PCD Leeds Conference | Panel 1 | 3 March 2026 | Aspire, Leeds

The first panel of the day set about tackling a question that has dominated the private client world for the past two years: what does it mean to be a business owner in the current tax environment, and how are advisers helping clients navigate the consequences? Chaired by Ken Chapman, the session brought together Chris Etherington and James Atkinson from RSM with Chelsea Martin and Suzannah Farnell, both partners in the family business team at Wrigleys Solicitors. The result was one of the most practically grounded conversations of the conference.

Accelerated Decisions in an Uncertain Climate

Suzannah Farnell opened with a clear picture of the trends she has been observing on the ground. Business owners are making decisions faster — often faster than they planned or wanted to. "We've definitely seen accelerated succession planning," she said, describing clients passing businesses to the next generation sooner than anticipated, others putting structures into trust ahead of legislative changes, and a segment of ultra-high net worth clients actively considering or completing offshore relocations. It is, she suggested, a landscape defined by urgency and a sense of uncertainty.

James Atkinson offered the M&A perspective. After a strong post-COVID peak in 2021 and 2022, the deals market entered a fallow period through 2023 and into early 2024 — a period characterised less by clean exits and more by alternative structures such as employee ownership trusts, management buy-outs, and sales to family members. Since then, momentum has returned. "There's more conversation about exit events this year than there has been over the past eighteen months," he said, noting that the sentiment is evident not just among business owners but across the advisory community. 

Etherington put that upturn in context. Going back further, he recalled the panic around Business Asset Disposal Relief — then still known as Entrepreneurs' Relief — during COVID, when every rumour threatened its curtailment. The fallow period that followed was in part a product of that anxiety, with owners exploring debt-funded deals, employee ownership structures, and internal sales. Now, with more owners having worked through those options and with a recovery in deal activity, exits are once again the conversation. But the tax backdrop remains punishing, and the planning complexity has only increased.

The Art of the Exit: Timing, Wills, and Pre-Sale Planning

One of the panel's most practical threads concerned timing. When asked how long before an exit advisers would ideally like to be involved, there was broad consensus around twelve months as the sweet spot — enough time to engage tax, legal, corporate finance, and financial planning advisers, align their work, and address any structural issues in the business before a sale process begins. James Atkinson was candid about what that window allows: getting management information in order, reducing concentration risk — whether in a key customer, individual, or supplier — and ultimately presenting a business that tells a compelling, clean story to a buyer.

Chelsea Martin and Suzannah Farnell pressed into the legal and structural dimensions of pre-sale planning with notable depth. Wills, they emphasised, are not an afterthought — they are a live document in the run-up to any significant liquidity event. For business owners, the shift from qualifying trading assets to cash at the point of sale represents a material change in inheritance tax exposure, and wills need to reflect that shift. Letters of wishes, too, require review: clients who have earmarked business assets for specific family members may have very different wishes once those assets become liquid. Executors and trustees named in a will drafted years earlier may no longer be appropriate post-sale. "I have been instructed on a couple of occasions where there has been a death pre-sale that was unexpected," Martin noted, "and it caused a lot of problems."

The panel explored pre-sale trust planning extensively, including its increasing limitations. The October 2024 budget introduced a £2.5 million per-person allowance for Business Property Relief — transferable between spouses, though the precise conditions for that transfer remain without formal legislative guidance. From April 2026, value above that threshold will attract an effective IHT rate of 20% rather than the current full exemption. For a couple, this means a combined £5 million of qualifying assets can still be sheltered at 100% relief — but the clock is ticking on structures that were designed for a different regime. "We are somewhat advising in the dark," Chelsea Martin observed, "but we are doing our best."

FICs, EOTs, and the Risk of the Tax Tail Wagging the Dog

Family investment companies drew measured enthusiasm from the panel. Etherington acknowledged their appeal — particularly for business owners more comfortable with corporate structures than trusts — but cautioned against treating them as a default solution. Used in the context of a trading business likely to seek external investment or PE backing in the future, a fragmented FIC structure can create significant complexity around earnouts and rollover arrangements. "You've got to make sure you're not letting the tax tail wag the dog," he said. "It's not necessarily the answer for a trading group."

Employee ownership trusts received a nuanced assessment. Once a highly popular vehicle during the M&A fallow period, their cost to the Exchequer had — partly through the profession's own success in promoting them — grown far beyond Treasury estimates, reaching approximately £2 billion a year by the time the budget arrived. The subsequent curtailment of the relief was, Etherington suggested, more likely to be motivated by the Treasury’s review of its estimated cost to the Exchequer, rather than from a considered policy review. "EOT tax reliefs were likely to come under the Treasury spotlight for savings as soon as their cost crossed the £1bn threshold," he said. EOTs remain viable for clients pursuing them for the right reasons — genuine employee ownership, not primarily tax efficiency — but they are no longer the reflex answer they once were.

Enterprise Investment Scheme reliefs attracted more straightforward enthusiasm. Etherington made the case that EIS and SEIS are not solely vehicles for passive investors — founders reinvesting proceeds into a new venture can structure their involvement to achieve zero tax on a future sale. For serial entrepreneurs, the ability to defer capital gains tax through EIS, or to qualify for full relief on a new qualifying trade, remains a powerful tool. The consultation currently underway on encouraging entrepreneurial behaviour may, he hoped, build on these reliefs further.

Collaboration as the New Normal

Perhaps the most consistent theme running through the session was the shift in how advisers work together. Suzannah Farnell spoke of a meaningfully closer collaboration across legal, tax, corporate finance, and wealth management than at any previous point in her career — a necessity born of the pace and volume of change. Etherington echoed this, pointing to a deal the previous week in which issues with a business owner's desire to relocate to Dubai had only surfaced the day before completion. "We really didn't want to be having that conversation at that stage but collaboration between the various advisers helped to resolve it," he said.

The message to clients — and to the advisers in the room — was clear: the earlier all parties are seated at the table, the better the outcome. With HMRC clearance applications taking longer, pre-sale restructuring windows tightening, and the legislative landscape still shifting, the luxury of last-minute planning no longer exists. In a period defined by upheaval, the profession's most effective response has been, above all, to talk to one another.