BPR/APR reforms: Professional advisers guide

The government announced changes to business property relief (BPR) and agricultural property relief (APR) from inheritance tax (IHT) in the October 2024 Budget.

It is proposed that these amendments to the IHT rules will come into effect from 6 April 2026. Assuming the changes are enacted as proposed, they will cap the availability of 100% BPR and APR for individuals and trustees owning qualifying property.

Your clients who either own relievable property (businesses and farmland) or are involved in the running of businesses, farms, or estates need to take advice now to understand the changes and how they may impact them.

Burges Salmon is able to provide a unique breadth of advice to clients, ranging through complex tax advice, corporate restructuring, family asset protection, property advice, employment advice, and contentious matters. The firm has a long history of advising landowners and business owners across the UK.

Key considerations

For many clients, the potential IHT cost may not be affordable or acceptable, bearing in mind the longer-term strategy for succession. In this circumstance, it will be necessary to consider whether any steps can be taken to mitigate this. This might include gifting, either outright or into trust. The timing of any gifts will need to take into account the transitional rules for the IHT changes, the wider succession plans for the relevant assets, and the mid to long-term aims of the business or land owners.

For trustee clients, there are separate considerations of when the rules will apply and that depends on the type of trust and when it began. See our separate page for trustees here for more details.

In all cases, whether changes to ownership are made or not, the IHT changes should be a catalyst for clients to review their affairs and ensure their planning is up to date.

This should include: