Capital Gains & Inheritance Tax - Recent & Planned Changes

Capial Gains Tax (CGT)

• Impact of the new CGT rates announced in the October 2024 Budget
• BADR
  • Key changes in recent Finance Acts and Budgets
    • Qualifying shares
    • Elections to avoid dilution issues
    • Increasing BADR tax rate from 6 April 2025, including the impact where a deferral of CGT charge has applied previously
  • Trading company status
    • Importance of the Assem Allam case
  • Traps to avoid and key cases
• Investors’ relief
  • Qualifying conditions
  • Cut in lifetime limit for qualifying gains from 30 October 2024
• Furnished Holiday Lettings abolition from 6 April 2025
  • Anti-forestalling rules affecting CGT reliefs
• Main residence relief
  • Review of recent cases
• Goodwill on business disposals and incorporations
  • HMRC practice
  • Recent cases

Inheritance Tax (IHT)

• Understanding the residence nil rate band
• When it is available
• Transferability between spouses / civil partners
• The complex ‘downsizing’ provisions
• Business Property Relief (BPR) and Agricultural Property Relief (APR)
• Main conditions
• Proposed restrictions on APR and BPR from 6 April 2026
• Instalment option for paying tax, including interest provisions
• Problems with cash-rich businesses or those deriving value from L&B
• Partnership structures and why they sometimes don’t work
• Recent cases
• FA 2020 changes to ‘excluded property’ rules

Abolition of non-dom status for tax purposes from 6 April 2025

• Abolition of remittance basis
• Key points of the proposed replacement ‘foreign income and gains’ (FIG) regime
• Transitional provisions, including:
  • Rebasing of assets for CGT purposes
  • Temporary Repatriation Facility
• The new residence-based IHT regime
  • When foreign assets come within the IHT net
  • How long they stay within it once you have become non-resident

This course will bring delegates up to date on:

• The key capital gains tax (CGT) reliefs, particularly business asset disposal relief (BADR)
• The latest developments in the business reliefs for inheritance tax (IHT), including the restrictions on agricultural property relief (APR) and business property relief (BPR) due in April 2026
• The key CGT and IHT planning points and problems arising from the abolition of non-dom status for individuals
• Recent case law, HMRC guidance and other developments

• Trainer is a Chartered Accountant with over 35 years’ experience in tax training
• The course includes discussion of a wide range of tax cases in this area
• There are many numbers-based practical examples to aid understanding of potential tax exposure
• Tax tips and traps are highlighted throughout

• All relevant issues from the November 2024 Budget and Autumn Finance Bill will be covered

This training course will update you on the changes that have taken place in recent years and those that are planned.

Various cases will be reviewed, to demonstrate some of the practical problems that you may come across. Throughout, emphasis will be given to traps that can catch out the unwary.

The course will look at many ways for you to save your client tax; these generally involve having a good understanding of what are often detailed rules and, crucially, planning well in advance of a disposal or transfer.