Capital Gains Tax relief for gifts of business assets
Published 23 June 2026
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This publication is available at https://www.gov.uk/government/publications/capital-gains-tax-relief-on-gifts-of-business-assets/capital-gains-tax-relief-for-gifts-of-business-assets
Who is likely to be affected
Individuals making a gift of shares or securities of a trading company or the holding company of a trading group where either the company is the transferor’s personal company, or the shares or securities are unlisted.
General description of the measure
This measure incorporates assets that qualify for the substantial shareholding exemption (SSE) or are subject to the intangible fixed assets (IFA) regime into the formula that restricts the amount of gift holdover relief available when the company or group holds assets that are not used for the purposes of the company’s or group’s trade.
Policy objective
The measure restores how the restriction formula worked before the introduction of the SSE and IFA regime, removing distortions that can arise when calculating the amount of holdover relief available.
Background to the measure
This measure was announced at Budget 2025.
Detailed proposal
Operative date
The measure will have effect in relation to disposals made on or after 6 April 2027.
Current law
Current law is contained in:
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sections 165 to 169G of the Taxation of Chargeable Gains Act (TCGA) 1992, which provide for gift of business asset hold-over relief
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paragraph 7 of Schedule 7 to TCGA 1992, which provides for reductions in held-over gains on the disposal of shares
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section 192A and Schedule 7AC to TCGA 1992, which provides exemptions for gains on disposals of shares by companies with substantial shareholdings
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section 752 of the Corporation Tax Act 2009, which provides in relation to the charge to corporation tax on non-trading gains on intangible fixed assets
Proposed revisions
The measure amends paragraph 7(2)(b) of Schedule 7 to TCGA 1992 to include as ‘chargeable assets’ those assets that would be chargeable assets but for being within the substantial shareholding exemption or the intangible fixed assets regime (such as goodwill created or acquired on or after 1 April 2002).
Summary of impacts
Exchequer impact (£ million)
| 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 | 2031 to 2032 |
|---|---|---|---|---|---|
| empty | empty | empty | empty | empty | empty |
The final costing will be subject to scrutiny by the Office for Budget Responsibility and will be set out at a future fiscal event.
Economic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
This measure impacts individuals who make gifts of qualifying shares, such as in their own personal company, typically as part of succession planning. It will have no impact where the assets of the relevant company, or group, consist only of trading assets.
Where the assets also consist of non-trading assets, when calculating the amount by which hold-over relief is to be reduced, the relief will become more generous where the additional assets to be considered are mainly trading assets. Conversely, the relief will be less generous where the additional assets are mainly non-trading assets.
It is not expected to impact on family formation, stability or breakdown.
This measure is expected overall to have no impact on an individual’s experience of dealing with HMRC as it does not change the process or how they engage with HMRC.
Equalities impacts
An individual may be affected by this measure regardless of their protected characteristics. If a protected group is overrepresented in this population, then it will be disproportionately impacted.
The individuals impacted by this measure are subset of the population liable for Capital Gains Tax (CGT). This population is estimated to have an overrepresentation of people aged between 45 to 74 (68%), with those between 55 to 64 (27%) being the largest group, compared to the UK adult population (45% and 17%, respectively). The population is also estimated to have an overrepresentation of males (57%) compared to the UK adult population (50%).
HMRC does not currently hold data on the other protected characteristics of individuals in the CGT population and so cannot determine conclusively if there are any other equality impacts.
Impact on business including civil society organisations
This measure is not expected to impact business or civil society organisations.
Operational impact (£ million) (HMRC or other)
This measure will not require changes to HMRC’s processes or resources.
Other impacts
Other impacts have been considered and none have been identified.
Monitoring and evaluation
The measure will be monitored through communication with affected taxpayers and practitioners.
Further advice
If you have any questions about this change, contact the Capital Gains Tax policy team on email: cgtbudget@hmrc.gov.uk