• Sectors we work in banner(2)

    Quick Reads

The Budget: implications for agricultural property relief

The long awaited Budget has now been delivered, although we await the details which will be published shortly.

The announcements made in the House represent extremely sobering news for farmers and landowners.  Business property relief (BPR) and agricultural property relief (APR) will be subject to a £1m combined cap of 100% relief; values in excess of this amount will only benefit from 50% relief from April 2026. 

The Chancellor claimed that the £1m 100% band would help protect small farms.  However, £1m is likely to be insufficiently generous for even the smallest of farms, meaning that practically all farmers can now expect to be subject to inheritance tax (IHT) on their deaths.  Those whose farms include amenity, or development value, or with higher local land prices (such as the South of England) will be particularly impacted by these measures.

Subject to the “small print”, for those landowners / farmers who can afford to give away their assets it is likely that, before these measures are introduced in April 2026, we will see a rush of landowners / farmers settling assets into trust or making gifts to the next generation in order to benefit from the current, much more generous, levels of relief.  Such planning will be attractive assuming that the current regime on lifetime gifts (known as PETs) and holdover relief from capital gains tax remain unaffected by the Budget.  Although there was no announcement in the House, the detail remains to be published and analysed.  For those who choose the trust option, careful thought will need to be given as to the funding of 10 year charges (which will be at an effective rate of 3% if APR is only available at 50%); for older trusts we are likely to see an increase in Court applications to enable income to be retained to meet these charges.

However, such planning will not be an option for those farmers who are financially dependent on their agricultural assets.  In order for gifts to be effective for IHT purposes, the donor cannot benefit further from them.  For these farmers, their planning options will be severely limited and the impact of the IHT charge on their death may, in the absence of other liquidity, lead to the break-up of their farms.  A sector which has low-yield and high-capital values is poorly placed to build up reserves to meet IHT charges. 

There are likely to be very strong reactions from the farming communities to these announcements.  APR was introduced to safeguard farms from being sold on death, providing inter-generational farming security.  These measures put this at risk.  In addition, for the reasons outlined above, the measures are most likely to harm farmers whose livelihoods depend on their farms.

The implications of these reforms will be widespread and will take some time to develop fully.  We may see an adjustment in land values, for example.  We also await the detail on how existing nuances in the APR (which, for example, treats let land differently to in-hand land) will carry across into the reformed relief.  This may produce further implications for landowners of let land, versus in-hand farmers.

The Spring Budget also promised to extend APR to environmental schemes.  This was seen as a key development in incentivising activities which support the UK’s climate targets.  It will be interesting to see whether this extension will be preserved under the Labour reforms and, if so, whether environmental schemes remains a commercially viable option for farmers which will (presumably) have to work harder than ever to build reserves in order to meet IHT on death.

The announcements made in the House represent extremely sobering news for farmers and landowners.  Business property relief (BPR) and agricultural property relief (APR) will be subject to a £1m combined cap of 100% relief; values in excess of this amount will only benefit from 50% relief from April 2026.

Our thinking

  • Blazing a Trail in Real Estate: Inspiring Female Leaders of the Future

    Georgina Muskett

    Events

  • Residential PEEPs Breakfast Panel

    Richard Flenley

    Events

  • Commonhold: Best Supporting Tenure or Leading Role?

    Sarah Bradd

    Quick Reads

  • Charles Russell Speechlys Strengthens Swiss Tax Capabilities with Appointment of Frédéric Ney in Geneva

    Frédéric Ney

    News

  • Biodiversity Net Gain: VAT considerations for Land Managers

    Elizabeth Hughes

    Insights

  • Entrepreneurship, Investment and Risk: Key Insights for Family Offices

    Marcus Yorke-Long

    Quick Reads

  • Construction News quotes Francis Ho on John Lewis shelving its build-to-rent property plans

    Francis Ho

    In the Press

  • eprivateclient quotes Richard Honey and Charlotte Hill on how the Property (Digital Assets) Act in the UK is impacting private clients

    Charlotte Hill

    In the Press

  • Sally Ashford comments in Spear's, IFA Magazine, and eprivateclient on the UK Spring Statement

    Sally Ashford

    In the Press

  • Tamasin Perkins writes for IFA Magazine on risks arising from the intersection of family wealth and commercial lending

    Tamasin Perkins

    In the Press

  • Property Patter: how to prepare for Martyn’s Law

    Ben Butterworth

    Podcasts

  • China stepping up efforts to attract foreign investment — New measures and new trends

    Shirley Fu

    Insights

  • Swiss Federal Supreme Court Rules: No Transfer of Holiday Home to Trust Without Authorisation

    Alexia Egger Castillo

    Quick Reads

  • Why the UK Remains Attractive to US Wealth Owners

    Paul McCarthy

    Quick Reads

  • Matt Foster comments in the Financial Times and the Daily Mail on the importance of cryptocurrency disclosure in divorce proceedings

    Matt Foster

    In the Press

  • SFI26: What Agricultural Practitioners Need to Know

    Maddie Dunn

    Quick Reads

  • UK TAX FOR US PEOPLE

    Sangna Chauhan

    Insights

  • eprivateclient names Piers Master in its 2026 Most Influential list for the sixth consecutive year

    Piers Master

    News

  • Understanding Share Classes in Family Investment Companies

    Edward Robinson

    Quick Reads

  • The collapse of Carillion plc and the final FCA fine issued

    Claudine Morgan

    Quick Reads

Back to top