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Agricultural and Business Property Relief: Current Rules and Planning Considerations for Mixed Estates

· 20 min

Executive Summary

The Finance Bill 2025-26 introduces a combined GBP 2.5 million allowance for 100% agricultural property relief and business property relief from 6 April 2026, with 50% relief on qualifying property above that threshold. The combined nature of this allowance transforms the interaction between APR and BPR from a specialist valuation concern into the central planning question for every estate containing both agricultural and business property. Section 114(1) IHTA 1984 mandates that APR takes statutory priority over BPR, a rule that practitioners cannot override by election. Under capped relief, the proportional allocation mechanism creates a zero-sum dynamic: every pound of qualifying property that consumes the allowance through one relief reduces what remains available for the other. This article provides rural accountants and business tax advisors with an integrated technical framework covering both reliefs' qualifying conditions, the priority rule, combined allowance allocation, and practical planning strategies for mixed agricultural and business estates.

1. The Statutory Architecture of Agricultural Property Relief and Business Property Relief

Agricultural Property Relief: Sections 115-124C IHTA 1984

Agricultural property relief operates within a framework of definition, valuation, occupation, and rate conditions. Section 115(2) IHTA 1984 defines agricultural property as agricultural land or pasture, including woodland and buildings used for intensive livestock or fish rearing where ancillary to agricultural land, together with cottages, farm buildings, and farmhouses "of a character appropriate to the property."1 The farmhouse condition remains a frequent area of HMRC challenge, particularly where properties have been extended or modernised beyond what is proportionate to the agricultural holding.

The valuation mechanism under s 115(3) is foundational to the APR/BPR interaction. Agricultural value is the hypothetical value of the property as if subject to a perpetual covenant prohibiting non-agricultural use.2 The difference between this agricultural value and market value -- encompassing development potential, amenity premium, mineral rights, or lifestyle value -- falls entirely outside APR but may qualify for BPR where the relevant conditions are satisfied.

Qualification requires satisfaction of either the two-year occupation route (s 117(a): the transferor occupied the property for agricultural purposes for two years immediately preceding the transfer) or the seven-year ownership route (s 117(b): ownership for seven years with agricultural occupation throughout).3 The rate of relief is determined by s 116: 100% where the transferor has vacant possession or the right to obtain it within 12 months, or where the tenancy commenced on or after 1 September 1995; 50% for older pre-September 1995 tenancies.4

Two recent amendments reshape the qualifying landscape. From 6 April 2024, APR applies exclusively to UK property, following the Finance Act 2024 removal of the Channel Islands, Isle of Man, and EEA extension.5 From 6 April 2025, s 124C extends APR to land managed under environmental agreements with UK government, devolved governments, public bodies, or approved responsible bodies, replacing the former habitat scheme provisions.6 This extension removes a longstanding barrier for landowners participating in Environmental Land Management schemes who were previously at risk of losing APR on land withdrawn from agricultural production.

Business Property Relief: Sections 103-114 IHTA 1984

BPR provides 100% relief for qualifying businesses, interests in businesses, and unquoted shares, with 50% relief for quoted shares conferring control and for land or machinery used in a controlled company's business (s 104 IHTA 1984).7 The critical gateway is the investment business exclusion at s 105(3): businesses consisting "wholly or mainly" of dealing in securities, land, or making or holding investments are excluded entirely.

The "wholly or mainly" test operates on an all-or-nothing basis. The five-factor framework established in Farmer v IRC [1999] SpC 216 assesses overall context, capital employed, time spent by employees, turnover, and profit.8 A business that is 51% trading qualifies fully; one at 49% receives nothing. For diversified farming operations that include investment elements -- holiday lettings, land rental, solar farm income -- this binary threshold carries significant planning consequences.

The excepted assets rule at s 112 imposes a two-limb test: assets that were neither used wholly or mainly for business purposes throughout the preceding two years (limb a) nor required for future business use (limb b) are excluded from BPR.9 HMRC scrutinises surplus cash holdings with particular rigour, requiring evidence of "some positive decision or firm intention" regarding future deployment. The binding contract exclusion at s 113 denies BPR where a binding contract for sale exists, though HMRC accepts that properly structured cross-option agreements (separate put and call options) do not constitute binding contracts.10

Both reliefs share structural features: a two-year minimum ownership period (s 106 BPR, s 117 APR), replacement property provisions (s 107 BPR), and binding contract exclusions (s 113 BPR, s 124 APR). These parallel structures create both consistency and compound risk where an estate contains property potentially qualifying for either relief.

2. The Section 114 Priority Rule: Agricultural Property Relief First, Business Property Relief Second

The Statutory Mechanism

Section 114(1) IHTA 1984 provides that where the value transferred is reduced by APR -- or would be so reduced but for s 121(3) -- the same part of the value cannot also be reduced by BPR.11 This is a mandatory priority rule, not a discretionary election. HMRC operational guidance at IHTM25121 confirms the position explicitly: "both business relief and agricultural relief can potentially apply to the same property, but to prevent double relief, agricultural relief takes priority" and "it is not possible for the parties to choose between business and agricultural relief."12

Practical Operation

The priority rule operates in a three-stage sequence:

Stage 1: APR applies first to the agricultural value of qualifying property, determined under the s 115(3) perpetual covenant methodology.

Stage 2: BPR may then apply to the difference between market value and agricultural value, provided the property independently satisfies all BPR qualifying conditions under ss 105-113.

Stage 3: The combined allowance (from 6 April 2026) applies to the aggregate of APR-qualifying agricultural value and BPR-qualifying non-agricultural value.

Consider a farming estate where agricultural land has an agricultural value (s 115(3)) of GBP 500,000 and a market value of GBP 800,000, with the GBP 300,000 differential attributable to development potential. APR applies first to the GBP 500,000 agricultural value. BPR may then apply to the GBP 300,000 non-agricultural element, but only if that element forms part of a qualifying business interest satisfying the s 105 relevant business property test, the s 105(3) "wholly or mainly" trading test, and the s 112 excepted assets rule.

Where one relief covers the entirety of the value transferred, HMRC guidance at SVM112020 indicates that it may be unnecessary to establish both reliefs in full.13 However, the combined allowance introduces a new imperative: even where APR covers all agricultural value, the amount of allowance consumed by that APR claim determines how much remains available for separate BPR-qualifying business property elsewhere in the estate.

Increased Significance Under Capped Relief

Before 6 April 2026, the priority rule was largely a mechanical concern. Both reliefs provided 100% relief without limit, so the order of application did not affect the overall tax liability. Under the combined allowance, the priority rule acquires material significance. Practitioners cannot strategically allocate the allowance by electing to claim BPR before APR, even in circumstances where doing so would produce a more favourable outcome. The statutory rigidity of s 114(1) means that the interaction between the reliefs is determined by the structure of the estate, not by post-death elections.

3. The Combined GBP 2.5 Million Allowance: Allocation Mechanics

The Reform Framework

From 6 April 2026, the Finance Bill 2025-26 introduces a single combined allowance of GBP 2.5 million for 100% APR and BPR relief, increased from the GBP 1 million originally announced at Autumn Budget 2024 following the 23 December 2025 amendment.14 Qualifying property above the threshold receives 50% relief, producing an effective IHT rate of 20% on the excess. The allowance is a single combined limit, not separate allowances for APR and BPR.15

As of 26 February 2026, the Finance Bill 2025-26 has completed its Public Bill Committee stage (3 February 2026) and the Report stage date has not yet been set, though it is expected after the week commencing 23 February 2026.16 Royal Assent has not yet been received. Practitioners should frame the combined allowance provisions as Finance Bill measures pending enactment while proceeding with planning on the basis that the substantive provisions are expected to take effect from 6 April 2026.

Proportional Allocation

Where combined APR and BPR-qualifying property exceeds the allowance threshold, the allowance allocates proportionally across the two relief categories. The GOV.UK Summary of Reforms illustrates this proportional methodology using a GBP 1 million allowance example: a taxpayer with GBP 3 million of agricultural property and GBP 2 million of business property (GBP 5 million combined) receives a 60%/40% allocation (GBP 600,000 to agricultural property and GBP 400,000 to business property).17 Applying the same proportional methodology to the GBP 2.5 million allowance produces an allocation of GBP 1.5 million to agricultural property (60%) and GBP 1 million to business property (40%).

This proportional mechanism creates a zero-sum dynamic that did not exist under unlimited relief. Every pound of APR-qualifying property that consumes the allowance reduces the amount available for BPR-qualifying property, and vice versa.

Worked Examples for Mixed Estates

Example A: Farming estate with separate trading business. A taxpayer holds agricultural land with an agricultural value of GBP 3 million and a separate unquoted trading company valued at GBP 1 million. Combined qualifying property totals GBP 4 million. The GBP 2.5 million allowance allocates proportionally: GBP 1,875,000 to APR (75%) and GBP 625,000 to BPR (25%). The remaining GBP 1,125,000 of agricultural property and GBP 375,000 of business property receive 50% relief. IHT on the excess (at the effective 20% rate): GBP 300,000.

Example B: Farm with agricultural and non-agricultural value. A farm has an agricultural value of GBP 2 million and a market value of GBP 3.5 million, the GBP 1.5 million differential attributable to development potential on land used within the farming trade. The farmer also holds a separate GBP 1 million trading business. Under the s 114 priority rule, APR applies first to the GBP 2 million agricultural value. BPR may apply to the GBP 1.5 million non-agricultural element (if BPR conditions are met) and to the GBP 1 million separate business. Total qualifying property: GBP 4.5 million. Proportional allocation of the GBP 2.5 million allowance: GBP 1,111,111 to APR (44.4%), GBP 833,333 to BPR on the non-agricultural element (33.3%), GBP 555,556 to the separate business (22.2%). The excess of GBP 2 million receives 50% relief. IHT on the excess: GBP 400,000.

Example C: Spousal planning. A farming couple holds combined qualifying property of GBP 7 million. Each spouse has a GBP 2.5 million allowance, providing GBP 5 million of 100% relief. The remaining GBP 2 million receives 50% relief, generating an IHT liability of GBP 400,000. Combined with nil-rate bands (GBP 325,000 each, totalling GBP 650,000), the couple can pass approximately GBP 5.65 million free of IHT (GBP 5 million from combined APR/BPR allowances plus GBP 650,000 from nil-rate bands; RNRBs would be fully tapered to nil on an estate of this value, given the GBP 1 reduction for every GBP 2 above the GBP 2 million net estate threshold).18 Critically, if the first-to-die's estate passes entirely to the surviving spouse via the spouse exemption, the deceased's allowance is wasted. Will structuring must direct qualifying property up to the allowance value to beneficiaries or discretionary trusts to utilise the first-to-die's allowance.

AIM-Traded Shares

For completeness, AIM-traded shares designated as "not listed" on recognised stock exchanges receive a flat 50% BPR from 6 April 2026, regardless of the GBP 2.5 million allowance.19 While this change is significant for portfolios containing AIM shares, it does not interact with the APR/BPR combined allowance mechanics that are the focus of this analysis.

4. Mixed Estate Structures: Navigating the Agricultural Property Relief and Business Property Relief Boundary

Diversified Farming Businesses

Modern farming businesses frequently straddle the APR/BPR boundary through diversification. The qualification implications under capped relief are materially more severe than under the previous unlimited regime, because failure to satisfy one relief's conditions may result in the property consuming the combined allowance under the other relief -- or receiving no relief at all.

Farm shops and retail operations. Where a farm shop operates as an integral part of the farming trade, the land on which it sits may retain APR qualification. Where the shop operates as a distinct trading entity or occupies land not used for agricultural purposes, APR is unlikely to apply, but BPR may be available on the trading business.20 The characterisation affects both the qualifying value and the proportional allocation of the combined allowance.

Renewable energy installations. Agricultural land hosting solar panels or wind turbines risks losing APR if the primary use shifts from agriculture. HMRC's agricultural purposes test at IHTM24060 requires the land to be used for the purposes of agriculture -- habitat management, growing crops, or rearing livestock.20 Where renewable installations are secondary to active agricultural use, APR may be preserved; where they become the primary revenue activity, the land may need to rely on BPR as part of a qualifying trading business.

Contract farming arrangements. Under a contract farming arrangement, the landowner retains occupation of the land (potentially satisfying APR's occupation requirement under s 117(a)) while the contractor provides labour and machinery. The landowner may claim APR on the agricultural value of the land; the contractor may claim BPR on the farming business assets.21 Practitioners must verify that the contractual structure preserves the landowner's occupation status rather than creating a tenancy that could compromise the APR claim.

Agritourism and holiday lettings. Holiday lettings, event venues, and glamping operations on agricultural land create dual risk. The non-agricultural use may compromise APR's agricultural occupation requirement, while the letting income may push the business towards the s 105(3) investment exclusion if the operation is characterised as property letting rather than trading. Where these activities form a minority element of a predominantly agricultural or trading business, both reliefs may be preserved; where they become dominant, compound qualification failure may result in neither relief applying.

The Farmhouse: A Specific Risk Area

The farmhouse "of a character appropriate to the property" test under s 115(2) is a persistent area of dispute. HMRC guidance at IHTM24036 requires the farmhouse to be proportionate to the agricultural holding, assessing factors including size, layout, and historical connection to the farm.22 Under capped relief, a farmhouse failing the character-appropriate test loses APR on its full value, consuming additional allowance under BPR (if available) or attracting the standard 40% IHT rate.

Heightened Consequences Under Capped Relief

Under unlimited relief, a qualification failure on one element of a mixed estate reduced but did not fundamentally alter the overall position -- other qualifying property still received full relief. Under the combined allowance, a qualification failure creates cascading effects. Property that loses APR qualification consumes BPR allowance (if BPR conditions are met) or receives no relief at all. The shared GBP 2.5 million ceiling means that every pound of relief lost on one asset directly increases the IHT liability on the estate as a whole.

5. Integrated Planning Considerations for Mixed Estates

Spousal Allowance Structuring

Each spouse or civil partner receives a GBP 2.5 million combined allowance. The spousal transfer mechanism provides that unused allowance passes to the surviving spouse; where the first death preceded 6 April 2026, the full GBP 2.5 million is assumed available for transfer.23 Farming couples should review testamentary arrangements to ensure the first-to-die's allowance is utilised rather than wasted through blanket spouse exemption provisions. Directing qualifying property up to the allowance value to a discretionary trust or direct to beneficiaries preserves the allowance while the spouse exemption covers any remaining non-qualifying property.

Lifetime Gifting and the Seven-Year Refresh

The combined allowance refreshes every seven years for lifetime transfers. A gift of qualifying APR or BPR property, if survived for seven years, fully utilises one tranche of the allowance and permits it to refill. However, capital gains tax implications must be assessed: agricultural land disposals may trigger CGT at market value unless holdover relief applies under TCGA 1992 s 165 (business assets) or s 260 (certain trust transfers).24 The interaction with the residence-based IHT regime enacted from 6 April 2025 -- which replaced the domicile-based system with a 10-of-20-year long-term resident test -- adds a further dimension for estates involving family members with international connections.25

Transitional rules apply to gifts of qualifying property made on or after 30 October 2024 but before 6 April 2026: these are initially assessed under the pre-reform rules but reassessed under the new regime if the donor dies on or after 6 April 2026 within seven years.26

Trust Planning

Pre-30 October 2024 trusts each receive their own GBP 2.5 million allowance. Trusts settled after that date share allowances between related settlements under anti-fragmentation rules with chronological allocation.27 The trust allowance is also a combined APR/BPR limit with proportional allocation mirroring the individual allowance structure. The 10-year refresh cycle creates strategic opportunities for trust-based succession planning. Both the individual and trust allowances are frozen at GBP 2.5 million until 2030-31, with CPI indexation commencing from 6 April 2031.

Professional Valuation

The distinction between agricultural value and market value becomes a critical planning variable under the combined allowance. Professional agricultural valuations that accurately establish the s 115(3) agricultural value determine how the allowance is allocated between APR and BPR. An undervaluation of agricultural value increases the BPR-qualifying non-agricultural element, altering the proportional allocation. Practitioners should commission RICS-qualified valuations that separately identify agricultural value, development value, amenity value, and any lifestyle premium.

Partnership and Shareholder Agreement Audit

Farming partnerships and companies with both agricultural and business assets face compound risk from binding contract provisions. A binding contract for sale defeats both APR (s 124 IHTA 1984) and BPR (s 113 IHTA 1984).28 Cross-option agreements structured as separate put and call options preserve relief, but buy-and-sell agreements creating mutual binding obligations do not. Under the combined allowance, the loss of both reliefs on partnership or company interests exposes the full value to the standard 40% IHT rate. A comprehensive review of all partnership agreements, articles of association, and shareholder agreements is essential before 6 April 2026.

Interest-Free Instalments

From 6 April 2026, IHT on qualifying APR and BPR property above the GBP 2.5 million threshold can be paid in 10 equal annual interest-free instalments, extending the existing instalment provisions under ss 227-234 IHTA 1984.29 This provides significant cash-flow relief for farming estates that would otherwise face a liquidity event to settle the tax liability on illiquid agricultural and business assets.

Integrated Dual-Relief Qualifying Assessment

Practitioners advising mixed estates should apply an integrated assessment framework rather than treating APR and BPR as separate compliance exercises:

  1. Identify all potentially qualifying property across both relief categories
  2. Apply the s 114 priority rule to determine which relief applies to which element of value
  3. Verify APR qualifying conditions (s 115(2) definition, s 115(3) agricultural value, s 116 rate, s 117 occupation/ownership) for all agricultural property
  4. Verify BPR qualifying conditions (s 105 relevant business property, s 105(3) trading test, s 106 ownership, s 112 excepted assets, s 113 binding contracts) for all business property and non-agricultural value
  5. Calculate the proportional allocation of the GBP 2.5 million allowance across both categories
  6. Assess spousal planning to maximise use of both allowances
  7. Complete IHT414 (Agricultural Relief) and IHT413 (Business and Partnership Interests) in coordination, ensuring consistent treatment of shared assets

Legislative Uncertainty: Monitoring Items

A judicial review challenge to the APR/BPR consultation process is before the High Court, with a rolled-up hearing scheduled for February or March 2026. The remedy sought is declaratory only -- a declaration that the consultation was unlawful -- and would not invalidate the legislation itself.30 Practitioners should treat this as a monitoring item rather than a planning variable and proceed on the basis that the Finance Bill provisions will take effect from 6 April 2026.

Conclusion

The introduction of the combined GBP 2.5 million allowance from 6 April 2026 represents a structural shift in how APR and BPR interact. For over three decades, the unlimited nature of both reliefs meant that the s 114 priority rule, the distinction between agricultural value and market value, and the question of which relief applied to which element of a mixed estate were technical considerations with limited financial consequence. Under capped relief, these become determinative of the effective IHT liability.

Practitioners advising mixed agricultural and business estates must now adopt an integrated approach that treats APR and BPR as components of a single allowance framework rather than separate compliance silos. The proportional allocation mechanism, the statutory rigidity of the s 114 priority rule, and the zero-sum dynamic between the two reliefs create planning imperatives that are qualitatively different from the pre-reform environment. For those seeking detailed single-relief analysis, the companion articles on APR and BPR provide comprehensive treatment of each relief's qualifying conditions and the April 2026 reforms in isolation. This article bridges those analyses by addressing the interaction that will define the advisory challenge for mixed estates in the reformed regime.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Inheritance Tax, Agricultural Tax, Business Tax, Estate Planning

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Explain the statutory priority rule under s 114 IHTA 1984 and its practical effect on the order of APR and BPR application in mixed estates (Understand)
  2. Calculate the proportional allocation of the GBP 2.5 million combined allowance across APR and BPR-qualifying property in a mixed agricultural and business estate (Apply)
  3. Distinguish between the qualifying conditions for APR (ss 115-117 IHTA 1984) and BPR (ss 105-106 IHTA 1984) and assess their interaction for property potentially eligible for both reliefs (Analyse)
  4. Evaluate the planning implications of the combined allowance for spousal estate structuring, lifetime gifting, and trust arrangements in mixed agricultural and business estates (Evaluate)
  5. Design an integrated APR/BPR qualifying assessment for a diversified farming business with mixed agricultural and non-agricultural activities (Create)

Professional Competency Mapping

  • ICAEW Code of Ethics: Professional competence and due care in tax advisory services
  • ATT Professional Standards: Technical competence in inheritance tax reliefs and estate planning
  • CIOT Professional Conduct in Relation to Taxation: Paragraph 2.29 -- Advising on tax planning arrangements

Reflective Questions

  1. How would an integrated APR/BPR assessment framework change the approach to advising farming clients with diversified business interests, compared with the pre-reform practice of assessing each relief independently?
  2. What additional due diligence steps should be incorporated into partnership agreement reviews to ensure that binding contract provisions do not inadvertently defeat both APR and BPR claims under the combined allowance?
  3. In what circumstances might the s 114 priority rule produce a less favourable allowance allocation than would result from a hypothetical BPR-first approach, and how should practitioners communicate this constraint to clients?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 26 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. IHTA 1984 s 115(2) -- Definition of agricultural property. https://www.legislation.gov.uk/ukpga/1984/51/section/115 ↩

  2. IHTA 1984 s 115(3) -- Agricultural value. https://www.legislation.gov.uk/ukpga/1984/51/section/115 ↩

  3. IHTA 1984 s 117 -- Occupation and ownership conditions; HMRC IHTM24070 -- Occupation introduction. https://www.legislation.gov.uk/ukpga/1984/51/section/117; https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24070 ↩

  4. IHTA 1984 s 116 -- Rate of relief; HMRC IHTM24140 -- Rate of relief. https://www.legislation.gov.uk/ukpga/1984/51/section/116; https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24140 ↩

  5. GOV.UK -- Inheritance Tax: Geographical scope of agricultural property relief and woodlands relief. https://www.gov.uk/government/publications/changes-to-the-geographical-scope-of-agricultural-property-relief-and-woodlands-relief-for-inheritance-tax/inheritance-tax-geographical-scope-of-agricultural-property-relief-and-woodlands-relief ↩

  6. GOV.UK -- Extension of inheritance tax agricultural property relief to environmental land management agreements; IHTA 1984 s 124C. https://www.gov.uk/government/publications/agricultural-property-relief-and-environmental-land-management/extension-of-inheritance-tax-agricultural-property-relief-to-environmental-land-management-agreements; https://www.legislation.gov.uk/ukpga/1984/51/section/124C ↩

  7. IHTA 1984 Part V Chapter I -- Business property relief. https://www.legislation.gov.uk/ukpga/1984/51/part/V/chapter/I ↩

  8. HMRC SVM111150 -- "Wholly or mainly" test; Farmer v IRC [1999] SpC 216. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111150 ↩

  9. IHTA 1984 s 112 -- Excepted assets; HMRC SVM111210. https://www.legislation.gov.uk/ukpga/1984/51/section/112; https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111210 ↩

  10. IHTA 1984 s 113 -- Binding contracts for sale. https://www.legislation.gov.uk/ukpga/1984/51/section/113 ↩

  11. IHTA 1984 s 114(1) -- Relationship between business relief and agricultural relief. https://www.legislation.gov.uk/ukpga/1984/51/section/114 ↩

  12. HMRC IHTM25121 -- Relationship between Business and Agricultural relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm25121 ↩

  13. HMRC SVM112020 -- Agricultural property practice notes. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm112020 ↩

  14. GOV.UK -- Inheritance tax reliefs threshold to rise to GBP 2.5m for farmers and businesses (23 December 2025). https://www.gov.uk/government/news/inheritance-tax-reliefs-threshold-to-rise-to-25m-for-farmers-and-businesses ↩

  15. GOV.UK -- Agricultural property relief and business property relief changes. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  16. Finance (No. 2) Bill 2025-26 -- Parliamentary Bills. https://bills.parliament.uk/bills/4042 ↩

  17. GOV.UK -- Summary of reforms to agricultural property relief and business property relief (proportional allocation methodology illustrated using GBP 1 million allowance example). https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩

  18. GOV.UK -- Agricultural property relief and business property relief changes -- spousal transferability provisions. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  19. GOV.UK -- Summary of reforms -- AIM-traded shares. https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩

  20. HMRC IHTM24060 -- Agricultural purposes. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24060 ↩ ↩2

  21. CLA -- Agricultural and Business Property Relief explained. https://www.cla.org.uk/news/in-focus-agricultural-business-property-relief-explained/ ↩

  22. HMRC IHTM24036 -- Farmhouses. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24036 ↩

  23. GOV.UK -- Agricultural property relief and business property relief changes -- spousal transfer of allowance. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  24. Taxation of Chargeable Gains Act 1992 s 165 -- Relief for gifts of business assets. https://www.legislation.gov.uk/ukpga/1992/12/section/165 ↩

  25. GOV.UK -- Inheritance Tax: Long-term UK resident guidance (residence-based regime from 6 April 2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩

  26. GOV.UK -- Agricultural property relief and business property relief changes -- transitional rules. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  27. GOV.UK -- Reforms to inheritance tax agricultural property relief and business property relief: application in relation to trusts -- summary of responses. https://www.gov.uk/government/consultations/reforms-to-inheritance-tax-reliefs-consultation-on-property-settled-into-trust/outcome/reforms-to-inheritance-tax-agricultural-property-relief-and-business-property-relief-application-in-relation-to-trusts-summary-of-responses ↩

  28. IHTA 1984 s 113 and s 124 -- Binding contracts for sale (BPR and APR respectively). https://www.legislation.gov.uk/ukpga/1984/51/section/113; https://www.legislation.gov.uk/ukpga/1984/51/section/124 ↩

  29. GOV.UK -- Summary of reforms -- interest-free instalments. https://www.gov.uk/government/publications/agricultural-property-relief-and-business-property-relief-reforms/summary-of-reforms-to-agricultural-property-relief-and-business-property-relief ↩

  30. Collyer Bristow -- Farmers and business owners seek judicial review of inheritance tax changes to agricultural/business property relief; Collyer Bristow -- High Court grants urgent hearing (19 January 2026). https://collyerbristow.com/news/farmers-and-business-owners-seek-judicial-review-of-inheritance-tax-changes-to-agricultural-business-property-relief/; https://collyerbristow.com/news/high-court-grants-urgent-hearing-of-judicial-review-into-iht-agricultural-business-property-relief-changes/ ↩

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