The UK Chancellor of the Exchequer, Rachel Reeves, has delivered the Autumn Budget 2025.

In her much-anticipated second Budget, the Chancellor announced a broad spectrum of tax measures which she said were designed both to secure public finances and make the UK tax system fairer. After much press speculation, rumours and reported U-turns, there is now some welcome clarity on how the government intends to balance the books, with the largest revenue raising measure being a stealth tax increase through the freezing of income tax thresholds. Outside of the headline grabbing measures, the government has published details on new and ongoing business tax reform measures, a number of which will be included in the upcoming Finance Bill.

In our latest podcast, Josh Critchlow speaks to May Smith, Emily Szasz and Sam Withnall from our London tax team about the smorgasbord of business tax measures they found most noteworthy in the Autumn Budget 2025, including:

• headline tax revenue raising measures including extending the freeze on income tax/NICs thresholds and raising income tax rates on dividend, savings and property income;
• the introduction of a new ‘UK listing relief’ from SDRT, providing a 3 year exemption from the 0.5% SDRT charge on agreements to transfer securities of newly listed companies on a UK regulated market;
• confirmation that an ‘Advance Tax Certainty Service’ for major investment projects in the UK will be launched in July 2026;
• changes to the capital allowances regime, including a new 40% first-year allowance and reduction of writing down allowances for main rate expenditure;
• broadening an anti-avoidance rule applicable to capital gains rollover relief on share exchanges and reorganisations;
• an update on proposals to reform behavioural tax penalties;
• revisions to the UK VAT grouping rules applicable to overseas establishments;
• confirmation that a permanent revenue-based oil and gas price mechanism will take effect on expiry of the existing Energy Profits Levy;
• additional measures to tackle tax avoidance; and
• measures not included in the Budget announcements, including the rumoured ‘partnership NICs’ and exit tax.

The second Trump administration has made numerous announcements on trade and tariffs, but US tax policy is increasingly woven into the discussion on international trade. This includes the possibility of retaliatory US action against “discriminatory or extraterritorial taxes” imposed by other countries.

The US House Budget Reconciliation Bill, officially titled the “One Big Beautiful Bill Act", was recently passed by the House of Representatives and includes retaliatory US tax measures in response to “unfair foreign taxes” - with digital services taxes (DSTs) and the undertaxed profits rule (UTPR) of the Pillar 2 global minimum tax regime expressly identified as falling in this category.

In our latest podcast US tax expert Claude Stansbury, UK tax expert Emily Szasz and international trade expert Lorand Bartels join Josh Critchlow to discuss the latest on this intersection of US tax and trade policy, including:

• details of the measures in new proposed section 899 of the US tax code (including increased withholding tax rates), the impact the measures could have on multinational groups with US operations, the interaction of section 899 with double tax treaties, and when these measures could take effect;
• a deeper dive into the taxes considered to be "unfair foreign taxes" and which countries may be in-scope of proposed section 899;
• previous use of US trade measures in response to tax rules imposed by other countries and how the proposed retaliatory tax measures fit into the rapidly evolving international trade landscape; and
• possible next steps, including:
• what actions may be taken at an OECD/EU level to address US concerns in respect of the identified "unfair" taxes; and
• whether proposed section 899 could itself be subject to challenge under trade laws.

Note: this podcast was recorded on 30 May 2025 and does not cover developments after this date.