Entity Setup

How UK Tax Reform Impacts Trusts & Business Asset Gifts from April 2027

If you're planning to set up a trust or make gifts of business assets, changes coming from April 2027 will affect whether you can claim full relief or be hit with unexpected IHT or CGT charges.

By NomadicTax Research Team • 5-8 min read • September 4, 2026

## What’s Changing? - **Gift Holdover Relief**: As of **6 April 2027**, new rules will include assets qualifying for the Substantial Shareholding Exemption (SSE) or within the Intangible Fixed Assets (IFA) regime in the formula that restricts Gift Holdover Relief. That restores how the restriction worked before SSE and IFA changes, removing distortions for donors. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-relief-on-gifts-of-business-assets/capital-gains-tax-relief-for-gifts-of-business-assets?utm_source=openai)) - **Inheritance Tax (IHT) on Pensions**: For **deaths on or after 6 April 2027**, Finance Act 2026 introduces new requirements relating to IHT on pensions. Primary legislation will require information sharing between personal representatives and pension scheme administrators to support the change. ([gov.uk](https://www.gov.uk/government/publications/inheritance-tax-on-pensions-technical-note/technical-note-inheritance-tax-on-pensions?utm_source=openai)) ## Who’s Impacted — Personal Scenarios - **Entrepreneurs & Family Business Owners**: If you gift shares in your trading company or group to a family member or via a trust, and some assets are non-trading, the changed hold-over formula will reduce your relief in certain cases. The more trading assets you hold, the better relief will be under the new changes. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-relief-on-gifts-of-business-assets/capital-gains-tax-relief-for-gifts-of-business-assets?utm_source=openai)) - **Executors & Beneficiaries**: For estates involving pensions, if someone dies on or after 6 April 2027, personal representatives must share information with pension administrators. Beneficiaries may find that some pensions become subject to IHT, depending on scheme rules and estate planning. ([gov.uk](https://www.gov.uk/government/publications/inheritance-tax-on-pensions-technical-note/technical-note-inheritance-tax-on-pensions?utm_source=openai)) ## Advice & Planning Tips - **Review Your Asset Mix**: If you hold both trading and non-trading assets, plan gift transactions now (before 6 April 2027) if you want more generous relief under the old rules. - **Trust Setup Timing**: Using trusts to hold assets intended for gifting? Establishing those trusts and making transfers ahead of the new effective date may help avoid reduced relief. - **Pensions & Estate Structure**: Work with your advisors to ensure your pension arrangements—especially scheme designation or beneficiary nomination—don’t create unexpected IHT exposure once the legislation takes effect. - **Keep Records & Be Compliant**: Given the new info sharing and reporting rules, ensure your estate documents, trustees’ records, and pension scheme paperwork are in order. ## Example Scenarios - *Example 1*: Sarah owns a personal trading company but also some intangible fixed assets (like brand royalties). She wants to gift shares to her children. Under the new rules, because the company holds IFAs, the permitted relief may be **less generous**. Doing the gift before 6 April 2027 may preserve more holdover relief. - *Example 2*: Tom’s father dies in 2028, leaving a pension to Tom. His executor must share detailed pension scheme data with administrators to determine what IHT is due. If this had been planned earlier, parts of the pension may have been structured differently. ## Key Takeaways 1. The date **6 April 2027** is crucial—changes to Gift Holdover Relie<br>f and IHT on pensions become active then. 2. Reviewing asset portfolios and estate plans now can preserve reliefs and avoid larger tax charges. 3. Getting professional advice—especially for trusts and pensions—is more important than ever to navigate overlapping regimes (CGT, IHT, FIG).