Site icon Steve J Bicknell Tel 01202 025252

Family Investment Companies: Are They Still Worth It in 2026?

Steve Bicknell
family-investment-company-fic-tax-inheritance-tax
Print đź–¨

How FICs Can Help Families Hold Property and Investments, Pass Wealth to Future Generations and Plan for Inheritance Tax

By Steve Bicknell FCMA, CGMA

A Family Investment Company can be a powerful way of holding family wealth, investing for the long term and passing future growth to children and grandchildren while the older generation retains control.

But a FIC is not a magic tax-saving company.

There is no special statutory definition of a Family Investment Company (FIC). It is normally a private limited company specifically structured to hold family investments, with different family members or trusts owning different classes of shares.

Those shares can have different rights to:

HMRC itself investigated Family Investment Companies through a specialist unit established in 2019. Its conclusion was significant: HMRC found no evidence that people establishing FICs were more inclined towards avoidance or non-compliance. HMRC subsequently closed the dedicated unit and moved FICs into “business as usual” compliance activity.

So what exactly is a Family Investment Company, how does it work, and is a FIC still worth considering in 2026?

Family Investment Company – Quick Answer

A FIC can be particularly useful where a family has substantial wealth to invest and wants to:

RETAIN CONTROL

while allowing:

CHILDREN OR GRANDCHILDREN TO BENEFIT FROM FUTURE GROWTH

and potentially:

REDUCE FUTURE INHERITANCE TAX EXPOSURE.

A typical FIC might have:

Control or founder shares
held by parents or grandparents

and:

Growth shares
held by adult children, other family members or possibly trusts.

The company might invest in:

But there is an important point:

A FIC IS GENERALLY MORE ATTRACTIVE FOR LONG-TERM WEALTH ACCUMULATION THAN FOR REGULARLY EXTRACTING ALL THE PROFITS.

Once profits are extracted from the company, a second layer of personal taxation may arise.

What Is a Family Investment Company?

A FIC is normally a UK private company whose shareholders are members of the same family, sometimes across several generations.

Interestingly, HMRC does not have a statutory definition of a FIC.

During its own research, however, HMRC identified several common characteristics:

That is a useful description of how many FICs work in practice.

What Does HMRC Think About Family Investment Companies?

This is particularly interesting because HMRC actually set up a dedicated unit to investigate them.

HMRC’s Family Investment Company Unit

HMRC established a specialist Family Investment Company team in April 2019.

Its purpose was to improve HMRC’s understanding of FICs, establish their common characteristics, examine the wealth profile of the families using them and identify potential tax risks.

HMRC carried out detailed reviews of FICs together with their:

Some FICs were also contacted directly as part of the research.

HMRC published its findings in the minutes of its Wealthy External Stakeholders Forum on 13 May 2021.

And its conclusion was particularly important.

HMRC said:

“there was no evidence to suggest that there was a correlation between those who establish a FIC structure and non-compliant behaviours.”

It also reported no evidence suggesting that people using FICs were more inclined towards avoidance.

That does not mean HMRC has formally “approved” FICs.

It does mean HMRC’s dedicated investigation did not conclude that using a Family Investment Company was, in itself, indicative of tax avoidance or non-compliance.

What Did HMRC Find FICs Were Being Used For?

HMRC found that FICs appeared primarily to be used as a:

GENERATIONAL WEALTH TRANSFER STRATEGY

often with the objective of mitigating future Inheritance Tax.

HMRC also recognised that there was considerable diversity in the way FICs were structured.

And that creates potential tax issues across several taxes, including:

INHERITANCE TAX

CAPITAL GAINS TAX

STAMP DUTY LAND TAX

CORPORATION TAX.

So HMRC’s conclusion wasn’t:

“There are no tax risks with FICs.”

It was much more nuanced.

The structure itself isn’t inherently avoidance, but the individual transactions within the structure still have to comply with the tax rules.

What Happened to HMRC’s Specialist FIC Unit?

Having completed its research, HMRC closed the dedicated FIC team.

Its work was absorbed into HMRC’s wider Wealthy and Mid-sized Business Compliance activity.

HMRC’s conclusion was that FICs would thereafter be considered:

“AS BUSINESS AS USUAL”

rather than requiring a dedicated specialist unit.

I think that’s probably the best way of understanding HMRC’s position.

A FIC isn’t automatically an avoidance scheme.

But neither does calling something a “Family Investment Company” give it special tax protection.

HMRC LOOKS AT WHAT THE FIC ACTUALLY DOES — NOT SIMPLY WHAT IT IS CALLED.

How Does a Family Investment Company Work?

Let’s use a completely fictional example.

David and Emma Taylor have accumulated substantial savings and investments.

They have two adult children:

Alex and Sophie.

They want to invest for the long term, retain control of the family wealth and allow the next generation to participate in future growth.

They establish:

TAYLOR FAMILY INVESTMENTS LTD

The company might invest in:

Instead of everyone owning identical ordinary shares, the Articles of Association can create different classes of shares with different rights.

This enables the family to separate:

CONTROL

from:

ECONOMIC OWNERSHIP AND FUTURE GROWTH.

Control Shares and Growth Shares

Suppose Taylor Family Investments Ltd is initially worth:

ÂŁ100,000.

Its share structure might be designed so that:

A Shares – David and Emma

carry voting rights and control.

Their capital entitlement might broadly reflect or “freeze” the existing value.

B Shares – Alex

participate in future growth.

C Shares – Sophie

also participate in future growth.

Now suppose the company eventually becomes worth:

ÂŁ1,000,000.

The intention might be for much of the:

ÂŁ900,000 FUTURE GROWTH

to accrue to the B and C growth shares rather than David and Emma’s shares.

This is the principle behind:

FREEZER SHARES

and:

GROWTH SHARES.

How Can Growth Shares Help With Inheritance Tax?

Suppose instead David and Emma simply own 100% of an investment company throughout their lives.

If the company eventually becomes worth ÂŁ1 million, they potentially have:

ÂŁ1 MILLION OF SHARE VALUE

within their estates.

With a carefully structured FIC, the intention may be to fix or restrict the value attributable to the older generation while allowing subsequent growth to accrue to shares owned by the next generation.

The strategy is therefore often not:

GIVE AWAY EVERYTHING TODAY.

It is:

MOVE FUTURE GROWTH AWAY FROM THE OLDER GENERATION.

This can be attractive where parents or grandparents want to retain voting control but do not need all the future economic growth personally.

Valuation Is Critical

Growth shares aren’t simply a matter of creating a new class of shares and giving them a nominal value of £1.

The rights attached to shares have value.

That can include:

If an existing company is already valuable and its share rights are changed, value may effectively move between shareholders.

That can have consequences for:

CAPITAL GAINS TAX

and:

INHERITANCE TAX.

There can also be Employment Related Securities implications in appropriate circumstances.

This is why it is generally much easier to design the share structure before substantial value has accrued.

Funding a FIC – Loan or Shares?

This is one of the most important decisions when establishing a Family Investment Company.

Suppose David has:

ÂŁ1,000,000

to invest.

There are two fundamentally different ways he could provide it to the FIC.

Option 1 – Loan £1 Million to the FIC

David lends:

ÂŁ1,000,000

to Taylor Family Investments Ltd.

Initially the company’s balance sheet might broadly look like:

ÂŁ
Cash1,000,000
Loan due to David(1,000,000)
Net value before other itemsNil

The company can then invest the ÂŁ1 million.

An important feature of this approach is that the company owes David the money.

That means it can potentially repay his loan later without the repayment itself being a dividend.

This can provide considerable flexibility.

But there is an important IHT point:

THE ÂŁ1 MILLION LOAN STILL BELONGS TO DAVID.

Simply replacing ÂŁ1 million in a bank account with a ÂŁ1 million loan receivable does not remove ÂŁ1 million from his estate.

Option 2 – Subscribe £1 Million for Shares

Suppose instead David subscribes:

ÂŁ1,000,000

for shares.

The company now has ÂŁ1 million of assets without a corresponding ÂŁ1 million loan liability.

The shares therefore potentially have substantial value.

If David subsequently gives shares to his children or a trust, their value needs to be considered.

So:

LOAN FUNDING

and:

EQUITY FUNDING

can produce very different:

Can the FIC Loan Be Gifted Later?

Potentially.

Suppose David initially lends £1 million to the company because he isn’t certain how much capital he will need in retirement.

Five years later he concludes that he only needs ÂŁ400,000 returned.

He could consider gifting part of the remaining loan to adult children.

An outright gift to an individual can potentially be a:

POTENTIALLY EXEMPT TRANSFER

for Inheritance Tax.

If the donor survives seven years, the value of the gift can generally fall outside their estate, subject to the normal IHT rules.

This illustrates one of the attractions of loan funding:

YOU DON’T NECESSARILY HAVE TO MAKE EVERY SUCCESSION DECISION ON DAY ONE.

Can Children Own Shares in a FIC?

Yes, but there is an important distinction between:

ADULT CHILDREN

and:

MINOR CHILDREN.

Giving income-producing shares to minor children does not automatically move the tax liability on the income to them.

The settlements legislation can attribute income back to a parent where income is diverted to their minor child.

So a strategy based simply on:

“We’ll give shares to the children and use their tax allowances.”

needs very careful consideration.

Adult children are generally much more straightforward, although the ownership and rights must still be genuine.

What About Adult Children at University?

This can be interesting.

Suppose an adult child:

Dividends may potentially be taxed at relatively low personal rates depending on their overall income.

For 2026/27 the dividend rates are:

BandDividend rate
Basic10.75%
Higher35.75%
Additional39.35%

The dividend allowance remains ÂŁ500.

But selective dividends and different share classes need to be supported by genuine legal rights rather than simply changing distributions each year to whichever family member happens to have the lowest tax rate.

Do You Need a Trust as Well as a FIC?

Not necessarily.

Many FICs can operate with family members owning the shares directly.

A trust can, however, add flexibility where the family wants to provide for:

For example, a discretionary trust might own one class of growth shares for the benefit of a wider family group.

But trusts bring another layer of complexity, potentially including:

So:

A FIC DOES NOT AUTOMATICALLY NEED A TRUST.

FIC Only or FIC Plus Trust?

FIC onlyFIC + discretionary trust
Retain family controlYesYes
Adult childrenStraightforwardCan be beneficiaries
Future generationsLess flexiblePotentially more flexible
ComplexityModerateHigher
Trust administrationNoneYes
10-year IHT regimeNoPotentially yes
Specialist legal draftingImportantEssential

The decision should follow the family’s objectives rather than starting with the assumption that the most complicated structure must produce the best result.

How Is a Family Investment Company Taxed?

A FIC is subject to Corporation Tax.

But there is an important trap.

A FIC DOES NOT AUTOMATICALLY PAY 19% CORPORATION TAX.

A close investment-holding company is subject to the main Corporation Tax rate and cannot benefit from the small-profits rate or marginal relief.

HMRC specifically says that a close company simply holding investments such as a bank deposit can fall within the CIHC rules and be liable at the full Corporation Tax rate.

The main Corporation Tax rate is currently:

25%.

This is an important correction to older FIC illustrations that simply assumed 19% Corporation Tax.

The Close Investment-Holding Company Trap

Broadly, a close company is treated as a close investment-holding company unless it exists wholly or mainly for certain qualifying purposes, including:

A FIC principally holding:

may therefore be within the CIHC regime.

That needs to be included when comparing personal investment with investment through a FIC.

Property Family Investment Companies Can Be Different

There is an important exception for property investors.

A close company can fall outside the CIHC definition where it exists wholly or mainly to invest commercially in land which is, or is intended to be, let to unconnected persons.

That means a genuine commercial property investment FIC may potentially benefit from the normal Corporation Tax small-profits and marginal-relief rules, depending on its profits and associated companies.

But be careful with connected-party lettings.

If the property is let to connected family members or certain connected entities, the exclusion may not apply.

Already Own Other Companies? Watch Associated Companies

Many people considering a FIC already own:

The Corporation Tax thresholds can be divided according to the number of associated companies.

So adding a FIC can potentially affect the Corporation Tax position of companies you already own.

This needs modelling as part of the structure rather than looking at the FIC in isolation.

Dividends Received by a FIC

One potential attraction of a corporate investment structure is that many dividends received by UK companies fall within the corporate dividend exemption rules.

This can make a FIC attractive where investment income is going to be:

RETAINED

and:

REINVESTED

for many years.

That brings us to perhaps the most important tax issue with FICs.

The Double-Tax Problem – Getting Money Out

Suppose a FIC makes:

ÂŁ100,000

of taxable investment profit.

The company may first pay Corporation Tax.

If the remaining profit is then distributed to an individual shareholder, there may also be:

DIVIDEND TAX.

So it is misleading to compare:

25% Corporation Tax

with:

40% or 45% personal Income Tax

and conclude that the company must be better.

The proper comparison may involve:

CORPORATION TAX + TAX ON EXTRACTION.

This is why FICs can work particularly well where investment returns can be:

COMPOUNDED WITHIN THE COMPANY FOR THE LONG TERM.

If the shareholders intend to withdraw virtually all the profits every year, the result can look very different.

Dividend Tax Increased From April 2026

Extraction became slightly more expensive from 6 April 2026.

The ordinary dividend rate increased to:

10.75%

and the higher dividend rate to:

35.75%.

The additional rate remains:

39.35%.

This makes modelling the eventual extraction strategy even more important.

Property Income Tax Is Changing From April 2027

There is another reason property investors may increasingly compare personal ownership with companies.

From 6 April 2027, the government is introducing separate rates for property income in England, Wales and Northern Ireland:

Property income bandRate from April 2027
Basic22%
Higher42%
Additional47%

Residential finance-cost relief will also use the new 22% property basic rate.

That doesn’t mean:

“Everyone should put property into a FIC.”

The Corporation Tax and extraction consequences still need comparing.

But it makes the personal-versus-company calculation increasingly important.

Property FICs and Mortgage Interest

Individual landlords of residential property are subject to the Section 24 finance-cost restriction.

Companies are not subject to Section 24 in the same way.

A property FIC can therefore generally obtain a Corporation Tax deduction for qualifying finance costs, subject to the normal corporate rules.

For highly geared residential property investors, this can be an important distinction.

Should You Transfer Existing Properties Into a FIC?

This is where a potentially useful structure can become extremely expensive if implemented without first doing the calculations.

Suppose David and Emma already personally own a rental portfolio worth:

ÂŁ1.5 MILLION.

They decide to establish a FIC and transfer all the properties into it.

The transfer isn’t automatically tax-free simply because they own the company.

Potential taxes include:

CAPITAL GAINS TAX

for the individual owners

and:

STAMP DUTY LAND TAX

for the company.

The SDLT position can also be affected by connected-party market-value rules and residential-property surcharges.

So there is a fundamental difference between:

USING A FIC TO BUY FUTURE INVESTMENTS

and:

TRANSFERRING AN EXISTING PORTFOLIO INTO A FIC.

Calculate the entry taxes before moving anything.

Don’t Forget ATED

If a FIC owns UK residential property worth more than:

ÂŁ500,000

the Annual Tax on Enveloped Dwellings (ATED) rules need considering.

A property commercially let to an unconnected third party may qualify for relief so that no ATED charge is ultimately payable.

But a relief declaration return may still be required.

This is particularly relevant with the 1 April 2027 ATED revaluation, which may bring more company-owned residential properties within the regime.

Gifts of FIC Shares

Giving shares to a family member isn’t necessarily tax-free.

For Capital Gains Tax purposes, a gift to a connected person will normally involve market value.

That means a gain can arise even though:

NO MONEY CHANGES HANDS.

For Inheritance Tax, an outright gift to an individual is generally a Potentially Exempt Transfer.

If the donor survives seven years, the gift can generally fall outside their estate.

A transfer to a discretionary trust is different and can be an immediately chargeable lifetime transfer.

Again:

VALUATION MATTERS.

Gift With Reservation of Benefit

A common objective is to transfer economic value to the next generation while the older generation retains control.

But there is an important distinction between:

CONTROL

and:

CONTINUING TO ENJOY THE VALUE YOU SUPPOSEDLY GAVE AWAY.

If a parent gives away shares or value but continues to benefit from what was gifted, the Gift With Reservation of Benefit rules may potentially apply.

This is another reason why the rights attached to the various share classes and the actual payment of dividends need to match the intended structure.

Employment Related Securities

Another specialist area is the Employment Related Securities legislation.

This may need considering where shares are acquired by:

This is particularly relevant with growth shares and restricted share rights.

Family relationships can affect the analysis, but the point shouldn’t simply be ignored because everybody involved is related.

Advantages of a Family Investment Company

A properly structured FIC can potentially offer several advantages.

1. Retaining Control

Parents or grandparents can potentially retain voting control.

2. Passing Future Growth Down the Family

Growth shares can allow younger generations to participate in future increases in value.

3. Inheritance Tax Planning

Future growth may potentially accrue outside the older generation’s estates.

4. Flexible Share Classes

Voting, income and capital rights can be separated.

5. Long-Term Corporate Reinvestment

Profits can be retained and reinvested rather than necessarily being distributed every year.

6. Loan Account Flexibility

Initial funding provided by loan can potentially be repaid without the repayment itself being a dividend.

7. Property Finance Costs

A company is not subject to the residential Section 24 restriction in the same way as an individual landlord.

8. Succession

A FIC can potentially provide a structure capable of continuing across several generations.

Disadvantages of a Family Investment Company

There are equally important drawbacks.

1. Double Tax on Extraction

Corporation Tax can be followed by personal tax when profits are distributed.

2. 25% Corporation Tax Can Apply

A securities/cash FIC may be a close investment-holding company.

3. Complexity

Different share classes require careful legal drafting.

4. Valuations

Growth shares, gifts and restructuring can require specialist valuation.

5. Annual Compliance

The company requires accounts, Corporation Tax returns, Companies House filings and bookkeeping.

6. Investment Companies Generally Don’t Qualify for Business Relief

So don’t assume the shares themselves automatically receive IHT Business Relief.

7. Trusts Add Another Layer

Trust tax, IHT and administration may all arise.

8. Moving Existing Property Can Be Expensive

CGT and SDLT can make transferring an established portfolio unattractive.

9. ATED

Higher-value residential property can create additional annual compliance.

10. Family Members Become Genuine Shareholders

Once shares have been given away, the recipients have real legal and economic rights.

A FIC should therefore be viewed as long-term succession planning rather than something that can simply be undone whenever circumstances change.

Worked Example – £1 Million Family Investment Company

Let’s return to our fictional family.

David and Emma have:

ÂŁ1 MILLION CASH

available for long-term investment.

They don’t need all of the capital for their normal living costs.

They want to benefit Alex, Sophie and eventually future grandchildren.

They establish:

TAYLOR FAMILY INVESTMENTS LTD.

David lends the company:

ÂŁ1,000,000.

The company invests the money.

Because the £1 million asset is matched by the £1 million loan liability, the company’s shares may initially have relatively little value.

The share rights are structured at an early stage so that Alex and Sophie have genuine rights to future growth.

Twenty years later, suppose the investments are worth:

ÂŁ3,000,000.

The original:

ÂŁ1,000,000 LOAN

still belongs to David to the extent it hasn’t been repaid or gifted.

But much of the:

ÂŁ2,000,000 FUTURE GROWTH

may potentially have accrued to the growth shares.

That illustrates one of the central principles of FIC planning:

THE FIC HASN’T MAGICALLY REMOVED £1 MILLION FROM DAVID’S ESTATE.

Instead, it may have:

REDIRECTED THE FUTURE GROWTH.

That distinction is crucial.

10 Questions to Ask Before Setting Up a FIC

1. What are we trying to achieve?

IHT planning, succession, property investment, investment compounding or a combination?

2. How much are we investing?

The setup and ongoing costs need to be proportionate to the wealth involved.

3. Loan or equity?

This can completely change the initial share values and future access to capital.

4. Who needs control?

Parents, grandparents, children or trustees?

5. Who should benefit from future growth?

Children, grandchildren or a trust?

6. Do the founders need investment income personally?

If most profits need extracting annually, the FIC may be less attractive.

7. What will the FIC invest in?

Property, shares and cash can have very different Corporation Tax consequences.

8. Will it be a close investment-holding company?

Don’t automatically assume 19% Corporation Tax.

9. Are existing properties or investments being transferred?

Calculate CGT and SDLT before doing it.

10. What happens in 10, 20 or 30 years?

Think about succession, death, divorce, family disagreements, grandchildren and eventual extraction before choosing the share rights.

Frequently Asked Questions

What is a Family Investment Company?

A FIC is normally a private company owned by members of the same family and used to hold investments such as property, shares and cash. Different share classes can separate voting control, income and capital growth. HMRC itself identified these as common FIC characteristics.

Is a FIC a tax avoidance scheme?

No. HMRC’s own specialist FIC research found no evidence that people establishing FICs were more inclined towards avoidance or non-compliant behaviour. Normal tax and anti-avoidance legislation nevertheless applies to every transaction undertaken by the company and its shareholders.

Does HMRC still have a Family Investment Company Unit?

No dedicated FIC research unit remains. HMRC completed its specialist work and moved FICs into its normal compliance activity — described in its 2021 minutes as “business as usual.”

Can parents retain control of a FIC?

Potentially. Different share classes can allow one generation to retain voting rights while other classes participate in income or future capital growth.

Can a FIC reduce Inheritance Tax?

Potentially. One strategy is to retain the older generation’s existing value while directing future growth to younger generations. The actual IHT result depends on the share rights, valuations, gifts and retained benefits.

Should I fund a FIC with a loan?

Loan funding can provide considerable flexibility because the company may later repay the loan without that repayment being a dividend. However, the loan remains an asset of the lender’s estate until it is repaid, spent or validly given away.

Can my children own FIC shares?

Yes, but arrangements involving minor children need particular care because of the settlements legislation. Adult children are generally more straightforward.

Does a FIC pay 19% Corporation Tax?

Not necessarily. A close investment-holding company is subject to the main Corporation Tax rate and cannot use the small-profits rate or marginal relief.

Is a property FIC a close investment-holding company?

Not necessarily. Commercial investment in land let to unconnected persons is specifically within an exception to the CIHC rules.

Can a FIC claim mortgage interest on residential property?

Companies aren’t subject to the Section 24 residential finance-cost restriction in the same way as individual landlords, although the normal corporate interest rules still apply.

Can I transfer my existing rental properties into a FIC?

You can, but that doesn’t mean the transfer is tax-free. CGT and SDLT can arise, so the entry cost should be calculated before proceeding.

Should a trust own FIC shares?

Sometimes. A discretionary trust can provide flexibility for future generations, but it brings additional IHT, tax, legal and compliance considerations.

Are Family Investment Companies Still Worth It in 2026?

For the right family:

YES, THEY CAN BE.

But the strongest case for a FIC isn’t simply:

“Companies pay less tax.”

Sometimes they don’t.

The real attraction is often the ability to combine:

CONTROL

with:

SUCCESSION

and:

LONG-TERM WEALTH COMPOUNDING.

A FIC can potentially allow parents or grandparents to retain control while directing future economic growth towards children and grandchildren.

Loan funding can provide access to the original capital.

Growth shares can move future value between generations.

Trusts can provide further flexibility where appropriate.

And for property investors, corporate ownership can have particular advantages around residential finance costs, especially as personal property-income tax rates are scheduled to rise to 22%, 42% and 47% from April 2027.

But these advantages need to be considered alongside:

The key is to design the structure around:

WHAT THE FAMILY WANTS THE WEALTH TO DO OVER THE NEXT 10, 20 OR 30 YEARS.

That is much more important than simply setting up a company and calling it a Family Investment Company.

How Bicknell Business Advisers Can Help

At Bicknell Business Advisers, we can help families explore whether a Family Investment Company is appropriate, including:

Where bespoke Articles of Association, trusts, wills or other legal documentation are required, appropriate specialist legal input should form part of the process.

A FIC can be a powerful structure.

But it should start with the family’s long-term objectives — not with the company formation form.

About the Author

Steve Bicknell FCMA, CGMA is Managing Director of Bicknell Business Advisers Limited, specialising in property taxation, landlord tax planning, SDLT, Capital Gains Tax and property company structures throughout the UK.

Exit mobile version