The government recently announced significant changes to the planned reforms to Agricultural Property Relief (APR) and Business Property Relief (BPR). The threshold for 100% relief will be increased from £1 million to £2.5 million when the changes take effect from 6 April 2026. The change will be introduced via an amendment to the Finance Bill 2025 with relief reduced to 50% on qualifying assets above the new level.

Spouses or civil partners will be able to pass on up to £5 million of qualifying agricultural and business assets between them free of inheritance tax, in addition to the existing nil rate bands. The transferable allowance will also apply to surviving spouses or civil partners who were widowed before the new policy was announced.

These changes adjust the reforms first announced at Autumn Budget 2024, which had attracted strong criticism from the farming community and rural businesses over the potential impact on small farms and family-owned enterprises. By raising the threshold, the government aims to significantly reduce the number of estates affected by higher inheritance tax charges, ensuring that the reforms are focused primarily on the largest estates.

The government estimates that around 85% of estates claiming APR in 2026–27, including those also claiming BPR, will pay no additional inheritance tax as a result of these changes.

Shares designated as “not listed”, such as those traded on AIM, will attract BPR at a flat rate of 50% (reduced from 100%) from April 2026. This measure was unaffected by the latest announcement.

Agricultural and business property relief changes that were first announced at Autumn Budget 2024 will come into effect from 6 April 2026. These measures will introduce significant reforms to Business Property Relief (BPR) and Agricultural Property Relief (APR), which provide Inheritance Tax (IHT) relief on qualifying business and agricultural assets. These measures have faced significant criticism for their potential impact on small farms and rural communities.

From April 2026, a new £1 million allowance will apply to the combined value of property in an estate qualifying for 100% BPR or 100% APR. This means that the existing 100% rate of IHT relief will only apply to the combined value of property in an estate qualifying for 100% BPR or 100% APR. The rate of IHT relief will be reduced to 50% for the value of any qualifying assets over £1 million. Accordingly, any assets receiving 50% relief will be effectively taxed at 20% IHT (the full rate being 40%).

The government has also confirmed they will reduce the rate of BPR available from 100% to 50% in all circumstances for shares designated as 'not listed' on the markets of recognised stock exchanges, such as AIM. The existing rate of relief will continue at 50% where it is currently this rate and will also not be affected by the new allowance.

The option to pay IHT by equal annual instalments over 10 years interest-free will be extended to all qualifying property which is eligible for APR or BPR.

The 2027 reforms will shift more responsibility to personal representatives, who may need to manage withholding arrangements and settle any IHT before pension benefits are released.

From 6 April 2027, most unused pension funds and death benefits will be included in IHT, meaning that more pension assets could be taxed when someone dies. This is a major change from the current rules, which largely exclude these funds from IHT.

Individuals with significant pension savings should review their estate plans carefully. Under the new rules, beneficiaries could face an IHT charge on inherited pension funds. Responsibility for reporting and paying this tax will fall on personal representatives, not the pension scheme administrators.

There are some important exceptions. Death-in-service benefits from registered pension schemes and dependants’ pensions from defined benefit or collective money purchase schemes will continue to be exempt from IHT.

It was announced as part of the Budget 2025 measures that from 6 April 2027, if a deceased person’s estate is expected to owe IHT, their personal representatives can instruct the pension provider to withhold 50% of taxable pension‑death benefits for up to 15 months. They must then pay any IHT due to the tax authorities before releasing the rest to beneficiaries. This does not apply to exempt benefits, small pots (under £1,000) or ongoing annuities. Personal representatives will also be discharged from liability for pensions discovered after they have received clearance from HMRC. 

Certain buildings, land, works of art, and other objects of national significance may be exempt from Inheritance Tax and Capital Gains Tax (CGT) when they are transferred to a new owner. This exemption applies under a special tax relief for national heritage assets that are either gifted or bequeathed.

To qualify for this relief, the asset must meet at least one of the following criteria:

• Buildings, estates or parklands of outstanding historical or architectural interest
• Land of outstanding natural beauty and spectacular views
• Land of outstanding scientific interest including special areas for the conservation of wildlife, plants and trees
• Objects with national scientific, historic or artistic interest, either in their own right or due to a connection with historical buildings

Upon transfer of ownership, the new owner is required to enter into a formal agreement, known as ‘the undertakings. This agreement ensures that the asset will be cared for, made available for public viewing, and retained in the UK. Failure to meet these conditions, or selling the asset, results in the revocation of the tax exemption under the Conditional Exemption Tax Incentive scheme. As a consequence, the asset would then be subject to tax in accordance with the standard rules.

HMRC is guided by the government’s heritage advisory agencies in deciding which assets qualify for exemption.

Gifting assets can cut inheritance tax, but traps like “gifts with reservation of benefit” may undo the plan.

The majority of gifts made during a person's lifetime are not subject to tax at the time they are made. These lifetime transfers are known as "potentially exempt transfers" (PETs). A PET becomes fully exempt from Inheritance Tax if the individual making the gift survives for more than seven years after the transfer.

If the donor dies between three and seven years after making the gift, taper relief may apply, which reduces the amount of tax payable. The effective rates of tax on the excess over the nil-rate band for PETs are as follows:

• 0 to 3 years before death: 40%
• 3 to 4 years before death: 32%
• 4 to 5 years before death: 24%
• 5 to 6 years before death: 16%
• 6 to 7 years before death: 8%

However, different rules apply if the person making the gift retains some benefit or enjoyment of the asset. This typically occurs when the donor does not relinquish full control over the asset, and the transfer is made with a reservation of benefit. These are referred to as ‘gifts with reservation of benefit’ (GWROBs).

A common example is when a person gifts their home to their children but continues to live in it rent-free. In this case, HMRC is likely to argue that the donor’s position has not changed in substance, and that the arrangement constitutes a GWROB. If this is the case, HMRC will not treat it as a valid gift for inheritance tax purposes, and the property would remain part of the donor’s estate, even if they live for more than seven years after making the transfer.

A GWROB can usually be avoided in these situations if the donor pays full market rent for their continued use of the asset.