Here are the latest CGT changes I can share now, with a focus on notable UK developments in late 2024–early 2025 and ongoing updates in 2026.
- Main CGT rates updated in Budget 2024 (UK): The lower CGT rate for most assets rose from 10% to 18%, and the higher rate from 20% to 24% from October 30, 2024. This is a substantial uplift in the standard CGT band.[3]
- BADR and investors’ relief adjustments: The 10% rate applicable to gains qualifying for Business Asset Disposal Relief (BADR) or Investors’ Relief increased to 14% from 6 April 2025 and to 18% from 6 April 2026, with a reduced lifetime limit for Investors’ Relief (£1m) taking effect from 30 October 2024.[3]
- EOT-related CGT relief changes: There was a notable reduction in CGT relief on qualifying disposals to an Employee Ownership Trust (EOT), from 100% to 50%, effective 26 November 2025; the remaining 50% is treated as a chargeable gain to the disposer, with some carryover/holdover mechanics continuing for the trust side. This change carried a large budgetary cost implication and was highlighted by professional bodies as a major shift in relief rules.[1]
- Incorporation relief and administration: From 6 April 2026, incorporation relief will need to be claimed (rather than automatically given) when transferring a business to a company in exchange for shares, affecting planning around company formations and restructurings.[1]
- Non-resident CGT and anti-avoidance: Measures to close loopholes for non-residents and to modernize anti-avoidance provisions around share exchanges and reorganisations were scheduled to take effect around 26 November 2025, affecting cross-border and intra-group activity.[1]
- General themes and expectations: Budget commentary in late 2024 referenced potential discussions around expanding CGT to gains on death and the idea of an “exit tax” for emigrants, though concrete legislative steps and timelines remained uncertain at that time. Budget rumours suggested ongoing consideration of carried interest treatment and relief adjustments, with tensions between competitiveness and revenue needs.[2]
What this means for planning
- Timing matters: The raised CGT rates and relief changes are already in place for the 2024–2025 tax year in many cases, so ensure disposals, relief elections, and restructurings align with the new rates and rules.
- Relief strategy shifts: Since BADR/Investors’ Relief rates increased and the reliefs have tighter limits, revisiting investment structures and exit planning is prudent, especially for entrepreneurs and private equity structures.[3]
- EOT and incorporations: If you’re using EOTs or planning to incorporate a business, review the new 50% EOT CGT relief and the requirement to claim incorporation relief to avoid unexpected gains or missed relief.[1][3]
- Non-resident planning: For cross-border activities, ensure compliance with new non-resident CGT rules and anti-avoidance provisions to avoid unexpected gains or disallowed relief.[1]
Illustrative example
- Scenario: A business owner with a qualifying asset disposes of shares to an EOT in 2026. Under the updated rule, only 50% of the gain qualifies for relief; the other 50% becomes a chargeable gain to the disposer. This shifts the effective tax planning around employee ownership transitions and could alter post-disposal proceeds.[1]
Citations
- Budget changes to CGT and reliefs, including EOT and BADR updates.[1]
- CGT rate increases and relief schedules with dates and scope.[3]
- Budget-related CGT rumours and broader reform context.[2]
If you’d like, I can tailor a quick 1-page summary for your context (e.g., whether you’re considering an EOT, a business sale, or an incorporation), and outline action steps with relevant dates.
Sources
In less than a month, the UK’s new chancellor, Rachel Reeves, will unveil her first budget and Green Square director Tony Walford says agency owners should brace themselves for tax changes that could hit them where it hurts. It’s hard to overlook that Rachel Reeves, the UK’s new chancellor of the exchequer, is preparing the […]
gsquare.co.ukThe Chancellor announced a number of changes to capital gains tax (CGT), inheritance tax (IHT) and the residence-based tax regime , including a change in the rules for disposals to employee ownership trusts (EOTs), effective immediately.
www.icaew.comReport on latest Budget tax rumours as at Friday 18 October 2024
www.tax.org.ukAJ Bell report that millions of last minute filers face potential CGT hurdle
www.actuarialpost.co.ukCapital gains tax rates were increased in the 2024 Budget but fresh data suggests the policy is failing to boost government coffers. Could it put chancellor Rachel Reeves off a wealth tax?
moneyweek.comFrom 30 October 2024, the main rates of capital gains tax (CGT) will be increased to 18% and 24%. The 10% rate of CGT for disposals attracting business asset disposal relief (BADR) will increase to 14% (from April 2025) and to 18% (from April 2026).
www.icaew.comAfter months of intense speculation, the Chancellor of the Exchequer, Rachel Reeves, delivered both her own and the new government’s first Budget yesterday.
www.penningtonslaw.com