Tax Planning
Succession Planning Shifts: New CGT Rules for Gifted Business Assets from April 2027
The UK is changing how hold-over relief works when gifting business assets, especially for companies with non-trading assets or SSE/IFA exposure — key for business succession planning.
By NomadicTax Research Team • 5-8 min read • July 18, 2026
## What’s Changing with Gift Hold-Over Relief for Business Assets
On **23 June 2026**, HMRC published a policy paper updating rules for **Capital Gains Tax (CGT) relief on gifts of business assets**. The changes revise how relief works when a gifted company has assets not used in trade, especially assets covered by the **Substantial Shareholding Exemption (SSE)** or **Intangible Fixed Assets (IFA)** regimes. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-relief-on-gifts-of-business-assets?utm_source=openai))
## Key Provisions
- **Assets under SSE or IFA inclusion**: Previously, the restriction formula didn’t count assets sheltered by those regimes. From **6 April 2027**, those assets will **count as “chargeable assets”** when determining hold-over relief eligibility. ([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))
- **Operative date**: Applies to disposals made **on or after 6 April 2027** only. ([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))
- **Impacted group**: Individuals gifting shares or securities of a trading company (or holding company of a trading group), especially where the company has **both trading and non-trading assets**, will feel the effects most. ([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))
## What This Means in Practice: Examples
- **Scenario A**: Parent owns a trading company that also holds intangible assets under IFA. If parent gifts shares, and non-trading/intangible assets make up a large part, relief may be **less generous**.
- **Scenario B**: Company is purely trading. Including SSE/IFA assets won’t change much—hold-over relief remains broadly intact.
## Action Steps for Tax Planning & Succession
1. **Audit your company’s balance sheet** to understand how much non-trading, intangible fixed assets or assets under SSE it holds.
2. **Front-load gifting** where possible before 6 April 2027 to get more generous relief under old rules.
3. **Plan share transfers strategically**, e.g., to family members whose shares will stay within a purely trading structure.
4. **Use valuation advice** to understand how much relief you might lose if assets don’t qualify under trading status.
## Strategic Implications
- Those doing **succession planning**, such as business owners passing shares to heirs, must act before the operative date to maximise relief.
- For businesses with mixed-asset portfolios, there might now be increased incentive to **reorganise asset ownership** so trading assets are cleaner, non-trading assets split off.
- Advice from specialists (corporate tax and valuation experts) becomes more critical.
## Summary
From **6 April 2027** new rules will make Gift Hold-Over Relief more stringent for companies holding non-trading assets, SSE assets, or under the IFA regime. To protect advantages, tax planning, especially for gifts and business succession, needs to begin well before that date.