Tax Planning
Tax Planning under New UK Rules: Capital Gains Tax Relief for Gifts of Business Assets
From April 6, 2026, significant changes to Capital Gains Tax affect individuals making gifts of business assets—understanding these changes can unlock planning opportunities for succession, family transfers, and trusts.
By NomadicTax Research Team • 6 min read • July 10, 2026
## What You Need to Know about the Change
On 23 June 2026, the UK government published a policy paper detailing reforms to **Capital Gains Tax relief for gifts of business assets**. The operative date is **6 April 2027**—this is when the new rules take effect. ([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))
These reforms restore how the gift hold-over relief worked before the introduction of the Substantial Shareholding Exemption (SSE) and Intangible Fixed Assets (IFA) regimes. Assets previously exempt under these regimes will now be considered “chargeable assets” for the purpose of calculating hold-over relief—a change that can affect tax liabilities when giving away shares in trading companies. ([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))
## Who Is Affected?
- Individuals gifting shares or securities in a **trading company**, or the holding company of a trading group. ([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))
- Usually owners of personal trading companies, or involved in family business succession, or involved in transfers via trusts. ([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))
- The relief applies only when the company holds both trading and non-trading assets; the more non-trading assets, the less generous the relief. ([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))
## Planning Opportunities and Examples
| Scenario | Old Rule | New Rule (from 6 Apr 2027) | What to Consider Now |
|---|---|---|---|
| Parent wishes to give shares of company with some non-trading assets to child | Relief restricted significantly thanks to SSE/IFA exclusions; gains on non-trading assets may trigger higher CGT | Non-trading assets will now be included in the restriction formula, reducing distortion and possibly increasing relief | Check proportion of trading vs non-trading assets; consider reorganising assets before April 2027 if possible |
| Trust involved in holding shares of personal company | Similar restrictions under SSE/IFA; relief often denied or reduced | With new rule, the calculation will be more systematic and fair; relief restored for assets that were previously disadvantaged | Trusts should review holdings and consider timing of gift; may want to gift before or after rule depending on circumstances |
## Actionable Strategies for 2026–2027
- **Audit your asset base**: Determine which assets are trading vs non-trading to assess impact under the new restrictions. If the majority are trading assets, the relief will be more generous.
- **Timing matters**: If you’re planning a gift before 6 April 2027, the old regime applies; after that date, the new rules will govern. Early action may be beneficial.
- **Family succession and share transfers**: Those arranging inter-generational transfers should reconsider structure, possibly use hold-over relief optimally.
- **Seek professional tax advice**: Especially if you have a mix of assets, complex ownership (holding companies, trusts), or overseas elements.
## Implications in Context
This change aligns with the UK government’s broader **Tax Update 2026**, focused on “simplification, modernisation and fairness.” ([gov.uk](https://www.gov.uk/government/collections/taxupdate-2026-simplification-modernisation-and-fairness?utm_source=openai)) The reforms help reduce unintended double taxation and distortions caused by split exposure to SSE/IFA and non-trading asset classes.
For many business owners, this opens up more predictable tax outcomes when gifting shares, which may promote smoother succession planning and greater flexibility.
**Bottom line**: If you anticipate gifting business assets, particularly where non-trading assets are involved, get ahead of the April 2027 change. Planning now could save you tax and avoid unexpected complications.