Tax Planning for High Net Worth Individuals: A Strategic Guide

HMRC delivered £24.2 billion in compliance yield in the first nine months of 2025 to 2026, against a full-year target of £50.4 billion (GOV.UK, 2026). The government has committed to recruiting an additional 5,500 compliance caseworkers over the next five years to deliver £10 billion of additional tax revenue per year by 2029 to 2030 (GOV.UK, 2026). For high net worth individuals, the April 2026 tax changes affect inheritance planning, investment taxation, and business structuring.

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This guide sets out what changed and the actions available in response.

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The 2026 tax landscape for wealthy individuals

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The Office for Budget Responsibility forecasts capital taxes as a share of GDP will rise from 1.4% in 2024-25 to 2.3% in 2030-31, a 64% increase over six years and the largest forecast rise of any tax group (Interactive Investor, 2026). The total Capital Gains Tax take for the year to January 2026 was £20.6 billion, a 44% increase on the same period the previous year (Interactive Investor, 2026).

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From 1 April 2026, new powers came into force allowing HMRC to investigate and penalise advisers suspected of "sanctionable conduct", meaning intentionally helping clients to pay less tax than they owe (CIOT, 2026). These powers apply to advisers involved in tax planning high net worth individuals undertake.

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Inheritance tax

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From 6 April 2026, a £2.5 million combined cap applies to 100% relief under Agricultural Property Relief and Business Property Relief. Value above the cap qualifies for 50% relief, producing an effective inheritance tax rate of 20% on the excess. The £2.5 million allowance is transferable between spouses and civil partners. AIM shares now qualify for 50% relief only, regardless of value, and sit outside the £2.5 million allowance.

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Actions available

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Commission a current professional valuation of the estate to establish whether assets sit above or below the £2.5 million cap.

Review existing wills against the new transferable £2.5 million allowance to confirm both spouses' or civil partners' allowances can be used.

Reassess any AIM-based inheritance tax planning against the 50% relief rate.

Reviewing existing wealth protection tax strategies against these rule changes is one of the available next steps.

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Investment tax

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From 6 April 2026, the following changes took effect:

Dividend tax rates rose by 2% at the ordinary and upper rates, to 10.75% and 35.75% respectively.

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The Capital Gains Tax rate on disposals qualifying for Business Asset Disposal Relief or Investors' Relief rose from 14% to 18%.

Income tax relief on Venture Capital Trust subscriptions reduced from 30% to 20%.

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Actions available

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For director-shareholders, review the balance between salary, dividend, and pension contribution against the new dividend rates.

Recalculate the after-tax return on VCT investments under the 20% relief rate.

Confirm full use of ISA and pension annual allowances, which form part of standard wealth protection tax strategies.

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In early 2026, HMRC's Wealthy and Mid-Sized Business Compliance Team began writing to taxpayers who had claimed Investors' Relief in their 2024/25 self-assessment returns. The letters ask recipients to review their claim and either provide supporting information or amend their return within 30 days. Where no amendment is made and HMRC takes the view that the claim is incorrect, a compliance check may follow.

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Business structuring

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From 6 April 2026, incorporation relief is no longer automatic. It must be actively claimed on the self-assessment return for the tax year in which the incorporation took place. From the same date, the main rate of writing-down allowance for plant and machinery reduced from 18% to 14%.

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Actions available

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Where an incorporation has taken place in the 2026/27 tax year, ensure the relief is actively claimed on the self-assessment return.

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For businesses with significant plant and machinery expenditure, recalculate capital allowance projections under the 14% rate.

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For existing trusts, family investment companies, or holding structures, an HNW tax advisor can review the structure against the expanded HMRC powers that took effect on 1 April 2026 (CIOT, 2026).

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Summary

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The April 2026 changes affect inheritance, investment, and structuring decisions for high net worth individuals. A current, documented assessment of exposure across all three areas supports any further tax planning high net worth individuals undertake under the new rules.

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Speak to a specialist

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WTT works with high net worth individuals to assess exposure across inheritance, investment, and business structures, and to produce documented tax plans aligned with current HMRC requirements. Contact us today on +44(0)20 3468 0000 or info@wttconsulting.co.uk for a confidential review.

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References

Chartered Institute of Taxation. (2026). HMRC Stakeholder Digest – 1 May 2026. https://www.tax.org.uk/hmrc-stakeholder-digest-1-may-2026

GOV.UK. (2026).

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HMRC Performance Update 2025 to 2026: Quarter 3. HM Revenue & Customs. https://www.gov.uk/government/publications/hmrc-performance-update-october-to-december-2025/hmrc-performance-update-2025-to-2026-quarter-3

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Interactive Investor. (2026). Spring Statement 2026: IHT and CGT receipts to soar by 2031. https://www.ii.co.uk/analysis-commentary/spring-statement-2026-iht-and-cgt-receipts-soar-2031-ii538325

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