The dividend allowance was £2,000 in 2022. It was cut to £1,000 in April 2023. It was cut again to £500 in April 2024. A founder extracting £200,000 in dividends annually is now paying higher-rate dividend tax on £199,500 of that income. At 33.75%, that is £67,331 in dividend tax alone — before income tax on salary, before National Insurance, before any other personal tax liability.
What founders are actually paying
The effective tax rate on dividends for a higher-rate taxpayer in 2024/25 is 33.75%. For an additional-rate taxpayer — anyone with income above £125,140 — it is 39.35%. These rates apply to dividends received personally. They do not apply to dividends received by a company.
A holding company receiving dividends from a trading subsidiary pays no corporation tax on those dividends under the dividend exemption rules. The same income that costs a founder 33.75% in personal dividend tax costs the holding company 0%. The difference is not a planning strategy. It is the structural consequence of where the income lands.
The retention architecture
The solution is not to stop taking dividends. It is to retain capital inside the structure rather than extracting it personally. A founder who needs £150,000 to live on extracts £150,000. The remaining profit is retained inside the holding company at 25% corporation tax rather than extracted at 33.75% dividend tax.
Over ten years, a founder retaining £200,000 annually inside a holding company rather than extracting it personally saves approximately £170,000 in dividend tax — before the compounding effect of that retained capital being deployed at corporate rates rather than personal rates.
The salary-dividend mix
The optimal salary-dividend mix for a founder in 2024/25 is a salary at the National Insurance secondary threshold (£9,100) and dividends up to the basic rate band (£50,270 total income). Above that threshold, the marginal rate on dividends jumps to 33.75%. This is the starting point for most accountants. It is not the architecture.
The architecture addresses the capital above the extraction threshold — the profit that is being retained, the capital that is compounding, and the framework that governs how it moves through the structure without triggering a personal tax event on every cycle. That is what the holding company and the SAFO structure are designed to do.