A62Delivery risk: AmberGate: pending
Close capital-tax reliefs rather than raise rates
Existing action A62, assessed at the same scope.
Provisional single-reviewer assessment; not an approved business case.
- Who and where
- People who realise or pass on capital gains and estates in the UK — concentrated at the top: 45% of capital gains tax came from gains of £5m or more in 2024–25. (from the action record) Jurisdiction: UK.
- Result so far
- Range if completed: 11.0–20.0 out of 30 (equal weights; not yet assessed: increment beyond baseline (Ad), expected incremental benefit (Bn), incremental affordability (Co))
- Funded now (baseline)
- Baseline: CGT rates of 18% and 24% since October 2024; business asset disposal relief rising to 18% from April 2026; a £2.5m allowance for agricultural and business property relief from April 2026. Closing further reliefs instead of raising rates is a UK Facts framing of options, not government policy. (from the action record)
- The change assessed (marginal)
- Marginal change not yet defined
- Domain home: Tax options
- In the national plan: Equality and opportunity list
What the evidence supports—and the next decision
Closing a relief is not one policy. The current tax baseline, behavioural response and distribution differ by relief.
AI-assisted analytical follow-up · 8 October 2026. Proposed appraisal design; the attributed scores below are unchanged. No funding or delivery agreement is implied.
- Define the change
- List each relief, eligibility rule and reform option; compare with the law and rates actually in force.
- Test whether it works
- Net receipts, avoidance, investment and distribution against a published behavioural model; compare forecasts with outturn after implementation.
- Establish the cost
- Administration, transition and compliance plus behavioural revenue loss. Do not add static estimates or count the same tax base twice.
- Protect against harm
- Consider legitimate reliance, liquidity, avoidance displacement and legal transition arrangements.
Read with the outcome evidence and sources in the full assessment. Monitoring proposals are not existing baseline measurements. A numerical benefit or cost score needs evidence for the defined increment, not just the scale of the problem.
Full assessment of Close capital-tax reliefs rather than raise rates: ten criteria, scenarios, delivery, costs and monitoring
The ten criteria (0–3)
Each criterion is scored 0 to 3 by the reviewer. “Not yet assessed” means unknown: it is never counted as zero.
Scale and severity (Sc)2 of 3 — Serious harm to a defined group or widespread moderate harm
Reviewer’s reason: Provisional problem-importance judgement from linked site pages; not the scale of achievable benefit.
Increment beyond baseline (Ad)Not yet assessed
Reviewer’s reason: Name reliefs, thresholds, interactions and transition; obtain distributional/behavioural costing and administrative assessment. A missing rating requires a defined marginal change.
Confidence in the proposed action (Ev)1 of 3 — Indirect, mixed, modelled or weak causal support
Reviewer’s reason: Illustrative rate changes and another party’s design do not cost the proposed relief package. Effects depend on exact reliefs and behaviour.
Expected incremental benefit (Bn)Not yet assessed
Reviewer’s reason: Unknown unless a reasonably defined target-population benefit can be judged; no bonus merely for spanning domains.
Residual harms (Hm)1 of 3 — Material harm/unresolved mitigation
Reviewer’s reason: Forestalling, avoidance and investment effects; progressivity must be demonstrated.
Incremental affordability (Co)Not yet assessed
Reviewer’s reason: Net receipts after behaviour, administration and transition; investment and compliance effects.
Delivery capacity (Ca)2 of 3 — Stretched but plausibly obtainable
Reviewer’s reason: Name reliefs, thresholds, interactions and transition; obtain distributional/behavioural costing and administrative assessment.
Distribution (Fa)2 of 3 — Mixed or broadly neutral with safeguards
Reviewer’s reason: Provisional distribution judgement for the stated target; verify who pays, who gains and excluded groups.
Meaningful first outcome (Ti)2 of 3 — More than one and up to three years
Reviewer’s reason: First meaningful outcome, not announcement: Net receipts, incidence and behavioural response.
Readiness (Rd)1 of 3 — Legislation/external agreement or major enabling work
Reviewer’s reason: Treasury, HMRC and Parliament; Specify tax package and official costing
Four weightings
Normalised as 10 × weighted sum ÷ sum of weights, on a 0–30 scale. Where a criterion is not yet assessed, the range is the lowest and highest result if it were later scored 0 or 3 — not a score, a confidence interval or a rank.
- Equal weights: Range if completed: 11.0–20.0 out of 30. Not yet assessed: increment beyond baseline (Ad), expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Evidence doubled: Range if completed: 10.9–19.1 out of 30. Not yet assessed: increment beyond baseline (Ad), expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Scale doubled: Range if completed: 11.8–20.0 out of 30. Not yet assessed: increment beyond baseline (Ad), expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Cost ignored (the funding gate still applies): Range if completed: 12.2–18.9 out of 30. Not yet assessed: increment beyond baseline (Ad), expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
Funding gate: Not passed — the cost is not yet assessed or no allocation is committed for this scope. Ignoring cost in a weighting never removes the gate.
Delivery risk and gate
Delivery risk shown: AmberReview’s claim: Amber. Best the recorded evidence allows: Amber.
Review’s reason: Net receipts after behaviour, administration and transition; investment and compliance effects.
Why it is not Green yet
- Scope (population, place and increment) not verified against the delivery baseline.
- No verified owner with the powers in place.
- Delivery capacity not verified.
- Lifetime incremental costs not complete.
- No credible funding (a committed allocation for the scope).
- Safeguards not specified.
- Monitoring lacks a metric, a data source or a baseline.
Green needs verified scope, a verified owner with the powers, verified capacity, complete lifetime costs with credible funding, specified safeguards and monitoring with a metric, source and baseline. Amber means appraisal gaps remain; Red means a material delivery obstacle. Red does not mean unimportant.
Gate: Pending — appraisal incomplete (review label: “Pending: incomplete appraisal”).
Why: Scores incomplete; Funding gate not passed (cost unknown or no credible funding).
The gate is separate from national list membership: being listed does not make an option eligible, and an eligible option need not be listed.
Cost and funding
Lifetime costing: Not established. Review: “Full incremental costing not established in reviewed material”.
Still to cost: Net receipts after behaviour, administration and transition; investment and compliance effects.
Funding status: not a spending proposal.
Owner, powers and capacity
Proposed owner: Treasury, HMRC and Parliament (proposed, unverified).
Powers: needs legislation or external agreement. Capacity: unverified.
Powers and capacity read from the review’s Rd and Ca anchors; no proposed owner has agreed to act (the review: “Proposed owners have not agreed to act”).
- England:
- HM Treasury and HMRC, with Parliament through a Finance Act (action record)
- Scotland:
- HM Treasury and HMRC, with Parliament through a Finance Act (action record)
- Wales:
- HM Treasury and HMRC, with Parliament through a Finance Act (action record)
- Northern Ireland:
- HM Treasury and HMRC, with Parliament through a Finance Act (action record)
Capital gains tax and inheritance tax are reserved and UK-wide.
Dependencies, safeguards and risks
Depends on: None recorded.
Safeguards
None specified yet.
Risks and residual harms: Forestalling, avoidance and investment effects; progressivity must be demonstrated.
Monitoring and measured results
Metric: Net receipts, incidence and behavioural response.
Data source: Not yet named. Baseline: Not yet established.
Measures already on the domain page
- Cost of business asset disposal relief: latest £1,000m (2025–26 forecast £800m) (2023–24 (outturn)); baseline not published (United Kingdom).
- Capital gains tax receipts: latest £24,310m (2025–26); baseline £13,687m (2024–25) (United Kingdom).
A page measure is not necessarily the review’s metric; linking the two is an editorial decision still to be made.
Evidence for the outcome
Outcome: Net receipts, incidence and behavioural response.
Illustrative rate changes and another party’s design do not cost the proposed relief package. Effects depend on exact reliefs and behaviour.
SWOT points it addresses
- Reliefs narrow the capital taxes: business asset disposal relief cost about £1.0bn in 2023–24 and agricultural and business property relief about £1.9bn in 2022–23, while gains held at death are not taxed and HMRC does not estimate their cost. The OBR expects behaviour to remove about 60% of the static yield of the 2024 capital gains tax rate rises. (Tax options)
- Behaviour can wipe out simple yields: on HMRC’s figures, +10 points on the higher rate of capital gains tax loses about £2.06bn, while +1 point on inheritance tax raises about £0.24bn. (Tax options)
Review record
Assessment status: Provisional single-reviewer assessment; not an approved business case.
Reviewer: Original assessment author (name not supplied). Reviewed: 6 October 2026.
Scored in the working review of 6 October 2026 on the shared ten-criterion scale (one reviewer); not independently calibrated.
First 90 days (review): Produce a signed scope and current-delivery baseline; Name reliefs, thresholds, interactions and transition; obtain distributional/behavioural costing and administrative assessment. Obtain incremental costs and an accountable decision before expansion.
Decision route: Specify tax package and official costing
An editorial screening framework by one reviewer, not a formal appraisal or business case. Proposed owners have not agreed to act.