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The Bench Report
Inheritance Tax Reforms: The £1 Million Cap on Farm and Business Property Reliefs
Significant changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) for Inheritance Tax (IHT) were announced in the Autumn Budget 2024, commencing in April 2026. Historically, these reliefs allowed up to 100% of eligible assets to be exempted from IHT. The government is introducing a £1 million cap on the combined 100% relief for APR and BPR, with 50% relief applying to value above that threshold. The aim is to target a wealthy minority of estates and raise funds. However, the policy has sparked debate, with concerns raised by farming organisations about negative impacts on family businesses and the administrative complexity of the new rules.
Key Takeaways in Bullet Points
- From April 2026, the maximum value of assets eligible for 100% Agricultural Property Relief (APR) and Business Property Relief (BPR) combined will be capped at £1 million.
- The standard Inheritance Tax rate is 40% on an estate’s value above the nil-rate band of £325,000.
- HM Revenue and Customs (HMRC) estimates that around 2,000 estates per year will pay more tax due to these reforms, assuming no changes in taxpayer behavior.
- Economic think tanks generally support the policy, arguing that assets should be taxed similarly and that existing reliefs favored certain asset types.
- Agricultural organizations argue the changes will negatively affect farming businesses, with one group claiming up to 70,000 farms could be harmed over 40 years.
Definitions
- Inheritance Tax (IHT): A tax charged on the ‘net estate’ (assets minus debts) of someone who has died, typically at a 40% rate if the estate exceeds the £325,000 threshold.
- Agricultural Property Relief (APR) and Business Property Relief (BPR): These are inheritance tax reliefs that shelter the value of eligible agricultural land or business assets from IHT, often at a 100% rate.
- £1 Million Cap: The new limit, applicable from April 2026, on the combined value of assets that can qualify for 100% APR and BPR.
Source: Changes to agricultural and business property reliefs for inheritance tax
Research Briefing
Wednesday, 10 December, 2025
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Contains Parliamentary information repurposed under the Open Parliament Licence v3.0...
Hello and welcome once more to the Bench Report, where we discuss recent debates from the benches of the UK Parliament, a new topic every episode. You're listening to Amy and Ivan. Today we have a really critical piece of policy change to unpack. The proposed overhaul of inheritance tax reliefs, the ones that uh specifically protect farms and family businesses. We're going to try and cut through the jargon to see what the real impact of this new cap might be.
Amy:Exactly. To set the stage, we're focused on two major tax shields: agricultural property relief, or APR, and business property relief, BPR. Historically, these have you know allowed up to 100% of the value of these assets to be taken out of the IHT calculation.
Ivan:And that's cost the Treasury a fair bit.
Amy:It has, around $1.7 billion in the 2021-22 financial year alone.
Ivan:So that figure is really the core driver for this government decision. What's the big change they've announced?
Amy:Well, the change was announced at the autumn budget 2024, and from April 2026, the 100% relief rate for these assets, APR and BPR combined, will be capped.
Ivan:Capped at what level?
Amy:At 1 million pounds. Anything above that new threshold, well, it only gets 50% relief.
Ivan:And this isn't just about land and traditional businesses.
Amy:No, not at all. The government is also reducing the relief on unlisted shares. So shares traded on the alternative investment market aim shares.
Ivan:And what's happening there?
Amy:Those will drop from 100% relief straight down to 50%. The message is, I think, quite clear. The most generous tax shields are being significantly curtailed. Trevor Burrus, Jr.
Ivan:To target estates the government considers um excessively wealthy.
Amy:That is the official line, yeah.
Ivan:Okay, let's unpack that. Because HMRC's own estimates claim only about 2,000 estates a year will end up paying more tax. That's right. But then you have agricultural bodies like the Country Land and Business Association sounding a huge alarm. They're talking about 70,000 farms over the next 40 years.
Amy:Uh-huh.
Ivan:How do you reconcile that massive discrepancy for the listener?
Amy:Well, it's not a data error. It's a uh it's a difference in definition in what's being measured.
Ivan:Difference in definition.
Amy:HMRC is using a static estimate. It's only looking at the estates that become liable for more tax immediately because of this new rule. The CLA, on the other hand, is using long-term farm size data. They're modeling the pressure this cap puts on future succession planning.
Ivan:So it's about the long-term planning, not the immediate tax bill.
Amy:Precisely. It means farming families are forced to fundamentally change how they pass down their assets to avoid, well, potentially ruinous tax bills decades from now.
Ivan:And what's the broader economic view on this?
Amy:What's fascinating here is that a think tank like the Institute for Fiscal Studies actually supports this reform.
Ivan:Why is that?
Amy:Their core argument is that the tax system shouldn't distort the market. It shouldn't give preferential treatment to specific assets like farmland over, say, other investments.
Ivan:Okay, leaving the big numbers aside for a moment, what does this look like on the ground? It sounds like an administrative headache.
Amy:The professional bodies, like the Chartered Institute of Taxation, are deeply concerned about the compliance burden, the sheer amount of paperwork. Even if you are well under the cap and owe zero tax, you'll now need to get full, formal valuations of all your assets.
Ivan:Just to prove you fall below the one million town limit.
Amy:Exactly.
Ivan:And politically, there has been real resistance to this.
Amy:Oh, absolutely. The Environment, Food, and Rural Affairs Select Committee recommended postponing the reforms entirely. Trevor Burrus, Jr.
Ivan:On what grounds?
Amy:They argued that farmers need more time to plan, and they cited an insufficient impact assessment from the government. Trevor Burrus, Jr.
Ivan:And despite all that, and some suggested alternatives like a much higher threshold, the government is holding firm.
Amy:They are. Which leads us to probably the most critical structural change they are introducing with this. Which is unlike almost every other major inheritance tax allowance, like the nil rate ban, this new 1 million cap is not transferable between spouses or civil partners.
Ivan:That brings us to our final thought for you to consider. The non-transferability of this new 1 million pound cap is a significant structural break from how spousal relief typically works in the IHT system. Think about how this asymmetry might force married couples who own large businesses or farms into complex, possibly premature, restructuring. Does introducing a non transferable cap like this inadvertently create a new complex distortion in the IHT system, even as it attempts to fix older ones? As always, find us on social media at Bench Report UK. Get in touch with any topic important to you. Remember, politics is everyone's business. Take care.
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