Tax Planning
Navigating UK Business Succession: New CGT Relief for Gifting Shares & Business Assets
Upcoming capital gains tax changes in the UK will affect how business owners gift shares or business assets — particularly relevant for succession planning and transfers to family members.
By NomadicTax Research Team • 5-8 min read • July 25, 2026
## What the New Relief Entails
In late June 2026, HM Revenue & Customs published draft legislation titled **Capital Gains Tax relief on gifts of business assets**. It targets changes to the **gift hold-over relief** regime in the UK, effective for disposals made **on or after 6 April 2027**. ([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))
Under the updated rules, individuals making gifts of shares or securities in a trading company — or its holding company — will face a revised formula affecting how much of their gains can be held over, especially when the company has non-trading or intangible fixed assets. Severely put, assets that were previously exempt due to **Substantial Shareholding Exemption (SSE)** or under the **Intangible Fixed Assets (IFA)** regime may now be included when calculating hold-over relief amounts. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-relief-on-gifts-of-business-assets?utm_source=openai))
## Who’s Affected
- **Owners of small or family businesses**, especially family members inheriting or receiving gifts of shares.
- Companies holding **non-trading assets** such as excess properties, investments, or items not used in the core business trade.
- Business groups under the SSE or IFA regimes. If you’re a shareholder in a holding company with intangible assets, the restriction formula changes will impact you.
## Practical Examples
| Scenario | Before 6 April 2027 | On or After 6 April 2027 |
|---|---|---|
| You gift shares in a trading company with some investment property. Only non-trading assets would reduce hold-over relief partially. | Holds-over largely on trading assets only. | Both trading and non-trading assets (even if exempt-until now under SSE or IFA) will reduce relief calculation. |
| A holding company with intangible assets (like trademarks), making gifting shares. | If IFA regime covered those, they might have been exempt in calculations. | Now included, possibly reducing relief. |
## How to Plan Around the Changes
- **Review asset composition**: assess what proportion of your company’s assets are non-trading or intangible, and understand the impact on relief amounts.
- **Consider timing**: where possible, make gifts *before* 6 April 2027 to take advantage of the current, more favorable calculation.
- **Document valuations carefully**: non-trading or intangible assets may need clear valuation to support relief amounts.
- **Seek succession advice**: estate planning, exit strategies, or family ownership transfers may need adjustment.
## Strategic Considerations & Risks
- The change addresses *fairness*, correcting distortions in relief calculations. But it may reduce the tax benefit formerly enjoyed by some business owners.
- Not all enterprises will see dramatic effects — purely trading companies with minimal non-trading assets will feel little change. But holding companies and those with intangible fixed assets could see limitations.
16# Ensure conversations with tax professionals, particularly around **valuation of intangibles** and meeting reporting requirements.
## Actionable Checklist for Business Owners
- Inventory all **trading vs non-trading assets** in your business, including intangible assets and non-core investments.
- Assess if planned gifts or transfers can occur **before 6 April 2027** to lock in favorable relief.
- Consult credible valuation experts to accurately assess values of non-trading and intangible assets.
- Update shareholder agreements and business succession plans to align with new law.
## Bottom Line
UK business owners face a meaningful tightening of hold-over relief calculations starting April 2027. Those serious about succession or transferring ownership through the family should start evaluating and potentially accelerating those transfers now — before the new rules restrict the value you can hold over.