Budget changes have reshaped how Agricultural Property Relief (APR) and Business Property Relief (BPR) apply for Inheritance Tax.
For farming families and business owners and those who have alternative market investment shares this is more than a tax adjustment. It affects how estates are structured, how assets pass under a Will and how control is preserved for the next generation.
The new capped system
As from 6th April 2026, the long standing position of unlimited 100 percent relief has been replaced with a cap. A £2.5 million allowance now applies to the combined value of qualifying APR and BPR assets. Up to this level, relief remains at 100 percent.
Above £2.5 million, unless you are married and then potentially have double that allowance, relief reduces to 50 percent, creating an effective 20 percent Inheritance Tax charge on the excess. For estates where wealth is tied up in land, property or business interests, this can significantly alter how an estate can be efficiently dealt with after death.
Why ownership structures now matter more
There are important legal implications behind these figures. While spouses and civil partners can combine allowances, this depends on:
• Who owns the asset
• How it is recorded
• How the Will is drafted
If the structure is wrong, the allowance may not apply in the way the family expects. That can affect who inherits, how quickly assets can be transferred and whether control passes smoothly.
Impact on trusts
Trusts are also directly affected. Existing arrangements may no longer operate as originally intended. The wording of the trust deed and the wider estate planning framework now require careful review to ensure continuity of control and that intended beneficiaries remain protected.
What this means for your Will and Estate plan
At Forrester Sylvester Mackett, we focus on how these changes interact with Wills, Trusts and estate structures in practice. This includes:
• Reviewing how assets are owned
• Ensuring Wills reflect current intentions
• Checking that trusts and business arrangements still achieve the intended outcome on death
This isn’t just about tax exposure. It’s about ensuring your estate passes in a clear, controlled and legally effective way, without uncertainty or unintended consequences for your family or business. The earlier these arrangements are reviewed, the more options remain available.
How we can help
If you have agricultural or business assets, now is the time to get in touch. Speak to a member of our friendly and knowledgeable Wills, Trusts and Probate team today. We’ll put a clear, legally sound estate plan in place to protect what you have built for the future.