UK: what changed on 6 April 2026 for owners who sell or pass on their business
In brief. Since 6 April 2026, Business Asset Disposal Relief is charged at 18% (up from 14%) and 100% Business Property Relief applies only to the first £2.5m, transferable between spouses. Above that, relief falls to 50%. For owners of UK companies, the trade-off between selling and passing on the business has changed.
On a sale: Business Asset Disposal Relief at 18%
BADR reduces capital gains tax on the sale of shares in a company where the owner works. Its rate rose from 14% to 18% on 6 April 2026, within a £1m lifetime limit. The maximum saving falls from £100,000 to £60,000. Above it, the standard CGT rate remains 24%.
On succession: Business Property Relief capped at £2.5m
BPR used to exempt unlisted business shares from inheritance tax in full. Since 6 April 2026, 100% relief applies only to the first £2.5m of combined business and agricultural assets. Above that, relief is 50%, an effective 20% rate on the excess. The allowance is transferable between spouses and civil partners, so a couple can pass on up to £5m with full relief.
What it changes
- A company worth £10m, passed on by a couple using both allowances, now bears tax on the value above £5m, about £1m, which the family must be able to pay without selling.
- The heirs' liquidity becomes central: dividends, recapitalisation, insurance or a partial sale.
- The comparison between selling in lifetime (18% then 24%) and passing on (20% above the cap) needs to be redone, with figures.
- Families present in both France and the UK must align these rules with the Dutreil pact and tax treaties.
What we advise
- Have the business valued and calculate potential tax under the new cap.
- Check that both spouses' allowances can actually be used (wills, ownership of shares).
- Plan the source of cash that will pay the tax, before it falls due.
- Validate the plan with a UK tax adviser.
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This article is general information. It is not investment, legal or tax advice. The rules quoted must be checked by your advisers before any decision.