The Labour government announced in the 2024 Autumn Budget that, from 6 April 2026, the availability of 100% agricultural property relief and business property relief will be restricted. This article focuses on the changes to business property relief, also known as BPR.
BPR is an Inheritance Tax (IHT) relief available against ‘Relevant Business Property’. This can include, but is not limited to, the following:
- A sole trade business or a partnership share
- Shares in an unlisted trading company
Currently, qualifying assets receive 100% BPR meaning transfers of these assets, either to a trust, or on death, will not give rise to an IHT liability.
Autumn Budget changes
Under the proposed Autumn Budget changes, assets currently eligible for 100% Business Property Relief (BPR) will only qualify for full relief on the first £1 million of value. Any value above this threshold will attract BPR at a reduced rate of 50%.
This is best illustrated with an example:
An individual dies owning shares in an unlisted family trading company valued at £5 million.
Post 5 April 2026
If the individual passed away after 5 April 2026, under the proposed changes, the first £1 million of these shares would qualify for 100% BPR.
However, the remaining shares, valued at £4 million, will only receive relief at a rate of 50% i.e. £2 million will be free of Inheritance Tax.
The remaining £2 million will be subject to Inheritance Tax at a rate of 40%, and assuming all other available allowances are utilised against the remainder of the estate, this will create an IHT liability of £800,000.
Pre 6 April 2026
If the individual were to pass away before 6 April 2026, the full value of the shares will receive 100% BPR, and no IHT will be payable.
A table, detailing the increased IHT liabilities based on company share value, from 6 April 2026, is provided below;
| Value of company | IHT – pre 6 April 26 | IHT – post 5 April 26 | Effective net company value | Effective tax rate |
| £1 million | £0 | £0 | £1 million | 0% |
| £3 million | £0 | £400,000 | £2.6 million | 13.33% |
| £5 million | £0 | £800,000 | £4.2 million | 16% |
| £8 million | £0 | £1.4 million | £6.6 million | 17.5% |
| £10 million | £0 | £1.8 million | £8.2 million | 18% |
| £15 million | £0 | £2.8 million | £12.2 million | 18.6% |
| £20 million | £0 | £3.8 million | £16.2 million | 19% |
| £50 million | £0 | £9.8 million | £40.2 million | 19.6% |
Cashflow issues
BPR qualifying assets are typically non-liquid, and while they may hold significant value, they are unlikely to be readily convertible to cash. This can create an issue when having to settle the outstanding IHT with HMRC.
HMRC recognise this and will allow the IHT payable in respect of the BPR qualifying assets to be paid in instalments, over a period of 10 years. In the example outlined above, £80,000 of IHT would be payable each year, until the liability is settled.
Depending on the deceased’s other assets, this may create a cashflow problem, and a question mark over how the tax can be funded. If the tax is paid late, HMRC will apply late payment interest. The HMRC interest rate is currently 8.5% per annum.
Can you mitigate your liability
Depending on the value of your qualifying BPR assets, the upcoming changes may create significant IHT liabilities overnight.
Thankfully, there remains a number of tax planning strategies to mitigate your tax exposure, ranging from simple outright gifts, to more complex trust structures.
The team at Menzies will work alongside you to devise a suitable plan that fits both your long term aims and your family requirements.
If you have any questions, or would like to review your inheritance tax position, please get in contact with the Menzies Private Client Team.
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