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From April 6th 2026, Agricultural Property Relief (APR) and Business Property Relief (BPR) will be capped at £2.5 million combined. Gifts made before April 5th 2026 can still receive unlimited relief. This is a one-time opportunity for families with farms or businesses.
This is a one-time opportunity. Assets transferred or restructured before April 5th 2026 can still receive unlimited APR and BPR relief. After April 6th, relief is capped at £2.5 million.
Time remaining: Consult a professional immediately if you own a farm or business worth over £2.5 million.
Before April 6th (Current Rules):
Full £5m receives 100% APR relief
Inheritance tax: £0
After April 6th (New Rules):
First £2.5m: 100% relief
Next £2.5m: 50% relief (£1.25m taxable)
Inheritance tax: £500,000 (40% of £1.25m)
Agricultural Property Relief (APR) applies to:
If your farm is worth over £2.5 million (£5m for married couples), you'll pay significantly more IHT after April 6th.
Business Property Relief (BPR) applies to:
Family businesses worth over £2.5 million will face a 20% effective IHT rate on the excess after April 6th.
Alternative Investment Market (AIM) shares currently receive 100% BPR after 2 years' ownership. The new £2.5 million cap will apply to AIM portfolios as well.
The £2.5 million cap is combined across both APR and BPR. If you own both a farm (APR) and a business (BPR), the total relief is capped at £2.5 million, not £2.5 million for each.
Transfer ownership of farm or business assets to the next generation before April 5th. These transfers will qualify for unlimited APR/BPR under current rules. Understanding the 7-year gifting rule is crucial when planning lifetime gifts.
How it works:
⚠️ Tax implications:
Change how assets are owned to maximise relief under current rules. This might involve transferring assets between spouses or creating new ownership structures.
Strategies to consider:
Important: Restructuring must be completed and documented before April 5th. Allow time for legal work and valuations.
Update your will to account for the new £2.5 million cap and ensure your estate plan maximises available reliefs.
What to review:
If you own farm or business assets worth over £2.5 million, act now. Professional advice takes time, and any transfers must be completed before April 5th.
Week of Feb 3-9: Urgent Consultation
Week of Feb 10-16: Valuation and Planning
Week of Feb 17-23: Make Decisions
Week of Feb 24-Mar 2: Execute Transfers
Week of Mar 3-9: Documentation
By April 5th: Final Deadline
⚠️ This is complex tax planning - do not attempt without qualified professional advice
Inheritance tax, capital gains tax, and gift planning interact in complicated ways. Mistakes can cost hundreds of thousands of pounds. Professional fees are a small price compared to potential tax savings.
STEP members specialise in inheritance tax and estate planning.
Website: www.step.org/find-a-member
Solicitors and accountants who specialise in farm succession and APR planning.
NFU Legal Services: www.nfumutual.co.uk/legal-services
CLA (Country Land and Business Association): www.cla.org.uk
Phone: 0300 123 1072
Hours: Monday to Friday, 9am to 5pm
Note: HMRC cannot give personalised tax advice but can explain the rules and how they apply generally.
Gifting assets during your lifetime may trigger Capital Gains Tax. However, Gift Hold-Over Relief may allow you to defer CGT until the recipient sells the asset. Discuss with your accountant.
Gifts made before April 5th 2026 will use unlimited APR/BPR, but you still need to survive 7 years for the gift to be fully exempt from your estate. If you die within 7 years, the gift is included in your estate but receives the unlimited relief (not the new capped version).
If you gift assets but continue to benefit from them (e.g., living rent-free in a gifted farmhouse), this may create a "gift with reservation of benefit" and lose the IHT advantage. Structure carefully with professional advice.
Transfers must be legally complete before midnight on April 5th 2026. Allow sufficient time for legal work, registrations, and any required approvals. Don't leave it to the last minute.
If you own qualifying assets worth over £2.5 million and take no action before April 5th:
For a £5 million farm, doing nothing means your family faces a £500,000 IHT bill instead of £0. That's £500,000 that could have been saved with proper planning before April 5th.
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