Sometime ago, an individual was given the following tax advice: sell the assets that you want to sell, triggering a capital gain. Then re-invest the capital gain (not all the sale proceeds) into qualifying enterprise investment scheme (EIS) shares. This effectively rolls over or defers the capital gains tax on the capital gain until the time when the newly purchased EIS shares are eventually sold. If the EIS shares are kept until the individual dies, the deferred capital gain is 'washed out', and is passed on to the inheritors at market value at the date of death (probate value). So far, it seems like a good idea.  

However, it gets better. If the EIS shares that are invested into qualify for inheritance tax (IHT) business property relief (BPR) and are kept for at least two years before death, the shares can be passed on to the inheritors without any IHT (i.e., 100% relief). There is an exception to this IHT BPRrule in that it does not apply to listed shares (e.g., shares marketed on the London Stock Exchange). But if the EIS shares are not listed shares (e.g., marketed on the Alternative Investment Market (AIM)), they can still benefit from this inheritance tax business property relief rule. Does this nice idea still apply?  

Arthur replies: 

The Chancellor has recently announced a restriction in IHT BPR at 100% to the first £2.5m, from April 2026. Anything above the first £2.5m will be eligible for only 50% relief. Furthermore, from April 2026, BPR will be reduced to 50% on shares designated as 'not listed' on the markets of recognised stock exchanges, such as AIM. So yes, there is a measure of relief, but not like there used to be.