Subject to the £1m lifetime limit (for all qualifying disposals made on or after 30 October 2024, £10m prior to this date) and a claim being made, where all of the shares in the holding disposed of are qualifying shares and, in the case of a disposal by trustees, where they meet the criteria in C3.1322, the gain on the disposal, after deduction of any allowable capital losses, is taxable at 10% (to increase to 14% from April 2025 and 18% from April 2026, see C3.1320)1.
The claim must be made on or before the first anniversary of the 31 January following the tax year in which the disposal is made. In the case of a disposal by trustees, the claim must be made jointly by the trustees and the eligible beneficiary or beneficiaries2. Where a notice
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