CGT Reliefs: Entrepreneur's and Holdover

I’m trying to get my head around the interaction between these two reliefs.

Entrepreneur’s can either be on the disposal of a whole/part of a business as a going concern, assets of a business that has ceased, or unquoted shares securities of a company. In all cases the relief is restricted to relevant business assets (so no investments), or in situations where the asset was only used partly for business.

Holdover relief is for any gift or sale at undervalue of a relevant business asset where a gain can be reduced to nil for the donor, with the donee reducing the base cost of the asset for future disposal. Any consideration received by the donee becomes immediately chargeable.

I know there are other conditions attached to each, but I’m trying to keep the post short.

So, if you get a question where a whole business has been disposed of for full market value (and it meets all the conditions), you immediately consider Entrepreneur’s relief. There is no element of gift, so holdover isn’t applicable.

If someone gifted their whole business for no consideration, then it will be deemed to be at market value, and assuming it still meets the conditions for Entrepreneur’s relief, you now have the option of both reliefs. Holdover would reduce the gain to nil, so that would be preferable to Entrepreneur’s. Again, you’d only use one relief.

If someone sold their entire business at undervalue, again it would be considered to be at market value. The consideration actually received would be immediately chargeable, but if the conditions were satisfied you could use Entrepreneur’s relief on this gain. The remainder is deferred to the donee under holdover relief.

If someone sold a business asset (qualifying) at undervalue, and the business was a going concern, the only available relief would be holdover. If it was for full market value then there is no element of gift, so there is no relief available (unless the donor replaces the business asset – rollover relief).

If someone sold a business asset (qualifying) at undervalue, and the business had ceased, then both Entrepreneur’s relief and holdover relief would be available. Defer as much gain as possible, any consideration received that is immediately chargeable can be relieved through Entrepreneur’s relief.

So I guess in conclusion, that even if all conditions are met, you use gift holdover relief first and then Entrepreneur’s relief on any gain that is left. Are there any other things you can think of in terms of how these reliefs interact, and how you think about them?