succession-plan

---
name: succession-plan
description: Turns your own facts about handing the business to a family member or an existing manager, rather than selling it on the open market, into a dated Business Relief position for Inheritance Tax on a trading business, a Capital Gains Tax holdover position for a lifetime gift under TCGA 1992 section 165, the written notice employment law requires when your successor's role changes, and a timeline ordering the two year clocks against the date you intend to hand over control. Use when the business is going to family or to someone who already works in it, not to a buyer found on the open market.
---

# A dated record for handing the business to your own family or manager, not to the market

You give this who the business is going to, whether they already work in it, and whether the plan is a gift or a sale; a full-value sale is the asset-or-share skill's job. You get back a Business Relief position, a Capital Gains Tax holdover position, the notice employment law requires when the role changes, and a timeline. It will not say whether to gift or sell, or state the tax either of you will pay.

## What it does

1. **Record whether the business qualifies for Business Relief.** Section 105(1)(a) covers "property consisting of a business or interest in a business," relieved 50% under section 104(1), 100% under 104(1A)-(1B), but not an investment business. Section 106 requires it "owned by the transferor throughout the two years immediately preceding the transfer."

2. **Use today's allowance, not the figure first announced.** The October 2024 Budget proposed GBP 1 million from 6 April 2026; it was raised to GBP 2.5 million on 23 December 2025 and is now law at section 124D, with 50% relief above it, transferable to a surviving spouse.

3. **Record whether a gift could hold over the Capital Gains Tax.** GOV.UK states "you do not pay Capital Gains Tax when you give away the assets," for a sole trader, partner, or someone with "at least 5% of voting rights" in a trading personal company. The claim is joint, and the gain reduces the recipient's base cost.

4. **Record what employment law requires when the role genuinely changes.** Section 4, Employment Rights Act 1996, requires a written statement "at the earliest opportunity and, in any event, not later than" one month after the change. Record both dates.

5. **Hand the facts to Codex.** Run:

   ```
   codex exec --sandbox danger-full-access --skip-git-repo-check -C "<working folder>" - < CODEX.md
   ```

   Back comes the Business Relief file, the holdover file, the notice log, and a timeline starting whichever clock is earlier.

## Then it checks

1. Business Relief file states current rates, the allowance, its date, and that it replaced the GBP 1 million design.
2. The two year start date is the one supplied, never assumed.
3. Holdover file states whether the 5% and trading conditions are met, and that the claim is joint.
4. Every role change carries a change date and a statement date, or states none given.
5. No file states the tax, or favours a route.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never state the tax either will actually pay; that is the accountant's.
- Never quote the allowance or the two year test without re-checking it; it has moved once.
- Never assume a section 4 statement was given on a verbal promotion alone.
- Owner-dependency and valuation-basis cover training and price, not repeated here.
- This is a working document for the owner's accountant and solicitor to check. It is not legal or tax advice, and never recommends a gift over a sale or a sale over a gift.

## Built from
- Inheritance Tax Act 1984, section 104, https://www.legislation.gov.uk/ukpga/1984/51/section/104, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026: the 50% default rate and the 100% rate in steps 1 and 2.
- Inheritance Tax Act 1984, section 105, https://www.legislation.gov.uk/ukpga/1984/51/section/105, up to date with all changes known to be in force on or before 13 October 2026, read 14 October 2026: the definition of relevant business property in step 1.
- Inheritance Tax Act 1984, section 106, https://www.legislation.gov.uk/ukpga/1984/51/section/106, up to date with all changes known to be in force on or before 13 October 2026, read 14 October 2026: the two year minimum ownership period in step 1.
- Inheritance Tax Act 1984, section 124D, inserted by the Finance Act 2026, https://www.legislation.gov.uk/ukpga/1984/51/section/124D, up to date with all changes known to be in force on or before 12 October 2026, read 14 October 2026: the GBP 2.5 million 100% relief allowance in step 2.
- GOV.UK, "Changes to agricultural property relief and business property relief", https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief, published 26 November 2025, last updated 3 March 2026, read 14 October 2026: the increase from GBP 1 million to GBP 2.5 million, the 50% rate above it, and spouse transferability, in step 2.
- GOV.UK, "Work out how to apportion agricultural and business relief for inheritance tax", https://www.gov.uk/guidance/work-out-how-to-apportion-agricultural-and-business-relief-for-inheritance-tax, published 6 April 2026, read 14 October 2026: confirms the GBP 2.5 million allowance and the GBP 5 million transferred figure in step 2.
- GOV.UK, "Business Relief for Inheritance Tax", print version, https://www.gov.uk/business-relief-inheritance-tax/print, no publication or updated date shown, read 14 October 2026: the two year ownership wording, the 100% and 50% categories, the investment exclusion and the sale exclusion, in step 1.
- Taxation of Chargeable Gains Act 1992, section 165, https://www.legislation.gov.uk/ukpga/1992/12/section/165, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026: the joint claim and the held-over gain in step 3.
- GOV.UK, "Gift Hold-Over Relief", https://www.gov.uk/gift-holdover-relief, no publication or updated date shown, read 14 October 2026: the sole trader and personal company conditions, the trading condition and the joint claim in step 3.
- Employment Rights Act 1996, section 4, https://www.legislation.gov.uk/ukpga/1996/18/section/4, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026: the written statement of changes and the one month deadline in step 4.

# succession-plan

## You are given
The owner's own facts: the business structure, the successor's relationship and whether already an employee, whether the plan is a gift, a part gift, or a full-value sale, the owner's shareholding and voting rights percentage and whether it reaches 5%, whether the owner is an officer or employee, the date the owner's ownership began, whether the business is mainly trading or mainly securities, land, buildings or investments, whether it is being marketed to anyone other than the named successor, every change to the successor's role, pay, hours or authority with its date, whether a written statement was given and when, and the owner's own estimate of how long each remaining step needs, with the reason. Every judgement is already made by the owner and supplied as a stated fact.

## Produce
Write into `./succession-plan-output/`:
1. `business-relief-position.csv`, columns `condition_ref`, `condition`, `met`, `basis_stated_by_owner`, `date_recorded`. One row each for: business or interest in a business; not mainly securities, land, buildings or investments; owned throughout the two years before transfer; not being sold to anyone other than the successor. `met` is `yes`, `no`, or `not stated by owner`.
2. `holdover-relief-position.csv`, columns `condition_ref`, `condition`, `met`, `basis_stated_by_owner`. Rows for: gift or undervalue transfer; sole trader or partner, or 5% voting rights in a personal company; company mainly trading; successor agreed to the joint claim.
3. `employment-notice-log.csv`, columns `change_ref`, `change_description_verbatim`, `date_of_change`, `written_statement_given`, `date_statement_given`, `deadline_one_month`. `deadline_one_month` is calculated only from the supplied `date_of_change`.
4. `handover-timeline.csv`, columns `item_ref`, `item`, `clock_type`, `start_date`, `owner_estimated_weeks`, `reason_for_estimate`. `clock_type` is exactly one of `business relief ownership test`, `holdover personal company test`, `employment notice deadline`, `training or authority handover`. Sort by `start_date` ascending.
5. `gaps.md`, a numbered list of every condition recorded `not stated by owner` and every change with no `date_statement_given`.

## Rules
Codex transcribes, sorts, and calculates only the one month deadline from a supplied date. It never decides whether a condition is met, never estimates a lead time or a start date not supplied, and never states a specific tax figure. British English, GBP as `GBP`, DD Month YYYY dates, no em dashes; supplied text with one is recorded verbatim and flagged. Every file ends: a working document for the owner's own accountant and solicitor to check. It applies supplied facts to published conditions and is not legal, tax, or valuation advice, and not a recommendation to gift or sell.

## Return
The path of every file written, the row counts, the count of `not stated by owner` conditions per file, the count of changes with no statement date, and the earliest `start_date` with its item.

Sources for succession-plan

Everything below was opened and read on 14 October 2026. Nothing is cited that could not be loaded.

1. Inheritance Tax Act 1984, section 104

https://www.legislation.gov.uk/ukpga/1984/51/section/104, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026.

Section 104(1) sets the default rate: "the whole or that part of the value transferred shall be treated as reduced by 50%." Subsections (1A) and (1B), inserted by the Finance Act 2026 (Schedule 12, paragraphs 2(2)(a), 2(2)(b) and 2(3)), raise that to "is to be treated (instead) as reduced by 100%" for the categories of property the section names. This is the rate step 1 of the skill applies, and the page's own currency note confirms the 2026 Act has already amended it, which is why the skill reads the section directly rather than relying on a summary that might predate the amendment.

Where the skill departs: section 104 also sets rates for agricultural property and for certain controlling shareholdings in a listed company, neither of which is the independent hospitality owner's own trading business this skill is built for, so only the business and unlisted-share rates are used.

2. Inheritance Tax Act 1984, section 105

https://www.legislation.gov.uk/ukpga/1984/51/section/105, up to date with all changes known to be in force on or before 13 October 2026, read 14 October 2026.

Section 105(1)(a) defines the first category of relevant business property as "property consisting of a business or interest in a business." This is the qualifying test step 1 records before anything else, because relief only exists at all for property that falls within this definition.

Where the skill departs: section 105 goes on to define several further categories, including unlisted shares and land, buildings or machinery used in a business, which the skill's companion owner-dependency and asset-or-share skills already touch on in their own contexts. This skill cites only paragraph (a), the core trading business category.

3. Inheritance Tax Act 1984, section 106

https://www.legislation.gov.uk/ukpga/1984/51/section/106, up to date with all changes known to be in force on or before 13 October 2026, read 14 October 2026.

Section 106 states plainly: "Property is not relevant business property in relation to a transfer of value unless it was owned by the transferor throughout the two years immediately preceding the transfer." This is the clock step 1 tells the owner to date from its start, not its end, because a transfer made one day short of two years of ownership fails the test entirely regardless of how long the business has otherwise been trading informally.

Where the skill departs: the Act also allows successive or replacement ownership periods to count toward the two years in some circumstances, under provisions this skill does not reproduce, since a straightforward single-owner hospitality business is the case it is built for. An owner relying on a replacement-property argument needs their own accountant's reading of those provisions.

4. Inheritance Tax Act 1984, section 124D, inserted by the Finance Act 2026

https://www.legislation.gov.uk/ukpga/1984/51/section/124D, up to date with all changes known to be in force on or before 12 October 2026, read 14 October 2026.

This is the primary legislative source for the figure the skill is built around, and it was checked directly rather than taken from commentary precisely because the figure had already changed once. Subsection (2) defines the "100% relief allowance" and opens with "(a) £2.5 million, less" the amount already used by earlier transfers in the same allowance period. The section was inserted by the Finance Act 2026, Schedule 12, paragraphs 4 and 17, and the legislation.gov.uk page shows it as current law, not a prospective clause still awaiting commencement, which confirms the GBP 2.5 million figure is actually in force for the 6 April 2026 date rather than merely proposed.

Where the skill departs: section 124D also defines how the allowance apportions between agricultural and business property and how it interacts with trust allowances under sections 124G to 124K, both of which sit outside a single trading hospitality business with no agricultural land and are not reproduced here.

5. GOV.UK, "Changes to agricultural property relief and business property relief"

https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief, published 26 November 2025, last updated 3 March 2026, read 14 October 2026.

This policy paper is the source for the correction the skill makes to the figure most commentary still quotes. It states that "a new £2.5 million allowance will apply to the combined value of property" qualifying for 100% relief, that "relief at the lower rate of 50% will apply to the value of any qualifying relievable property over £2.5 million," and that "any unused amount of the new £2.5 million allowance can be transferred to a surviving spouse or civil partner." It confirms the change takes effect "from 6 April 2026" and that the allowance was increased from an earlier £1 million design.

Where the skill departs: the paper also sets out the reduction of business property relief to 50% for shares on a recognised stock exchange not meeting HMRC's definition of listed, such as AIM shares, which does not arise for a sole trading hospitality business with no quoted shareholding and is not used here.

6. GOV.UK, "Work out how to apportion agricultural and business relief for inheritance tax"

https://www.gov.uk/guidance/work-out-how-to-apportion-agricultural-and-business-relief-for-inheritance-tax, published 6 April 2026, read 14 October 2026.

This guidance page independently confirms the figure from source 5 in operational terms: for deaths on or after 6 April 2026, qualifying property can receive 100% relief "up to a maximum of £2.5 million," falling to 50% above it, and an unused allowance transferred from a predeceased spouse or civil partner "could make this allowance up to £5 million." Having two separately published gov.uk sources state the same figure, one a policy paper and one a working guidance page, is why the skill treats GBP 2.5 million as the figure to use rather than a single page's wording.

Where the skill departs: the page's worked apportionment examples split the allowance across agricultural and business property together, which does not arise where the only qualifying property is a trading hospitality business, so the apportionment mechanic itself is not reproduced.

7. GOV.UK, "Business Relief for Inheritance Tax", print version

https://www.gov.uk/business-relief-inheritance-tax/print, no publication or updated date shown, read 14 October 2026.

The print version carries the plain-English statement of the two year rule, "you can only get relief if the deceased owned the business or asset for at least 2 years before they died," applied the same way to a lifetime gift. It also states the exclusion the skill records: Business Relief does not apply where the business "mainly deals with securities, stocks or shares, land or buildings, or in making or holding investments," and does not apply where the business "is being sold, unless the sale is to a company that will carry on the business" and the estate is paid mainly in that company's shares.

Where the skill departs: the print guide's wording on the sale exclusion is aimed at a transfer on death; the skill applies the same wording to a lifetime gift, which the underlying legislation treats the same way, but it records this as the owner's own fact to confirm, not as a settled conclusion the skill reaches on its own.

8. Taxation of Chargeable Gains Act 1992, section 165

https://www.legislation.gov.uk/ukpga/1992/12/section/165, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026.

Section 165(1)(b) requires "a claim for relief under this section is made by the transferor and the person who acquires the asset," which is the joint claim step 3 records as the owner's own fact to confirm with the successor. Section 165(4) provides that both the transferor's and the transferee's positions "shall each be reduced by an amount equal to the held-over gain on the disposal," which is the mechanism behind the skill's statement that the gain is deferred into the recipient's base cost rather than cancelled.

Where the skill departs: section 165 also sets out the qualifying categories of business asset in detail, which the skill summarises through the GOV.UK guidance at source 9 rather than quoting the statute's own schedule reference, since the guidance states the practical conditions in plainer terms for an owner who is not reading the Act directly.

9. GOV.UK, "Gift Hold-Over Relief"

https://www.gov.uk/gift-holdover-relief, no publication or updated date shown, read 14 October 2026.

The page states the relief in the owner's own terms: "you do not pay Capital Gains Tax when you give away the assets," available to a sole trader or business partner, or someone holding "at least 5% of voting rights in a company" that is their "personal company," whose "main activities must be in trading" rather than investment. It confirms the joint claim: "You must claim jointly with the person you give the gift to."

Where the skill departs: the page also covers gifts to trusts and the separate claim route for trustees, which this skill does not address, since a lifetime gift directly to a named family member or manager is the case it is built for, and a gift into trust needs its own advice on a different claim mechanism.

10. Employment Rights Act 1996, section 4

https://www.legislation.gov.uk/ukpga/1996/18/section/4, up to date with all changes known to be in force on or before 14 October 2026, read 14 October 2026.

Section 4(1) requires a written statement of any change to the particulars required by sections 1 to 3, and section 4(3) sets the deadline: the statement "shall be given at the earliest opportunity and, in any event, not later than" one month after the change. This is the statutory hook the skill uses to separate a genuine change to the successor's role, pay or authority, which the law requires in writing, from training or mentoring that is the owner's own choice and carries no statutory deadline.

Where the skill departs: section 4 also covers changes arising from a worker being posted abroad for more than a month, which does not arise in a hospitality handover and is not used.

The best public prompt found

A search of the anthropics/knowledge-work-plugins and anthropics/skills repositories, using the GitHub contents and git-tree APIs read on 14 October 2026 (GitHub's code search endpoint returned HTTP 401 for an unauthenticated call, so directory listings and a keyword scan of each repository's file tree were used instead), found no skill in either repository addressing succession planning, a family business handover, or Inheritance Tax Business Relief. The knowledge-work-plugins repository's small-business plugin lists 44 skills, covering cash flow, payroll, invoicing, tax preparation and reputation management, and its finance and legal plugins list 8 and 7 skills respectively, covering reconciliation, variance analysis, contract review and NDA triage; none compares a gift against a sale or applies an estate or capital gains relief test. anthropics/knowledge-work-plugins had 29,621 stargazers and anthropics/skills had 181,062, both read from https://api.github.com/repos/anthropics/knowledge-work-plugins and https://api.github.com/repos/anthropics/skills on 14 October 2026, but since no closer match exists, these figures describe the repositories as a whole rather than a comparable skill.

What was deliberately not copied: nothing, because nothing comparable was found. The closest structural relative is the same knowledge-work-plugins legal/skills/review-contract skill noted in the companion asset-or-share SOURCES.md, which reads a single document against a checklist rather than tracking two parallel statutory clocks against a dated handover, so it was not treated as a template.