change also starts on 6 April 2027.

Who it doesn't affect

An owner already selling, or planning to sell, to an employee ownership trust pays capital gains tax as before: the Budget did not change the trust relief or the 18% and 24% rates.

Where this comes from

Every figure on this page comes from the Budget documents published on GOV.UK on , and was checked by Alan Davidson FCA. Last updated . It is general information, not advice on your own position.