One minute with Tahir Ebrahim, Partner in BDO’s Private Wealth Team.
What’s keeping you busy at work?
The run up to the new tax year starting on 6 April 2025 was the busiest of my career! With the abolition of the concept of non-UK domicile for tax purposes, there was a lot to think about and advise clients on.
If you could make one change to tax, what would it be?
Simplifying the tax system is crucial. But if I could make only one change, it would be to the proposed reforms to the IHT reliefs available for business and agricultural property. While the APR changes have received attention, the BPR changes and their impact are not getting the publicity they should. These changes will have significant impact on many businesses and will alter the way owners think about the future, which will be to the detriment of the UK economy in the long run. Research by Family Business UK indicates that because of these changes more than 200,000 jobs will be lost by the end of this Parliament.
What do you know now that you wish you’d known at the start of your career?
I have learnt the most from situations where things have not gone to plan or where I have made mistakes. My advice to my younger self is to not be afraid of making those mistakes where ‘playing it safe’ seems like the easier route.
Are there any new rules that are causing a particular problem?
The announced BPR changes are already leading to changes in behaviours. Some business owners are not expecting to own and run the business for as long as they were expecting to, and others are assessing options to move their businesses out of the UK. Businesses that were expecting to be passed down the generations are now evaluating whether this is possible/desirable where a large tax bill will need to be funded on death. This seems contrary to what the Government wants to achieve in encouraging economic growth and stimulating entrepreneurship.
Has a recent tax case caught your eye?
Unfortunately, some of my international clients have taken steps to leave the UK in recent months. The advice I have been giving in this context includes their UK tax residence status. For this reason, A Taxpayer v HMRC [2025] EWCA Civ 106which concerned the application of exceptional circumstances for days of presence has been fascinating, in particular, in seeing HMRC’s view and stance on these matters. It has also come in handy when advising clients as they can see how HMRC approach these matters.
What are clients asking about?
The dominant conversation is around what actions clients should be taking now before 6 April 2026 (when the BPR changes are expected to take effect). We have certainty on the current rules and it is a great time to reconsider succession plans to ensure they remain fit for purpose, take advantage of existing unlimited BPR to transfer assets into trusts, etc.
One positive from the announcement of these changes is that it has forced business owners to proactively address the question of succession, as simply holding onto assets until death and passing them on will no longer be an effective IHT strategy.
You might not know this about me but...
I was born and brought up in Southern Africa. Understanding what it is like to uproot your entire life gives me a rare perspective on many things, including motivation to help others, adaptability in the face of a shifting landscape and helping clients who have only ever lived here to leave the UK. I also feel that it gives me a very international yet grounded outlook in personal and professional life.
One minute with Tahir Ebrahim, Partner in BDO’s Private Wealth Team.
What’s keeping you busy at work?
The run up to the new tax year starting on 6 April 2025 was the busiest of my career! With the abolition of the concept of non-UK domicile for tax purposes, there was a lot to think about and advise clients on.
If you could make one change to tax, what would it be?
Simplifying the tax system is crucial. But if I could make only one change, it would be to the proposed reforms to the IHT reliefs available for business and agricultural property. While the APR changes have received attention, the BPR changes and their impact are not getting the publicity they should. These changes will have significant impact on many businesses and will alter the way owners think about the future, which will be to the detriment of the UK economy in the long run. Research by Family Business UK indicates that because of these changes more than 200,000 jobs will be lost by the end of this Parliament.
What do you know now that you wish you’d known at the start of your career?
I have learnt the most from situations where things have not gone to plan or where I have made mistakes. My advice to my younger self is to not be afraid of making those mistakes where ‘playing it safe’ seems like the easier route.
Are there any new rules that are causing a particular problem?
The announced BPR changes are already leading to changes in behaviours. Some business owners are not expecting to own and run the business for as long as they were expecting to, and others are assessing options to move their businesses out of the UK. Businesses that were expecting to be passed down the generations are now evaluating whether this is possible/desirable where a large tax bill will need to be funded on death. This seems contrary to what the Government wants to achieve in encouraging economic growth and stimulating entrepreneurship.
Has a recent tax case caught your eye?
Unfortunately, some of my international clients have taken steps to leave the UK in recent months. The advice I have been giving in this context includes their UK tax residence status. For this reason, A Taxpayer v HMRC [2025] EWCA Civ 106which concerned the application of exceptional circumstances for days of presence has been fascinating, in particular, in seeing HMRC’s view and stance on these matters. It has also come in handy when advising clients as they can see how HMRC approach these matters.
What are clients asking about?
The dominant conversation is around what actions clients should be taking now before 6 April 2026 (when the BPR changes are expected to take effect). We have certainty on the current rules and it is a great time to reconsider succession plans to ensure they remain fit for purpose, take advantage of existing unlimited BPR to transfer assets into trusts, etc.
One positive from the announcement of these changes is that it has forced business owners to proactively address the question of succession, as simply holding onto assets until death and passing them on will no longer be an effective IHT strategy.
You might not know this about me but...
I was born and brought up in Southern Africa. Understanding what it is like to uproot your entire life gives me a rare perspective on many things, including motivation to help others, adaptability in the face of a shifting landscape and helping clients who have only ever lived here to leave the UK. I also feel that it gives me a very international yet grounded outlook in personal and professional life.
