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Business Property Relief: Maximizing Client Benefits and Compliance Requirements

· 20 min

Executive Summary

The April 2026 reforms to Business Property Relief under IHTA 1984 ss 103-114 introduce a GBP 2.5 million combined allowance for 100% relief, with 50% relief on excess values creating an effective 20% IHT rate above the threshold. Introduced through Finance Bill 2025-26, which remains before Parliament as at 24 February 2026, these changes end over three decades of uncapped relief. Tax advisors must now operate a dual compliance framework: confirming qualification under the established statutory tests -- the s 105(3) "wholly or mainly" trading exclusion, the s 112 excepted assets trap, and the s 113 binding contract bar -- while simultaneously modelling allowance allocation across spousal transfers and trust structures. With AIM-traded shares reduced to flat 50% relief, an anti-forestalling date of 30 October 2024, and a live judicial review challenging the consultation process, the reforms create a three-tier advisory challenge of qualification, quantification, and mitigation.

1. Introduction

Business Property Relief has operated as the cornerstone of inheritance tax planning for trading businesses since its introduction in the Finance Act 1976. The relief, codified in IHTA 1984 Part V Chapter I (ss 103-114), has historically provided 100% relief on qualifying business property without any value ceiling, enabling trading businesses of any size to pass between generations free of IHT.1 For over three decades, the primary advisory question has been binary: does the asset qualify? From 6 April 2026, that question becomes insufficient.

Finance Bill 2025-26, which completed its Public Bill Committee stage on 3 February 2026 and awaits Report stage, Third Reading, and Royal Assent, introduces a GBP 2.5 million combined allowance for APR and BPR assets, capping 100% relief and applying 50% relief to excess values.2 This creates an effective 20% IHT charge on qualifying business property above the threshold (40% standard rate applied to the 50% unreduced value). The allowance -- originally announced at GBP 1 million in the Autumn Budget 2024 and increased to GBP 2.5 million on 23 December 2025 -- represents the most significant structural change to BPR since the relief was increased from 50% to 100% in 1996.3 The Bill is expected to receive Royal Assent before 6 April 2026, but practitioners should monitor its Parliamentary progress and verify the enacted provisions once available.

The reform's impact is concentrated but substantial. HMRC estimates that up to 1,100 estates will pay additional IHT in 2026-27, generating GBP 235 million in Exchequer revenue rising to approximately GBP 505 million annually.4 Of these, around 915 estates claim only BPR, with approximately 700 holding AIM-traded shares now subject to a flat 50% relief rate regardless of the allowance.

For tax advisors and business accountants, the reform creates a three-tier advisory challenge. First, qualification: the existing statutory tests under ss 105-113 remain the threshold gate, and a business that fails the s 105(3) "wholly or mainly" trading test receives zero relief irrespective of the allowance. Second, quantification: for qualifying businesses exceeding GBP 2.5 million, the allowance allocation mechanism -- including spousal transfers, trust provisions, and chronological ordering -- determines the effective IHT liability. Third, mitigation: planning strategies including lifetime gifting, equity restructuring, and trust settlements must be evaluated against the anti-forestalling rules operative from 30 October 2024. This article provides a comprehensive practitioner framework addressing each tier.

The residence-based IHT regime, enacted from 6 April 2025 under the Finance Act 2025, adds further complexity for internationally connected business owners whose BPR-qualifying UK assets now fall within an expanded liability framework determined by long-term UK residence rather than domicile.5

2. The BPR Statutory Framework: Qualification Fundamentals

2.1 Legislative Architecture

The BPR provisions occupy twelve operative sections within IHTA 1984 Part V Chapter I. Section 103 provides interpretive definitions. Section 104 establishes the core relief mechanism, currently providing 100% reduction for qualifying business property.1 Section 105 defines six categories of "relevant business property," ranging from businesses carried on by the transferor (s 105(1)(a)) to unquoted shares (s 105(1)(bb)) and interests in partnerships (s 105(1)(a)), while also providing 50% relief for quoted shares conferring control (s 105(1)(cc)) and land or machinery used in controlled companies (s 105(1)(d) and (e)).6

Section 106 imposes a two-year minimum ownership requirement preceding the transfer. Sections 107-109 provide replacement property, succession, and successive transfer provisions that allow aggregation of ownership periods across qualifying assets. Section 110 directs that relief applies to the net value of business property (assets minus liabilities). Sections 111 and 112 address group companies with excluded activities and the excepted assets exclusion, respectively. Section 113 denies relief where a binding contract for sale exists at the time of transfer, and sections 113A-113B impose continuing ownership conditions on lifetime transfers where the transferor dies within seven years.

2.2 The Section 105(3) "Wholly or Mainly" Test

The most consequential qualification test is the exclusion under s 105(3), which denies BPR where a business consists "wholly or mainly" of dealing in securities, stocks or shares, land or buildings, or making or holding investments.7 This test operates on an all-or-nothing basis: a business assessed at 51% trading qualifies for full relief; at 49% trading, no relief whatsoever.

HMRC's Shares and Assets Valuation Manual at SVM111150 directs caseworkers to apply the five-factor framework established in Farmer v IRC [1999] SpC 216: (i) the overall context of the business, (ii) capital employed in each activity, (iii) time spent by employees on each activity, (iv) turnover attributable to each activity, and (v) profit generated by each activity.8 The tribunal must "stand back" and consider all factors holistically without giving disproportionate weight to any single indicator.

Subsequent case law has refined the application. In IRC v George [2003] EWCA Civ 1763 (reported at [2004] STC 147), the Court of Appeal considered a residential caravan park operating as a hybrid trading and investment business and held that BPR was due because the investment element was not the "main" component despite significant property holdings.9 In HMRC v Brander (as executor of the 4th Earl of Balfour) [2010] UKUT 300 (TCC), the Upper Tribunal applied the Farmer principles to a diversified Scottish sporting estate, confirming the holistic multi-factor assessment and establishing that a business may comprise multiple activities without disqualification provided trading predominates.10

The practical consequence is that businesses operating near the 50% threshold require meticulous factual analysis. A company deriving 55% of turnover from trading but holding 60% of its capital in investment property presents conflicting indicators. HMRC guidance indicates the position should be assessed over a "reasonable period" prior to the transfer to smooth temporary fluctuations, but no statutory safe harbour exists.8

2.3 Worked Example: The Trading Threshold

Consider a company with the following profile assessed over the two years preceding the transferor's death: trading turnover of GBP 1.2 million (58% of total) against investment income of GBP 870,000 (42%); employee time allocated 65% to trading operations; but capital employed 55% in investment property. Applying the Farmer framework, the overall context (a company originally established as a trading entity that has diversified into property investment), combined with the turnover and employee-time indicators, would support BPR qualification. However, the capital-employed factor creates genuine uncertainty. Under the new regime, this assessment has intensified commercial significance: failure means not merely the loss of an uncapped relief, but exposure of the entire business value to a 40% charge.

3. Compliance Traps: Excepted Assets and Binding Contracts

3.1 Section 112: The Excepted Assets Exclusion

Section 112 provides that BPR does not apply to the value attributable to "excepted assets" -- assets that were neither used wholly or mainly for business purposes in the two years preceding the transfer (limb (a)) nor required at the time of the transfer for future use in the business (limb (b)).11 Unlike the s 105(3) test, which operates as an all-or-nothing gate on the entire business, the excepted assets test reduces the qualifying value pound for pound.

Under the new GBP 2.5 million allowance, this distinction becomes materially more consequential. Previously, with uncapped 100% relief, a company with GBP 500,000 of excepted assets within a GBP 5 million business still achieved full relief on the remaining GBP 4.5 million. From April 2026, that GBP 500,000 of excepted value directly reduces the 100% relief envelope, potentially pushing additional value into the 50% relief band and generating an IHT liability where none would have existed had the cash been deployed in trading activities.12

HMRC's operational position, reflected in SVM111210, is that future business use must be "clearly contemplated" with evidence of "some positive decision or firm intention."13 The case law reinforces this standard. In Brown's Executors v IRC [1996] STC (SCD) 277, surplus cash from a nightclub business sale held in a deposit account failed limb (b) absent evidence of a positive decision regarding redeployment. In Barclays Bank Trust Co Ltd v IRC [1998] STC (SCD) 125, the tribunal assessed whether a company's strong cash position (exceeding GBP 450,000) exceeded genuine working capital requirements, establishing that surplus cash must be justified by reference to concrete business needs rather than general prudence.

Practitioners advising business owners with significant cash reserves or non-operational assets must document the commercial rationale for asset retention. Board minutes recording investment plans, capital expenditure proposals, or working capital modelling provide the evidential foundation that HMRC requires.13

3.2 Section 113: The Binding Contract Exclusion

Section 113 denies BPR where a binding contract for sale exists at the time of the transfer.14 Two exceptions apply: business incorporations where consideration is wholly or mainly shares or securities (s 113(a)), and company reconstructions or amalgamations (s 113(b)).

The critical planning distinction lies between cross-option agreements and buy-and-sell agreements for shareholder protection. A buy-and-sell agreement creates mutual binding obligations between shareholders -- an obligation to sell on one side and to purchase on the other -- constituting a binding contract that defeats BPR. A cross-option agreement provides separate put and call options: the deceased's estate holds an option to require the surviving shareholders to purchase, and the surviving shareholders hold an option to require the estate to sell.15 HMRC accepts that these separate options do not constitute a binding contract under s 113, preserving BPR eligibility.

HMRC also subjects transfers followed by sales within six months to close scrutiny, as documented at SVM111120. While a post-death sale does not automatically defeat BPR (the test is whether a binding contract existed at the date of transfer), rapid sales invite investigation into whether informal pre-death agreements existed.15

For practitioners advising on shareholder protection arrangements, the structural difference between cross-option and buy-and-sell agreements represents the distinction between preserving and destroying BPR. Given that the April 2026 reforms make BPR qualification more commercially significant than ever -- a GBP 3 million shareholding with full BPR faces GBP 100,000 IHT, whereas the same shareholding without BPR faces GBP 1.2 million -- the drafting of these agreements demands meticulous attention.

4. The April 2026 Reform: Allowance Framework and Mechanics

4.1 The GBP 2.5 Million Combined Allowance

Finance Bill 2025-26 inserts a new Chapter 2A into IHTA 1984, establishing the individual GBP 2.5 million allowance and amending ss 104 and 116.16 The allowance operates as a combined ceiling across both APR and BPR qualifying assets. Where a taxpayer holds both agricultural and business property, the allowance is proportionally allocated based on the relative values of qualifying assets, not by taxpayer election.2

The chronological allocation methodology, confirmed through the government's trust consultation response (which received 122 formal submissions between 27 February and 23 April 2025), means that the order and timing of transfers directly affects relief outcomes.17 Practitioners modelling multi-asset, multi-transfer scenarios must sequence transfers to optimise allocation, recognising that the absence of an election mechanism removes flexibility.

4.2 AIM-Traded Shares: The 50% Flat Rate

Shares admitted to trading on AIM, designated as "not listed" on a recognised stock exchange for BPR purposes, face a fundamentally different treatment from 6 April 2026. These shares receive only 50% relief regardless of value and regardless of the GBP 2.5 million allowance.18 This represents a reduction from the current 100% relief and affects approximately 700 of the estimated 915 BPR-only estates impacted by the reforms. The effective IHT rate on AIM shares rises from 0% to 20% (40% applied to the 50% unreduced value), representing a material change for portfolios that were previously IHT-exempt.

4.3 Spousal Transfer and Combined Planning

Unused allowance transfers to the surviving spouse or civil partner on death.19 Critically, where the first death preceded 6 April 2026, the full GBP 2.5 million is deemed available for transfer, creating a significant planning opportunity for recently bereaved clients. The GOV.UK policy paper states that couples can pass up to GBP 5.65 million of combined qualifying business, agricultural, and personal property free of IHT -- a figure comprising dual BPR/APR allowances (GBP 2.5 million x 2 = GBP 5 million) and dual nil-rate bands (GBP 325,000 x 2 = GBP 650,000).3 Where the residence nil-rate band conditions are also satisfied, the combined tax-free threshold increases further to GBP 6.0 million (adding GBP 175,000 x 2 = GBP 350,000).

This spousal transfer mechanism demands immediate attention for clients where the first spouse has recently died. Advisors should verify whether the deceased's estate included BPR-qualifying assets and, if not, confirm that the full GBP 2.5 million deemed allowance is available for transfer to the surviving spouse's estate.

4.4 Effective IHT Calculations at Different Business Values

The practical impact of the reform is best illustrated through worked examples. For a sole business owner with no agricultural property and no spousal transfer:

  • Business valued at GBP 2.5 million: Full 100% relief applies. IHT liability: nil.
  • Business valued at GBP 5 million: 100% relief on GBP 2.5 million; 50% relief on the remaining GBP 2.5 million, leaving GBP 1.25 million subject to IHT at 40%. IHT liability: GBP 500,000.
  • Business valued at GBP 10 million: 100% relief on GBP 2.5 million; 50% relief on GBP 7.5 million, leaving GBP 3.75 million subject to IHT at 40%. IHT liability: GBP 1,500,000.2

For a surviving spouse with a transferred allowance (total GBP 5 million at 100% relief):

  • Business valued at GBP 5 million: Full 100% relief. IHT liability: nil.
  • Business valued at GBP 10 million: 100% relief on GBP 5 million; 50% relief on GBP 5 million, leaving GBP 2.5 million at 40%. IHT liability: GBP 1,000,000.

These calculations assume the nil-rate band is exhausted by non-business assets. The ten-year interest-free instalment option, extended to all BPR/APR qualifying property from April 2026 under amendments to ss 227 and 234 IHTA 1984, provides liquidity relief where estates cannot fund the liability from liquid assets.20

4.5 Anti-Forestalling and Lifetime Transfers

Lifetime transfers of BPR-qualifying assets made on or after 30 October 2024 fall within the new allowance rules if the donor dies on or after 6 April 2026 within seven years.21 This anti-forestalling provision catches gifts already made in the period between the Autumn Budget announcement and the reform's operative date. The allowance refreshes every seven years for lifetime transfers, creating timing-dependent planning windows: a gift made on 1 November 2024 that survives until 2 November 2031 falls outside the seven-year window and restores the donor's GBP 2.5 million allowance.

The CPI indexation freeze compounds the planning urgency. The GBP 2.5 million allowance remains frozen until tax year 2030-31, with CPI indexation commencing only from 6 April 2031.22 At a projected 3% annual CPI, the real value of the allowance erodes by approximately 15% over the five-year freeze, meaning that a business growing in nominal value at or above inflation faces an expanding effective IHT exposure without any corresponding increase in the relief threshold.

5. Trust Provisions and Lifetime Gifting Strategies

5.1 Trust Allowances: Pre- and Post-October 2024 Settlements

The trust consultation outcome confirmed that each trust receives its own GBP 2.5 million allowance, refreshing every ten years in alignment with the ten-year anniversary charge cycle.17 However, a critical distinction applies based on settlement date:

  • Pre-30 October 2024 trusts: Each trust retains a separate and independent GBP 2.5 million allowance. Existing trust structures settled before the Autumn Budget announcement are therefore grandfathered with individual allowances.
  • Post-30 October 2024 trusts: Related settlements share their allowances. The allocation between related trusts follows the proportional methodology, reducing the effectiveness of creating multiple trusts to multiply available allowances.

Exit charges are calculated on unrelieved values regardless of the timing relative to the ten-year anniversary, requiring trustees to model the interaction between the trust allowance, the unrelieved proportion, and the effective exit charge rate.17

The government rejected proposals for spousal transferability of trust allowances, election-based allocation, and extension of related property rules. These decisions limit planning flexibility but provide certainty regarding the operative framework.

5.2 Lifetime Gifting Within the Seven-Year Mechanism

Lifetime transfers of BPR-qualifying business property represent a primary mitigation strategy. A gift that survives seven years falls outside the cumulation period, and the donor's allowance refreshes for subsequent transfers.21 However, the continuing ownership conditions under s 113A require the donee to retain the qualifying property (or replacement property under s 113B) from the date of the gift until the earlier of the donor's death or seven years. If the donee sells the business before the seven-year period expires and the donor dies within that period, BPR is lost on the original transfer.

For practitioners, the interaction between the seven-year refreshing mechanism and the anti-forestalling date creates a planning matrix: gifts made before 30 October 2024 are assessed under the pre-reform rules if the donor dies within seven years, whereas gifts from 30 October 2024 onwards are assessed under the new allowance framework. This distinction is particularly relevant where advisors recommended accelerated gifting programmes during the consultation period.

5.3 Equity Restructuring and Share Capital Reorganisation

Where a business exceeds the GBP 2.5 million threshold, equity restructuring can distribute value across multiple shareholders, each potentially qualifying for their own allowance. A company valued at GBP 7.5 million could, through a reorganisation of share capital and gradual transfer of shares to the next generation, spread the value across three individual allowances totalling GBP 7.5 million.2 However, such arrangements must satisfy the two-year ownership requirement under s 106 and the replacement property provisions under s 107. Practitioners should also consider the general anti-abuse rule under Finance Act 2013, Part 5 (ss 206-215), which applies to arrangements that cannot reasonably be regarded as a reasonable course of action in relation to the relevant tax provisions.23 HMRC scrutiny of reorganisations motivated primarily by tax considerations is anticipated, and advisors should ensure that any restructuring has genuine commercial substance beyond IHT mitigation.

6. Practitioner Planning Framework

6.1 The Three-Stage Compliance Protocol

The April 2026 reforms require advisors to adopt a structured three-stage approach for every BPR-eligible client:

Stage 1 -- Qualify: Confirm trading status under the s 105(3) "wholly or mainly" test by applying the Farmer five-factor analysis.8 Identify and quantify excepted assets under s 112, documenting the commercial rationale for retention of surplus cash or non-operational property.13 Review shareholder or partnership agreements to verify cross-option (not buy-and-sell) structuring under s 113.15

Stage 2 -- Quantify: Value qualifying business property net of excepted assets. Model the GBP 2.5 million allowance allocation across business and agricultural property. Calculate effective IHT liability at current values and projected growth rates. Assess spousal transfer availability, including the deemed GBP 2.5 million where the first death preceded April 2026.19 Evaluate trust-held assets and the applicable trust allowance.

Stage 3 -- Mitigate: Evaluate lifetime gifting strategies against the seven-year window and the anti-forestalling date. Consider equity restructuring to distribute value across multiple allowances. Model trust settlements with attention to the pre/post-October 2024 distinction. Assess insurance requirements to fund residual IHT liability. Review cross-option agreements and ensure BPR-preserving structures are in place.

6.2 Monitoring the Judicial Review

A judicial review challenging the adequacy of the APR/BPR consultation process has been granted a rolled-up hearing before Mrs Justice Lang, scheduled for February/March 2026.24 The claimants, including the campaign group "Farmers and Businesses for Fair Tax Relief," contend that the consultation process was procedurally deficient. The remedy sought is declaratory only: a finding that the consultation was unlawful would not invalidate the legislation itself. Practitioners should monitor the outcome as a contextual factor but should plan on the basis that the substantive reforms proceed as legislated.

6.3 The Residence-Based IHT Dimension

The residence-based IHT regime from 6 April 2025 replaced the domicile-based system with a long-term UK residence test (broadly, resident for 10 of the preceding 20 tax years).5 For business owners with international connections, this intersects with BPR in two respects. First, overseas assets of long-term UK residents are now within the IHT net, potentially creating competing claims on the GBP 2.5 million allowance if those overseas assets include qualifying business or agricultural property. Second, the three-to-ten-year "tail" provisions mean formerly long-term residents departing the UK remain within scope, affecting the timing of any BPR-qualifying transfers.

Conclusion

The April 2026 BPR reforms mark a structural shift from a binary qualification regime to a graduated system of capped reliefs. The advisory landscape transforms from "does it qualify?" to the more complex "how much qualifies, and what is the most efficient allocation?" Practitioners must now integrate three previously separate disciplines: the established case law framework governing qualification under ss 105-113, the new allowance mechanics introduced by Finance Bill 2025-26, and the mitigation strategies that manage the residual IHT exposure.

The commercial consequences of advisory error have multiplied. Under the uncapped regime, a failure to identify excepted assets reduced relief but did not necessarily generate material IHT. Under the new regime, every pound of excepted value shrinks the 100% relief envelope and may push additional value into the 50% band. A structuring error in a shareholder protection agreement that defeats BPR entirely transforms a GBP 100,000 liability into a GBP 1.2 million exposure. The margin for error has narrowed precisely as the complexity has increased.

With the allowance frozen until 2031 and real value eroding through inflation, the planning window for lifetime transfers and structural reorganisations is finite. Advisors who delay risk advising clients on a diminished allowance. The three-stage protocol -- qualify, quantify, mitigate -- provides a systematic framework for navigating a reform that, while concentrated in its impact on 1,100 estates, reshapes the advisory relationship for every business owner whose assets approach or exceed the GBP 2.5 million threshold.

CPD Declaration

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

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Apply the Farmer five-factor test to assess whether a business satisfies the s 105(3) "wholly or mainly" trading requirement for BPR qualification
  2. Distinguish between the excepted assets exclusion under s 112 and the binding contract bar under s 113, identifying the evidential requirements for each
  3. Calculate effective IHT liabilities under the April 2026 GBP 2.5 million combined allowance at varying business values, incorporating spousal transfers and trust provisions
  4. Evaluate lifetime gifting, equity restructuring, and trust settlement strategies against the anti-forestalling rules and the seven-year allowance refreshing mechanism

SRA Competency Mapping

  • Technical legal practice: Inheritance tax compliance and advisory (SRA Competence Statement, Section A2)
  • Working with other people: Multi-disciplinary advisory coordination for tax-efficient estate planning (SRA Competence Statement, Section B)

Reflective Questions

  1. How would the April 2026 allowance cap change the priority given to excepted assets analysis within current client review protocols?
  2. What additional documentation procedures should be implemented when advising business owners with hybrid trading and investment activities near the s 105(3) threshold?
  3. How might the distinction between pre- and post-30 October 2024 trust settlements affect existing trust restructuring recommendations for clients with substantial business property?

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. Inheritance Tax Act 1984, Part V, Chapter I (ss 103-114). https://www.legislation.gov.uk/ukpga/1984/51/part/V/chapter/I ↩ ↩2

  2. GOV.UK -- Agricultural property relief and business property relief changes (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4

  3. GOV.UK -- Inheritance tax reliefs threshold to rise to GBP 2.5m (23 December 2025). https://www.gov.uk/government/news/inheritance-tax-reliefs-threshold-to-rise-to-25m-for-farmers-and-businesses ↩ ↩2

  4. GOV.UK -- Agricultural property relief and business property relief changes -- Exchequer impact (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  5. Finance Act 2025, Part 2, Chapter 4, s 44 -- Excluded property: domicile test replaced with long-term residence test. https://www.legislation.gov.uk/ukpga/2025/8/section/44/enacted ↩ ↩2

  6. IHTA 1984 s 105 -- Relevant business property. https://www.legislation.gov.uk/ukpga/1984/51/section/105 ↩

  7. IHTA 1984 s 105(3) -- Investment business exclusion. https://www.legislation.gov.uk/ukpga/1984/51/section/105 ↩

  8. HMRC Shares and Assets Valuation Manual -- SVM111150: Wholly or mainly test. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111150 ↩ ↩2 ↩3

  9. IRC v George [2003] EWCA Civ 1763; [2004] STC 147. ↩

  10. HMRC v Brander (as executor of the 4th Earl of Balfour) [2010] UKUT 300 (TCC). ↩

  11. IHTA 1984 s 112 -- Excepted assets. https://www.legislation.gov.uk/ukpga/1984/51/section/112 ↩

  12. HMRC Shares and Assets Valuation Manual -- SVM111210: Excepted assets. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111210 ↩

  13. HMRC Shares and Assets Valuation Manual -- SVM111210: Evidence requirements for future business use. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111210 ↩ ↩2 ↩3

  14. IHTA 1984 s 113 -- Contracts for sale. https://www.legislation.gov.uk/ukpga/1984/51/section/113 ↩

  15. HMRC Shares and Assets Valuation Manual -- SVM111120: Contracts for sale, shareholdings and partnership interests. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111120 ↩ ↩2 ↩3

  16. GOV.UK -- Summary of reforms to agricultural property relief and business property relief (Finance Bill 2025-26 provisions). 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 ↩

  17. GOV.UK -- Reforms to IHT APR and BPR: 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 ↩ ↩2 ↩3

  18. GOV.UK -- Summary of reforms to APR and BPR (AIM shares treatment). 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 ↩

  19. GOV.UK -- Agricultural property relief and business property relief changes (spousal transfer provisions). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2

  20. GOV.UK -- Agricultural property relief and business property relief changes (instalment provisions). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩

  21. GOV.UK -- Agricultural property relief and business property relief changes (anti-forestalling). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2

  22. GOV.UK -- Reforms to IHT APR and BPR trusts consultation response (CPI indexation freeze). 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 ↩

  23. Finance Act 2013, Part 5 (ss 206-215) -- General Anti-Abuse Rule. https://www.legislation.gov.uk/ukpga/2013/29/part/5 ↩

  24. Collyer Bristow -- Farmers and business owners seek judicial review (December 2025). https://collyerbristow.com/news/farmers-and-business-owners-seek-judicial-review-of-inheritance-tax-changes-to-agricultural-business-property-relief/ ↩

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