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Agricultural Property Relief: Advising Farming Clients on the Reformed Framework from April 2026

· 21 min

Executive Summary

The Finance Bill 2025-26 enacts the most significant reform to agricultural property relief since 1984, capping the 100% relief rate at GBP 2.5 million of combined APR and BPR-qualifying property from 6 April 2026, with 50% relief applying thereafter. DEFRA data showing average farm net worth at GBP 2.4 million across all types, and GBP 3.7 million for cereal farms, indicates that a material minority of farming estates now face inheritance tax exposure for the first time. The reformed framework introduces spousal transferability of the allowance, 10-year interest-free instalment payments, and transitional rules for recent lifetime gifts that create both planning opportunities and compliance risks. Concurrently, the extension of APR to environmental land management agreements from April 2025 and the restriction of geographical scope to UK-only property reshape the qualifying landscape. This article provides a technical analysis for rural accountants and agricultural tax specialists navigating the new regime.

1. Introduction

Agricultural property relief has operated as a cornerstone of farming succession planning since its introduction by the Finance Act 1981 and consolidation within the Inheritance Tax Act 1984. For over three decades following the increase to 100% relief in 1992, the unlimited nature of APR meant that the relief's qualifying conditions -- while important -- were not determinative of the overall tax liability for most farming estates. A farm valued at GBP 5 million that qualified for APR paid no IHT on that property; precise valuation and structural compliance mattered, but the margin for error was generous.

The April 2026 reforms fundamentally alter this calculus. Under capped relief, every pound of agricultural value above GBP 2.5 million attracts an effective 20% IHT rate, making accurate valuation and strategic structuring critical rather than merely advisable.1 Simultaneously, the residence-based IHT regime enacted from 6 April 2025 has replaced the domicile-based system, introducing a 10-of-20-year long-term resident test with tail provisions of 3 to 10 years after departure.2 For farming estates with non-UK-domiciled family members, these overlapping reforms create compound advisory complexity.

This article examines the reformed relief framework, refreshes the core qualifying conditions that now function as gateway requirements, analyses the environmental land management extension and transitional rules, identifies structural risks amplified by capped relief, and provides worked examples quantifying the IHT impact across different farming estate values.

2. The Reformed Relief Framework

The Policy Journey and Legislative Position

The Autumn Budget 2024 announced restrictions to APR and BPR from 6 April 2026, originally proposing a GBP 1 million combined allowance for 100% relief.3 Following sustained representations from the NFU, CLA, and TFA, the government announced on 23 December 2025 that the allowance would increase to GBP 2.5 million, introduced as an amendment to the Finance Bill 2025-26.4 HMRC data indicates that 93% of agricultural claims in 2021-22 involved assets below GBP 2.5 million, suggesting the revised threshold addresses the majority of farming estates while maintaining the policy objective of restricting relief for the largest claims.5

The New Rate Structure

From 6 April 2026, the reformed rate structure operates as follows:

  • First GBP 2.5 million of combined APR and BPR-qualifying property: 100% relief (no IHT)
  • Qualifying property above GBP 2.5 million: 50% relief, producing an effective IHT rate of 20% on the excess
  • Non-qualifying property: Standard 40% IHT rate, subject to the nil-rate band and residence nil-rate band6

The GBP 2.5 million allowance is a combined limit. Where an estate contains both agricultural property qualifying for APR and business property qualifying for BPR, the two categories share the single allowance. Practitioners must assess the total qualifying value across both relief categories when advising farming clients who also hold non-agricultural business interests, such as farm shops operated as separate trading entities, renewable energy businesses on agricultural land, or diversified rural enterprises.

Spousal Transferability

The allowance is transferable between spouses and civil partners. Where the first spouse or civil partner died before 6 April 2026, the full GBP 2.5 million allowance is assumed available for transfer to the surviving spouse, irrespective of the value of qualifying property in the first estate.7 This mirrors the nil-rate band transfer mechanism introduced by Finance Act 2008 and creates analogous will-drafting imperatives. Farming couples must ensure their testamentary arrangements do not waste the first-to-die's allowance by, for example, directing all qualifying property to the surviving spouse through the spouse exemption rather than utilising the deceased's own allowance.

Combined with the nil-rate band (GBP 325,000) and RNRB (GBP 175,000), a married couple can potentially pass up to GBP 6 million free of IHT: GBP 5 million of APR/BPR-qualifying property, GBP 650,000 through combined nil-rate bands, and up to GBP 350,000 through combined RNRBs where the direct descendant condition is met. In practice, the RNRB taper -- which reduces the allowance by GBP 1 for every GBP 2 of net estate above GBP 2 million -- will reduce this figure for most farming estates, producing a practical tax-free threshold closer to GBP 5.65 million for estates where the taper eliminates part or all of the RNRB component.

Trust Allowance

The trust allowance is GBP 2.5 million, matching the individual allowance following the December 2025 amendment that increased it from the originally proposed GBP 1 million.8 Where settlors create multiple trusts after 30 October 2024, the GBP 2.5 million allowance is allocated chronologically across trusts as an anti-fragmentation measure. Existing trusts that held qualifying property before 30 October 2024 each receive their own GBP 2.5 million allowance. The government's technical consultation on trust provisions (27 February to 23 April 2025, 122 responses) confirmed standardised exit charge calculations based on unrelieved values.9

For farming families who have historically used discretionary trusts to hold agricultural land -- a common structure for managing succession across multiple generations -- the alignment of trust and individual allowances removes a potential disparity that existed under the originally proposed framework. The anti-fragmentation rules for post-30 October 2024 trusts nonetheless require careful planning: multiple trusts created by the same settlor share the single GBP 2.5 million allowance, allocated in chronological order by reference to the value of qualifying property settled. Practitioners advising on new trust structures must model this allocation to ensure that the allowance is not exhausted by earlier settlements.

CPI Indexation and the Frozen Period

Both the GBP 2.5 million individual allowance and GBP 2.5 million trust allowance remain fixed until and including tax year 2029-30. CPI indexation commences from 2030-31.10 For farming estates where asset values continue to appreciate in the intervening period, this four-year freeze progressively reduces the real value of the allowance. With Savills recording average GB agricultural land values at GBP 8,200 per acre in H1 2025 and prime arable at GBP 10,100 per acre, even modest land value appreciation during the frozen period could push estates that are currently below the threshold into IHT exposure.11

Interaction with the Residence-Based IHT Regime

The residence-based IHT regime, enacted from 6 April 2025, replaced the domicile-based system for determining which individuals have worldwide IHT exposure.12 Under the new test, individuals who have been UK-resident for 10 of the previous 20 tax years are classified as long-term residents with worldwide assets within the IHT charge, subject to tail provisions of 3 to 10 years after departure. For farming estates with non-UK-domiciled family members -- a scenario encountered in estates involving cross-border agricultural partnerships or where farming businesses have been established by individuals who settled in the UK -- the interaction between the residence-based regime and APR qualification requires careful analysis. APR is available only on UK agricultural property from 6 April 2024, but the residence-based regime determines whose worldwide estate is within the IHT charge.

3. Core Qualifying Conditions: An Advisory Refresher

The April 2026 reforms modify the rate structure but do not alter the qualifying conditions set out in IHTA 1984 ss.115-117. Under capped relief, these conditions become gateway requirements to the GBP 2.5 million allowance rather than merely threshold questions for unlimited relief.

Definition of Agricultural Property (s.115(2))

Agricultural property is defined as agricultural land or pasture, including woodland and buildings used for intensive livestock rearing or fish farming (where ancillary to agricultural land), cottages, farm buildings, and farmhouses "of a character appropriate to the property."13 Agricultural value is the value the property would have if subject to a perpetual covenant prohibiting non-agricultural use (s.115(3)). Any development premium or amenity value falls outside APR. The distinction between agricultural value and open market value becomes materially more significant under capped relief: where the GBP 2.5 million threshold is assessed against agricultural value only, an accurate disaggregation of agricultural and non-agricultural value elements is essential.

The Farmhouse "Character Appropriate" Test

The farmhouse qualification remains a significant area of dispute. HMRC applies the multi-factor test established in Antrobus v IRC (No 2) [2005], examining size, layout, and content of the farmhouse relative to the farm buildings and agricultural land.14 Golding v HMRC [2011] affirmed these principles for a modest three-bedroom house on 16 acres. Hanson v HMRC [2012] addressed whether a farmhouse and the agricultural land need be in common ownership for APR to apply, with the First-tier Tribunal holding that the required nexus between a farmhouse and agricultural land is one of common occupation rather than common ownership -- a distinction of particular relevance for farming families where legal title to the farmhouse and agricultural land may be held by different family members.

Under capped relief, a failed farmhouse claim has materially different consequences. Where the farmhouse value was previously subsumed within unlimited 100% relief, its disqualification under the new regime could push the remaining agricultural property above the GBP 2.5 million threshold, generating an IHT liability that would not otherwise arise.

Rate of Relief (s.116)

Section 116 provides 100% APR where the transferor has vacant possession or the right to obtain it within 12 months, or where the tenancy began on or after 1 September 1995. Pre-September 1995 tenancies attract 50% relief.15 This rate structure now operates within the GBP 2.5 million cap: 100% relief on the first GBP 2.5 million of qualifying property (subject to s.116 conditions), then 50% on the excess.

Occupation and Ownership Conditions (s.117)

Two alternative routes to qualification exist: (a) occupation by the transferor for agricultural purposes for the two years immediately preceding the transfer, or (b) ownership for seven years with agricultural occupation throughout, whether by the owner or another person.16 The distinction matters for farming families where operational and ownership roles are separated -- a common structure where the farming business is conducted by the next generation while the legal title remains with the parent. Under capped relief, a failure to meet the occupation or ownership condition on any part of the agricultural holding directly reduces the property qualifying for the GBP 2.5 million allowance.

Geographical Scope

From 6 April 2024, APR applies only to agricultural property in the United Kingdom. The previous extension to Channel Islands, Isle of Man, and EEA property was removed by Finance Act 2024.17 Farming estates with cross-border agricultural holdings must account for this restriction when calculating APR-eligible property against the GBP 2.5 million threshold.

4. Environmental Land Management Extension

The April 2025 Extension

From 6 April 2025, APR was extended to land managed under environmental agreements with or on behalf of UK government, devolved governments, public bodies, local authorities, or approved responsible bodies.18 This includes Environmental Land Management Schemes in England and equivalent schemes across the devolved nations. Section 124C IHTA 1984 (which previously provided relief only for land in habitat schemes) was repealed and replaced with the broader environmental agreement provisions.

The Barrier Removed

The extension addresses a genuine structural barrier. Agricultural landowners entering environmental management schemes risked losing APR qualification where land was taken out of agricultural production permanently or for extended periods. Under the previous framework, this created a perverse incentive against environmental stewardship: the IHT cost of entering a scheme could substantially exceed the environmental payments received over the landowner's remaining lifetime.

With DEFRA committed to increasing Environmental Land Management Scheme support from GBP 800 million in 2023-24 to GBP 2 billion per year by 2028-29, the extension is practically significant for a growing proportion of farming estates.19

Practical Implications for Advisors

Practitioners advising farming clients participating in or considering environmental schemes should verify that the specific agreement meets the statutory criteria. The qualifying conditions require an environmental agreement with a specified public body or approved responsible body. Private conservation arrangements outside the statutory framework do not qualify. Documentation evidencing the agreement and its terms should be maintained within the estate planning file, including the identity of the contracting public body and the duration of the agreement.

The extension interacts with the core APR conditions: land under an environmental agreement must still satisfy the ownership or occupation requirements of s.117, albeit the environmental use now constitutes a qualifying agricultural purpose for these purposes. Practitioners should ensure that clients entering environmental schemes retain adequate evidence of the agricultural character of the holding and the connection between the environmental agreement and the agricultural land.

5. Transitional Rules and Lifetime Gift Planning

The Transitional Window

Transitional rules apply to gifts of agricultural property made on or after 30 October 2024 but before 6 April 2026. Such gifts are initially assessed under the pre-reform rules, meaning unlimited 100% APR is applied at the date of gift.20 However, if the donor dies on or after 6 April 2026 and within seven years of making the gift, the transfer is reassessed under the new rules. The GBP 2.5 million allowance then applies retrospectively across the failed potentially exempt transfer and the death estate combined.

Interaction with the Seven-Year Rule

Taper relief -- which reduces the IHT payable (not the value transferred) on gifts made three to seven years before death -- applies to the recalculated liability under the new rules. A gift of agricultural property worth GBP 4 million made in January 2025 would, if the donor dies in January 2030 (within five years), be reassessed under the new framework: the first GBP 2.5 million would receive 100% relief, the remaining GBP 1.5 million would receive 50% relief (GBP 750,000 taxable), and the tax liability would then be reduced by taper relief at the applicable rate for the period between gift and death.21

Advisory Imperative

This transitional framework creates an urgent review requirement. Farming clients who made lifetime transfers of agricultural property between 30 October 2024 and 6 April 2026 may face retrospective restriction of relief if they die within seven years. Practitioners should identify all such transfers, quantify the potential additional IHT exposure under the new rules, and assess whether supplementary planning measures -- such as life insurance to cover the potential liability during the seven-year survival period -- are appropriate.

The combined GBP 2.5 million allowance applies across all qualifying property in both the failed PET and the death estate. Where a farming client transferred GBP 2 million of agricultural property by lifetime gift and retains GBP 3 million of qualifying property at death, the entire GBP 5 million is assessed against the single GBP 2.5 million threshold. Practitioners must model this combined exposure rather than treating lifetime gifts and the death estate as separate calculations.

6. Structural Risks Under Capped Relief

Partnership Agreements and Binding Contracts for Sale

Partnership agreements remain the most common structural risk for APR qualification. Where a partnership agreement contains provisions requiring the purchase of a deceased partner's share -- creating a binding contract for sale at the date of transfer -- HMRC's position is that the property is disqualified from APR.22 The critical distinction lies between an obligation (which disqualifies) and an option (which preserves relief). The language in the partnership deed determines the outcome: provisions stating that the surviving partners "shall" purchase the deceased's share create a binding obligation, whereas provisions conferring a right to purchase preserve the agricultural character of the property.

Under unlimited 100% relief, this structural defect, while significant, could be partially mitigated by the availability of BPR on partnership interests. Under capped relief, the consequences are compounded: losing APR on partnership agricultural assets not only removes the relief but may reduce the available allowance for other qualifying property, since APR and BPR share the GBP 2.5 million combined threshold. BPR may provide partial backup -- 50% on assets used in a partnership but owned by a partner, 100% on partnership assets -- but within the shared allowance this offers limited additional protection.23

Diversification Risks

Farm diversification activities pose escalating risks to APR qualification under the new regime:

  • Renewable energy installations: Solar panels and wind turbines on agricultural land may compromise eligibility if the land ceases to be primarily used for agricultural purposes
  • Agritourism: Glamping, farm shops, and event venues may undermine the agricultural occupation condition
  • Non-agricultural use: Equestrian activities, dog boarding, and storage lettings on former agricultural buildings create "hobby farm" risk where the farming business is loss-making and diversified activities predominate

Under capped relief, the disqualification of even part of a farming estate from APR can produce disproportionate IHT consequences. Where an estate's qualifying agricultural value sits at or near the GBP 2.5 million threshold, the loss of APR on diversified assets could push the estate into the 20% effective rate band.

Practitioner Audit Priorities

Rural accountants should prioritise the following structural review for farming clients:

  • Partnership agreements: Review all partnership deeds for binding contract for sale provisions; recommend amendment to option-based structures where identified
  • Farmhouse qualification: Assess the farmhouse against the Antrobus character-appropriate criteria and document the farming nexus
  • Diversification analysis: Map all non-agricultural activities on the farming estate and assess their impact on APR qualification
  • Tenancy arrangements: Verify tenancy start dates (pre/post 1 September 1995) and the s.116 rate consequences
  • Valuation evidence: Commission or update agricultural valuations distinguishing agricultural value from market value, given the determinative significance of precise valuation under capped relief

7. Quantifying the Impact: Worked Examples

Context: Farm Values and the Threshold

DEFRA's Balance Sheet Analysis for 2023/24 reports average farm net worth of GBP 2.4 million across all farm types. Cereal farms average GBP 3.7 million; general cropping farms GBP 3.2 million. Approximately 23% of farms have net worth of at least GBP 3 million.24 DEFRA cautions that farm net worth is "not a clear guide to inheritance tax liabilities" as farm structures involve multiple ownership arrangements that may distribute value across several individuals.

HMRC estimates that approximately 85% of APR-claiming estates in 2026-27 will pay no additional IHT. However, 185 estates claiming APR (including those also claiming BPR) are expected to pay more, with up to 1,100 estates paying additional IHT across both reliefs combined.25

Example 1: Estate Below the Threshold (GBP 2 Million)

A sole-owner farming estate with GBP 2 million of qualifying agricultural property (300-acre mixed farm, farmhouse, and farm buildings). The farmer is widowed with adult children.

  • APR at 100% on GBP 2 million: GBP 2 million fully relieved
  • Nil-rate band: GBP 325,000 (plus transferred NRB of GBP 325,000)
  • RNRB: GBP 175,000 (plus transferred RNRB of GBP 175,000, if qualifying direct descendant condition met)
  • IHT liability: nil

This estate is unaffected by the reforms. The position is identical to the pre-reform unlimited relief.

Example 2: Estate Above the Threshold (GBP 4.5 Million)

A sole-owner cereal farming estate with GBP 4.5 million of qualifying agricultural property. The farmer is widowed, surviving spouse's full allowance transferred.

  • APR at 100% on first GBP 5 million (own GBP 2.5 million plus transferred GBP 2.5 million): fully relieved, but estate is GBP 4.5 million, so all within the combined couple's allowance
  • IHT liability: nil (assuming surviving spouse's full allowance transfers)

However, if the farmer is unmarried or the spouse's allowance is not fully transferable:

  • APR at 100% on first GBP 2.5 million: fully relieved
  • Remaining GBP 2 million at 50% relief: GBP 1 million taxable
  • Nil-rate band applied: GBP 325,000
  • Taxable amount: GBP 675,000
  • IHT at 40%: GBP 270,000
  • 10-year instalment payments: GBP 27,000 per year, interest-free26

The contrast between the married and unmarried positions illustrates the critical importance of spousal allowance planning under the new regime.

Example 3: Estate Substantially Above the Threshold (GBP 7 Million)

A farming partnership estate comprising GBP 5 million agricultural property and GBP 2 million BPR-qualifying business property. The deceased partner is widowed with transferred spouse allowances.

  • Combined APR/BPR allowance: GBP 5 million (own plus transferred)
  • Total qualifying property: GBP 7 million
  • Excess above allowance: GBP 2 million at 50% relief
  • Taxable value: GBP 1 million
  • Less nil-rate bands: GBP 650,000
  • Taxable amount: GBP 350,000
  • IHT at 40%: GBP 140,000
  • Annual instalments: GBP 14,000 over 10 years

Without transferred spouse allowances, the same estate faces GBP 4.5 million above the single GBP 2.5 million allowance, producing GBP 2.25 million taxable and IHT of approximately GBP 770,000 after nil-rate bands. The instalment facility would permit annual payments of approximately GBP 77,000 over the 10-year period, a significant but manageable cash-flow obligation for a productive farming enterprise of this scale.

Conclusion

The reformed APR framework represents a structural shift in agricultural succession planning. For the approximately 85% of APR-claiming estates that fall below the GBP 2.5 million threshold, the practical position is unchanged. For the remaining minority -- concentrated among cereal, general cropping, and larger mixed farming operations -- the transition from unlimited to capped relief introduces material IHT exposure and an advisory complexity that did not previously exist.

The professional imperative is clear. Rural accountants and agricultural tax specialists should undertake systematic reviews of farming client estates, prioritising accurate agricultural valuations, partnership agreement audits, farmhouse qualification assessments, and diversification risk analysis. The transitional rules for gifts made between 30 October 2024 and 6 April 2026 demand immediate attention where lifetime transfers have occurred.

The spousal transferability mechanism, 10-year interest-free instalments, and the environmental land management extension provide meaningful planning tools. Combined with nil-rate bands and RNRBs, farming couples can shelter substantial value from IHT. The diminishing margin for error under capped relief, however, makes precise valuation and structural compliance determinative in a way that unlimited relief never required. The four-year freeze on the allowance before CPI indexation commences from 2030-31 adds temporal urgency: farming estates that sit marginally below the threshold today may breach it through natural asset appreciation before the allowance adjusts. These APR changes form part of a broader IHT reform package that also includes the taxation of pension death benefits under income tax rules from April 2027, underscoring the need for holistic estate planning reviews that address multiple reform elements concurrently.

CPD Declaration

Estimated Reading Time: 25 minutes Technical Level: Advanced Practice Areas: Agricultural Tax, Inheritance Tax Planning, Farm Succession, Rural Practice

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Explain the reformed APR framework from 6 April 2026, including the GBP 2.5 million combined allowance, spousal transferability, trust allowance, and effective IHT rates on qualifying property above the threshold
  2. Calculate the IHT liability on farming estates of different values combining APR, BPR, NRB, RNRB, and spousal transfer under the new regime
  3. Distinguish between the occupation condition (2 years) and ownership condition (7 years) for APR qualification and assess their heightened significance under capped relief
  4. Evaluate the transitional rules for lifetime gifts of agricultural property made between 30 October 2024 and 6 April 2026 and their interaction with the seven-year survival rule
  5. Design a structural audit checklist for farming partnership agreements, farmhouse qualification, and diversification risks in the context of the GBP 2.5 million cap

SRA Competency Mapping

  • A2: Maintain the level of competence and the legal knowledge needed to practise effectively
  • B4: Draft documents that are legally effective, accurate, and meet the needs of clients
  • C1: Identify the client's objectives in relation to the work to be done for the client

Reflective Questions

  1. How would current farming client estate plans be affected if an agricultural valuation were to differ from existing estimates by 10-15%, given that precise valuation is now determinative under capped relief?
  2. What additional due diligence steps should be implemented when reviewing farming partnership agreements to identify binding contract for sale provisions that could disqualify agricultural property from APR?
  3. How might the environmental land management extension be communicated to farming clients who have previously declined ELMS participation due to IHT concerns?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-24. 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. 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 ↩

  2. GOV.UK, Technical Amendments to the Residence-Based Tax Regime. https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩

  3. GOV.UK, Inheritance Tax Reliefs Threshold to Rise to GBP 2.5m for Farmers and Businesses (December 2025). https://www.gov.uk/government/news/inheritance-tax-reliefs-threshold-to-rise-to-25m-for-farmers-and-businesses ↩

  4. House of Commons Library, Changes to Agricultural and Business Property Reliefs for Inheritance Tax (CBP-10181). https://commonslibrary.parliament.uk/research-briefings/cbp-10181/ ↩

  5. GOV.UK, What Are the Changes to Agricultural Property Relief? https://www.gov.uk/government/news/what-are-the-changes-to-agricultural-property-relief ↩

  6. 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 ↩

  7. GOV.UK, Summary of Reforms to Agricultural Property Relief and Business Property Relief. 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 ↩

  8. 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 ↩

  9. GOV.UK, Reforms to Agricultural Property Relief and Business Property Relief (Legislative Provisions). https://www.gov.uk/government/publications/reforms-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-reforms ↩

  10. 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 ↩

  11. Savills, Market in Minutes: GB Farmland Summer 2025. https://www.savills.co.uk/research_articles/229130/380170-0 ↩

  12. GOV.UK, Technical Amendments to the Residence-Based Tax Regime. https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩

  13. Inheritance Tax Act 1984, s.115(2). https://www.legislation.gov.uk/ukpga/1984/51/section/115 ↩

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

  15. Inheritance Tax Act 1984, s.116; HMRC IHTM24140. https://www.legislation.gov.uk/ukpga/1984/51/section/116 ↩

  16. Inheritance Tax Act 1984, s.117; HMRC IHTM24070. https://www.legislation.gov.uk/ukpga/1984/51/section/117 ↩

  17. GOV.UK, 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 ↩

  18. GOV.UK, Extension of IHT Agricultural Property Relief to Environmental Land Management Agreements. 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 ↩

  19. DEFRA Farming Blog, Spending Review 2025: A Commitment to Farming (16 June 2025). https://defrafarming.blog.gov.uk/2025/06/16/spending-review-2025-a-commitment-to-farming/ ↩

  20. 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 ↩

  21. Saffery, Agricultural Property Relief and Business Property Relief Reforms from 6 April 2026. https://www.saffery.com/insights/articles/agricultural-property-relief-and-business-property-relief-reforms-from-6-april-2026/ ↩

  22. HMRC IHTM24040 -- Contracts and Trusts for Sale. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24040 ↩

  23. Saffery, Business Property Relief Overview. https://www.saffery.com/insights/articles/business-property-relief/ ↩

  24. DEFRA, Balance Sheet Analysis and Farming Performance, England 2023/24. https://www.gov.uk/government/statistics/balance-sheet-analysis-and-farming-performance-england/balance-sheet-analysis-and-farming-performance-england-202324-statistics-notice ↩

  25. GOV.UK, What Are the Changes to Agricultural Property Relief? https://www.gov.uk/government/news/what-are-the-changes-to-agricultural-property-relief ↩

  26. GOV.UK, Summary of Reforms to Agricultural Property Relief and Business Property Relief. 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 ↩

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