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ESG and Tax Relief: Integrating Sustainable Investments into Estate Tax Planning

· 21 min

Executive Summary

The intersection of ESG-aligned investing and inheritance tax planning presents a significant analytical challenge for tax advisors. ESG labels do not confer IHT advantages; the tax treatment depends entirely on the underlying investment structure and the specific provisions of the Inheritance Tax Act 1984 engaged. From 6 April 2026, the proposed APR/BPR relief reforms -- capping 100% relief at GBP 2.5 million per individual and reducing AIM share BPR to 50% in all cases -- fundamentally alter the calculus for several ESG-relevant investment categories. This article provides a systematic framework mapping six categories of ESG-aligned investment against IHTA 1984 relief provisions, evaluated against the reformed relief landscape. It addresses the critical distinction between unquoted EIS shares in green economy companies (retaining 100% BPR access) and AIM ESG portfolios (relegated to 50% BPR), while examining woodland, heritage, and charitable routes that remain significant and, in some cases, uncapped.

1. The ESG-IHT Convergence: Why It Matters Now

The UK low carbon and renewable energy economy recorded turnover of GBP 77 billion in 2024, representing a 91.3% increase from 2015 and employing 304,000 full-time equivalents.1 Simultaneously, IHT receipts reached GBP 7.1 billion in the period April 2025 to January 2026, with the OBR forecasting GBP 8.7 billion for 2025-26 and the nil-rate band frozen at GBP 325,000 until April 2030-31.2 These twin trajectories -- an expanding green economy and escalating IHT liabilities -- generate increasing demand from clients seeking portfolios that align with sustainability objectives while mitigating estate tax exposure.

Professional practice, however, treats these disciplines in isolation. ESG investment guidance addresses portfolio construction, risk-return profiles, and the FCA's Sustainability Disclosure Requirements regime without reference to estate tax consequences.3 Conversely, IHT planning literature analyses reliefs and exemptions with little regard for the sustainability characteristics of qualifying investments. This separation leaves tax advisors without a systematic framework for advising clients who seek both.

Three concurrent developments make integration urgent. First, the APR/BPR relief reforms proposed to take effect from 6 April 2026 restructure the relief landscape for business and agricultural property, directly affecting the IHT treatment of several ESG-relevant investment categories.4 Second, the FCA's anti-greenwashing rule, effective from 31 May 2024, imposes obligations on authorised firms to ensure sustainability claims are fair, clear, and not misleading -- a requirement with direct implications for advisors recommending ESG-aligned IHT strategies.3 Third, the residence-based IHT regime enacted from 6 April 2025, replacing the domicile-based system under Finance Act 2025 Schedule 13, introduces the long-term UK resident test as the gateway to worldwide IHT exposure, relevant where ESG investments are held across jurisdictions.5

The critical analytical principle underpinning this article is that an investment's ESG credentials and its IHT treatment are determined by entirely separate legal tests. A solar farm investment may score highly on environmental metrics while failing the BPR qualifying trade test due to the November 2015 energy generation exclusion. Conversely, a company carrying on an environmentally harmful trade may qualify for full BPR. Tax advisors must assess each investment against the specific provisions of IHTA 1984, then overlay the ESG analysis as a separate consideration.

2. The IHT Relief Landscape for Sustainable Investments

Six IHTA 1984 relief provisions are relevant to ESG-aligned estate planning. Understanding each before examining specific investment categories is essential.

Business Property Relief (ss.104-114)

BPR reduces the value transferred by a transfer of value attributable to "relevant business property" as defined in s.105.6 Currently, a business or interest in a business and unquoted shares (including AIM shares, which are "not listed on a recognised stock exchange" per s.105(1ZA)) qualify for 100% BPR, subject to a two-year minimum holding period under s.106.7 The critical exclusion is s.105(3): BPR is unavailable where the business consists "wholly or mainly" of dealing in securities, stocks or shares, land or buildings, or making or holding investments.8 This provision is the primary gatekeeper for any ESG investment seeking BPR qualification -- the business must be a qualifying trading business, not an investment vehicle holding ESG-labelled assets.

The proposed reforms to BPR, contained in the Finance (No. 2) Bill 2025-26, introduce a GBP 2.5 million combined APR/BPR allowance for 100% relief (increased from the originally proposed GBP 1 million following the December 2025 government concession), transferable between spouses, effectively providing GBP 5 million per couple.4 Crucially, AIM shares are relegated to 50% BPR in all cases with no access to the GBP 2.5 million allowance, while unquoted shares (including EIS shares) retain access to 100% BPR within the allowance.4 Interest-free instalments over ten years are extended to all qualifying APR/BPR property.4 The Finance (No. 2) Bill 2025-26 had not received Royal Assent as of the date of writing; the provisions are expected to take effect from 6 April 2026 as announced, subject to Parliamentary approval. References to the "post-April 2026" position throughout this article should be read accordingly.

Agricultural Property Relief (ss.115-124B)

APR applies to agricultural property occupied for the purposes of agriculture, with relief at 100% where the transferor had vacant possession or the right to obtain it, or 50% otherwise.9 From April 2026, subject to Royal Assent, APR is subject to the same GBP 2.5 million combined allowance.4 The relevance to ESG strategies arises primarily through woodland ancillary to agricultural land and natural capital initiatives on farmland.

Woodland Relief (ss.125-130)

Section 125 provides a deferral (not exemption) for the value of trees and underwood growing on UK land that is not agricultural property.10 The election must be made within two years of death, the deceased must have owned the land for five years preceding death, and from 6 April 2024 the relief applies to UK woodland only.11 Tax becomes chargeable on subsequent disposal under s.126. While modest in scope, this relief is significant for ESG-aligned forestry strategies.

Heritage Conditional Exemption (ss.30-35)

Heritage conditional exemption provides 100% IHT exemption for qualifying heritage assets -- buildings of outstanding historic or architectural interest, land of outstanding scenic, historic, or scientific interest, and objects of national, scientific, historic, or artistic interest designated under s.31.12 The new owner must give undertakings to preserve the property, maintain reasonable public access, and retain objects in the UK.13 There is no monetary cap, and the exemption is unaffected by the proposed April 2026 BPR/APR reforms, making it a distinctive planning tool.

Charitable Reduced Rate (s.7 / Schedule 1A)

Where 10% or more of the net estate is left to qualifying charities, the IHT rate reduces from 40% to 36%.14 Post-death implementation via a deed of variation under s.142 is available within two years. The interaction between the reduced rate and the charitable legacy requires individual modelling to determine whether a net benefit arises for non-charitable beneficiaries.

Normal Expenditure Out of Income (s.21)

Regular charitable giving from income, rather than capital, is exempt from IHT under s.21 where the gifts form part of the transferor's normal expenditure, are made from income, and leave the transferor with sufficient income to maintain their usual standard of living. This provision supports lifetime charitable giving to environmental causes as an IHT-neutral strategy.

3. EIS, SEIS, and Unquoted Green Economy Companies

Enterprise Investment Scheme shares in qualifying companies offer a triple tax benefit: 30% income tax relief on investments up to GBP 1 million per year (GBP 2 million for knowledge-intensive companies), CGT exemption on disposal after three years, and BPR eligibility after two years of holding provided the company qualifies as a trading company under s.105.1516 EIS was extended from 6 April 2025 until 6 April 2035, with investment limits increasing from April 2026.17

The Energy Generation Exclusion

A critical restriction for green sector EIS investment is that from 30 November 2015, the provision of reserve energy generating capacity and the generation of renewable energy benefiting from other government support (Feed-in Tariffs, Renewables Obligation Certificates, Contracts for Difference) were excluded from EIS qualifying trades under ITA 2007 s.192.15 From 6 April 2016, the exclusion was broadened to encompass all energy generation activities, not merely subsidised renewable generation (Finance Act 2016, s.31). This means that any business whose trade consists wholly or mainly of energy generation -- whether renewable or conventional, subsidised or unsubsidised -- is ineligible for EIS. However, green technology development, energy efficiency services, clean transport solutions, environmental consultancy, waste management technology, and other non-generation green economy activities remain qualifying trades. Tax advisors must examine each company's trade against the exclusion criteria, not merely its ESG classification.

Post-April 2026 Position

The proposed BPR reforms create a material advantage for unquoted EIS shares over AIM shares. EIS companies, as unquoted trading companies, retain access to 100% BPR within the GBP 2.5 million allowance.4 For a client investing GBP 500,000 in an EIS-qualifying clean technology company, the combined benefits after the two-year holding period comprise:

  • Income tax relief: GBP 150,000 (30% of GBP 500,000) -- claimed in the year of investment
  • BPR: 100% relief within the GBP 2.5 million allowance, eliminating IHT on the investment value
  • CGT exemption: no capital gains tax on disposal after three years

By contrast, the same GBP 500,000 allocated to an AIM ESG portfolio would, from April 2026, attract only 50% BPR, producing an effective IHT charge of GBP 100,000 (20% effective rate on GBP 500,000) with no income tax relief at investment.18

Scale of Opportunity

In 2023-24, 3,780 companies raised GBP 1,575 million under EIS, with the Information and Communication sector -- which encompasses clean technology -- accounting for GBP 551 million (35% of total EIS investment).19 SEIS raised GBP 242 million from 2,290 companies, a 51% increase from 2022-23, driven by the April 2023 expansion of annual and lifetime investment limits to GBP 250,000.19 While HMRC statistics do not disaggregate "green" or "ESG" companies, the dominant position of the technology sector suggests a substantial pool of potentially qualifying green economy companies.

Practical Considerations

Tax advisors should verify three conditions before recommending EIS for combined IHT and ESG objectives: first, that the company has obtained HMRC advance assurance confirming its qualifying trade status; second, that the specific trade does not fall within the November 2015 energy generation exclusion; and third, that the company satisfies the "wholly or mainly trading" test for BPR purposes under s.105(3), which is assessed by HMRC on a facts-and-circumstances basis.8

4. AIM Shares, ESG Portfolios, and the April 2026 Reckoning

AIM shares are treated as "unquoted" for BPR purposes because AIM is not a recognised stock exchange (s.105(1ZA) IHTA 1984).20 Currently, qualifying AIM shares held for two years attract 100% BPR, and ESG-screened AIM portfolios have been marketed as combining IHT efficiency with sustainability alignment.

The Proposed April 2026 Change

From 6 April 2026, subject to Royal Assent of the Finance (No. 2) Bill 2025-26, AIM shares attract 50% BPR only, with no access to the GBP 2.5 million 100% relief allowance.4 The effective IHT rate on qualifying AIM shares rises from 0% to 20%. For an ESG-screened AIM portfolio valued at GBP 1 million, the IHT exposure increases from nil to GBP 200,000 -- a fundamental shift in the risk-return equation.18

Comparative Analysis: AIM ESG versus Unquoted EIS

For an estate of GBP 2 million above the available nil-rate bands, the post-April 2026 comparison is stark:

Parameter AIM ESG Portfolio Unquoted EIS Green Company
BPR rate from April 2026 50% 100% (within GBP 2.5m allowance)
Effective IHT rate 20% 0% (within allowance)
IHT on GBP 1m investment GBP 200,000 GBP 0
Income tax relief at investment None 30% (GBP 300,000 on GBP 1m)
CGT on disposal Standard rates Exempt after 3 years
Liquidity Quoted market; daily dealing Illiquid; 3-year minimum hold
Diversification Portfolio of 20-40 companies Single company or small portfolio
Risk profile Market risk; lower single-company risk Higher single-company risk; early-stage risk

The IHT advantage of unquoted EIS is unambiguous. However, AIM portfolios offer liquidity, diversification, and lower single-company risk. The 20% effective IHT rate on AIM shares remains more favourable than the 40% rate on non-qualifying assets. Tax advisors must weigh these factors against individual client circumstances, including investment horizon, risk tolerance, and the proportion of the estate represented by the investment.

Reassessing Client Portfolios

Practitioners holding existing AIM ESG portfolios for clients should initiate a review ahead of April 2026. The analysis should consider whether a reallocation from AIM to unquoted EIS green companies is appropriate given the client's risk profile, whether the GBP 2.5 million allowance is better utilised by other qualifying assets (agricultural property, family trading businesses), and whether the AIM portfolio's liquidity serves other estate planning objectives such as meeting IHT liabilities on non-qualifying assets.

5. Woodland, Forestry, and Natural Capital

Woodland and forestry investments occupy a distinctive position in the ESG-IHT landscape, potentially engaging three separate IHTA 1984 relief provisions simultaneously while delivering verifiable environmental benefits.

Woodland Relief (s.125)

The s.125 deferral applies to the value of trees and underwood on UK land (not the underlying land itself), provided the deceased owned the land for five years preceding death.10 The election must be made within two years of death. From 6 April 2024, relief applies to UK woodland only following the Finance Act 2024 amendment restricting the geographical scope.11 The deferral mechanism means tax becomes chargeable under s.126 on subsequent disposal of the timber, making this a timing relief rather than an outright exemption. For clients with established UK woodland, the deferral provides cash flow benefit to estates while the woodland continues its environmental function.

APR for Ancillary Woodland

Where woodland is "occupied with, and ancillary to, the occupation of agricultural land or pasture" (s.115(2) IHTA 1984), it qualifies for APR rather than woodland relief.9 Ancillary uses include shelter belts, tree nurseries, and short rotation coppice. From April 2026, this APR is subject to the GBP 2.5 million combined allowance. Advisors must distinguish between woodland that is ancillary to agriculture (APR) and standalone woodland (s.125 deferral), as the relief mechanisms differ materially.

BPR for Commercial Forestry

Where forestry is operated as a qualifying trading business -- involving active management, harvesting, processing, and selling timber -- BPR under s.104 may apply at 100%, subject to the s.105(3) investment business exclusion.2122 The characterisation turns on whether the activity constitutes active trading rather than passive land holding. Income from the Woodland Carbon Code, under which projects have created 38,705 hectares of woodland predicted to sequester over 13 million tonnes of CO2 equivalent, may support the trading activity characterisation for BPR purposes, though no published HMRC guidance addresses this point directly.23 Tax advisors should treat the BPR qualification of carbon credit income as uncertain and document the analysis carefully.

Environmental Land Management Schemes

Defra has secured GBP 2.7 billion funding for sustainable farming and nature recovery for 2026-27 to 2028-29, with ELMS funding expanding by 150%.24 ELMS payments to landowners managing land for environmental outcomes interact with both the APR and BPR analyses. Advisors must consider whether ELMS participation affects the "occupied for the purposes of agriculture" test under s.115(2) for APR, and whether the payments constitute trading or investment income for BPR purposes. The interaction remains an area requiring professional judgement pending specific HMRC guidance.

Combined Relief Potential

A single woodland investment may engage all three provisions: s.125 deferral on timber value, APR on land ancillary to agricultural property, and BPR where the forestry operation constitutes a qualifying trade. Combined with verifiable carbon sequestration under the Woodland Carbon Code, this represents a uniquely convergent ESG-IHT planning opportunity -- though advisors must map each element of value to the correct relief provision and should not assume all three apply to the same asset without detailed analysis.

6. Heritage Assets, Charitable Giving, and Green Gilts

Heritage Conditional Exemption

The heritage conditional exemption under ss.30-35 provides 100% IHT exemption with no monetary cap for qualifying heritage assets designated by the Treasury under s.31.12 For clients with interests in heritage conservation -- historic buildings, landscapes of outstanding scenic or scientific interest, works of national importance -- this route aligns conservation objectives with estate tax efficiency. The conditions (preservation, public access of typically 28 days per year, and retention in the UK) are onerous, and HMRC determines qualifying status on advice from heritage advisory agencies.13 The exemption is unaffected by the proposed April 2026 BPR/APR reforms, making it a distinctive route for high-value heritage assets that might otherwise face substantial IHT charges.

The 36% Charitable Reduced Rate

Directing 10% or more of the net estate to qualifying charities, including environmental charities and conservation trusts, reduces the IHT rate from 40% to 36%.14 The net benefit requires individual modelling. Consider an estate with a net taxable value (after nil-rate bands) of GBP 1 million:

  • Without charitable legacy: IHT at 40% on GBP 1 million = GBP 400,000; beneficiaries receive GBP 600,000
  • With 10% charitable legacy (GBP 100,000): IHT at 36% on GBP 900,000 = GBP 324,000; beneficiaries receive GBP 576,000; charity receives GBP 100,000

The non-charitable beneficiaries receive GBP 24,000 less, but the estate achieves GBP 76,000 in IHT savings and the charity receives GBP 100,000. Where the client has environmental philanthropy objectives, the charitable reduced rate provides a mechanism that partially offsets the cost of the legacy through the reduced rate. Post-death implementation via a deed of variation under s.142 allows beneficiaries to redirect assets to environmental charities within two years of death where the deceased did not make provision in the will.14

Green Gilts and NS&I Green Savings Bonds

The UK Government Green Financing Programme has raised over GBP 51 billion since September 2021, with GBP 10 billion in planned green gilt sales for 2025-26 and GBP 1.7 billion raised through NS&I Green Savings Bonds to March 2025.2526 The Green Financing Framework, rated "dark green" by S&P Global Ratings, allocates proceeds across seven eligible expenditure categories including clean transportation, renewable energy, and climate change adaptation.27

However, green gilts and NS&I Green Savings Bonds carry no specific IHT advantage for UK-resident individuals. They are included in the estate at market value on death, identical to conventional gilts and savings products.25 Tax advisors should be alert to the misconception, encountered in client conversations, that "green" investment products confer tax advantages beyond those available to conventional equivalents. The environmental impact of green gilt investment operates through government expenditure allocation, not through the tax treatment of the investor.

7. Practice Framework: The ESG-IHT Decision Matrix

Systematic Assessment

Tax advisors recommending ESG-aligned IHT strategies should apply a four-step framework:

  1. Identify the client's ESG objective: environmental (carbon reduction, conservation), social (community investment), or governance-focused -- this determines the relevant investment universe
  2. Map to IHTA 1984 provisions: for each candidate investment, identify which relief provision is engaged and the post-April 2026 relief rate
  3. Assess qualifying conditions: verify the investment satisfies the specific statutory tests (s.105(3) trading exclusion for BPR, s.115(2) agricultural occupation for APR, s.31 heritage designation, s.7/Schedule 1A charitable threshold)
  4. Model the tax outcome: quantify the IHT saving against the investment risk, liquidity constraints, and the client's overall estate composition

Summary Comparison

ESG Investment Category IHTA 1984 Provision Post-April 2026 Relief Access to GBP 2.5m Allowance Min Holding Key Qualifying Condition
EIS green company (unquoted) BPR s.104 100% (within allowance) Yes 2 years Qualifying trade; not excluded energy generation
AIM ESG portfolio BPR s.104 50% No 2 years Qualifying trade; "not listed" status
Commercial forestry BPR s.104 100% (within allowance) Yes 2 years Active trading, not investment holding
Agricultural woodland APR s.115 100% (within allowance) Yes (combined) 2/7 years (owner-occupied / let) Ancillary to agricultural land
Standalone UK woodland s.125 deferral Deferral (no cap) N/A 5 years UK situs; election within 2 years of death
Heritage property ss.30-35 exemption 100% (no cap) N/A (exempt) None Treasury designation; undertakings
Charitable legacy (environmental) s.7/Sch.1A 36% rate (4% saving) N/A N/A 10% of net estate to charity
Green gilts / NS&I Green Bonds None No relief N/A N/A No IHT advantage for UK residents

FCA SDR Compliance

The FCA's anti-greenwashing rule requires all authorised firms to ensure sustainability claims are fair, clear, and not misleading.3 Where tax advisors recommend ESG-aligned investments for IHT purposes, communications must not overstate the sustainability credentials of recommended investments. The SDR labelling framework -- Sustainability Focus, Sustainability Impact, Sustainability Improvers, and Mixed Goals -- provides a reference point, though tax advisors should note that SDR labels apply to investment products, not to underlying companies.28 Record-keeping should document both the tax planning rationale and the ESG assessment separately, ensuring that the IHT recommendation stands on its own merits irrespective of the ESG overlay.

Forward-Looking: Pension Death Benefits (April 2027)

From 6 April 2027, unused pension funds and death benefits enter the value of estates for IHT, with an estimated 10,500 estates newly liable.29 This development may accelerate client interest in lifetime drawdown of pension capital to fund IHT-efficient investments, including ESG-aligned structures. Advisors should consider whether clients approaching retirement may benefit from drawing pension income to fund EIS investments in green economy companies, simultaneously reducing the pension fund exposed to IHT from 2027 and acquiring assets that attract BPR after two years. The income tax implications of pension drawdown must, of course, be modelled against the potential IHT saving.

Conclusion

The analytical framework presented in this article demonstrates that ESG alignment and IHT efficiency are independently determined. An investment's sustainability credentials -- however genuine -- do not engage the relief provisions of IHTA 1984. The tax treatment depends on whether the investment constitutes relevant business property under s.105, agricultural property under s.115, qualifying woodland under s.125, designated heritage property under s.31, or a charitable legacy meeting the Schedule 1A threshold.

The proposed April 2026 BPR reforms create identifiable advantages within the ESG-IHT landscape. Unquoted EIS shares in qualifying green economy companies retain access to 100% BPR within the GBP 2.5 million allowance, while AIM ESG portfolios are confined to 50% BPR. Woodland and forestry investments remain capable of engaging multiple relief provisions simultaneously. Heritage conditional exemption stands apart as an uncapped, unreformed route for qualifying conservation assets. The charitable reduced rate provides a quantifiable mechanism for integrating environmental philanthropy with estate tax planning.

Tax advisors are well positioned to develop integrated frameworks that serve both client objectives -- but the analysis must proceed from the legal substance of the investment, not its marketing label. In a landscape of expanding green economy opportunity and tightening IHT reliefs, technical rigour in matching ESG-aligned investments to the correct IHTA 1984 provisions is not merely desirable; it is an essential component of competent professional advice.

CPD Declaration

Estimated Reading Time: 21 minutes Technical Level: Advanced Practice Areas: Inheritance Tax Planning, Investment Taxation, ESG Integration, Agricultural and Business Property Relief

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the six IHT relief provisions relevant to ESG-aligned investments and their key qualifying conditions under IHTA 1984
  2. Distinguish between the post-April 2026 BPR treatment of unquoted shares (including EIS) and AIM shares, and explain the implications for ESG-focused estate planning strategies
  3. Evaluate the suitability of EIS investment in a green economy company for combined income tax, CGT, and IHT relief, including the application of the November 2015 energy generation exclusion
  4. Assess the IHT relief potential of woodland and forestry investments by reference to the three applicable IHTA 1984 provisions and the interaction with the April 2026 reforms
  5. Calculate the net benefit of directing 10% of a net estate to environmental charities under the 36% reduced IHT rate

SRA Competency Mapping

  • Technical legal knowledge: Taxation, trusts, and estate planning (SRA Competence Statement A2)
  • Working with other people: Understanding related professional disciplines and regulatory frameworks (SRA Competence Statement B6)

Reflective Questions

  1. How would the April 2026 BPR reforms affect existing client portfolios that combine AIM ESG investments with IHT planning objectives, and what reassessment process should be initiated?
  2. What due diligence steps are necessary to verify that an EIS green economy company qualifies for BPR, particularly in light of the November 2015 energy generation exclusion?
  3. How might the interaction between pension death benefits (from April 2027) and ESG-aligned investment opportunities influence lifetime planning advice for clients approaching retirement?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-26. 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. ONS, Low carbon and renewable energy economy, UK: 2024 (February 2026). https://www.ons.gov.uk/economy/environmentalaccounts/bulletins/finalestimates/2024 ↩

  2. HMRC Tax Receipts and National Insurance Contributions for the UK -- Monthly Bulletin (February 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin; GOV.UK, Inheritance Tax Thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  3. FCA, Sustainability Disclosure and Labelling Regime (November 2023, updated April 2025). https://www.fca.org.uk/firms/climate-change-and-sustainable-finance/sustainability-disclosure-and-labelling-regime ↩ ↩2 ↩3

  4. 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 ↩5 ↩6 ↩7

  5. Finance Act 2025 (c.8), Schedule 13 -- Inheritance Tax: long-term UK residence. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩

  6. Inheritance Tax Act 1984, section 105. https://www.legislation.gov.uk/ukpga/1984/51/section/105 ↩

  7. Inheritance Tax Act 1984, section 106. https://www.legislation.gov.uk/ukpga/1984/51/section/106 ↩

  8. HMRC Shares and Assets Valuation Manual, SVM111100. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111100 ↩ ↩2

  9. HMRC Inheritance Tax Manual, Section 9: Agricultural Property. https://www.gov.uk/guidance/inheritance-tax-manual/section-9-agricultural-property ↩ ↩2

  10. Inheritance Tax Act 1984, section 125. https://www.legislation.gov.uk/ukpga/1984/51/section/125 ↩ ↩2

  11. GOV.UK, Inheritance Tax -- geographical scope of agricultural property relief and woodlands relief (2024). 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 ↩ ↩2

  12. Inheritance Tax Act 1984, section 30. https://www.legislation.gov.uk/ukpga/1984/51/section/30; section 31. https://www.legislation.gov.uk/ukpga/1984/51/section/31 ↩ ↩2

  13. GOV.UK, Tax relief for national heritage assets. https://www.gov.uk/guidance/tax-relief-for-national-heritage-assets ↩ ↩2

  14. GOV.UK, Inheritance Tax reduced rate calculator. https://www.gov.uk/inheritance-tax-reduced-rate-calculator; IHTA 1984 s.7 read with Schedule 1A. ↩ ↩2 ↩3

  15. GOV.UK, HS341 Enterprise Investment Scheme -- Income Tax relief (2025). https://www.gov.uk/government/publications/enterprise-investment-scheme-income-tax-relief-hs341-self-assessment-helpsheet/hs341-enterprise-investment-scheme-income-tax-relief-2025 ↩ ↩2

  16. GOV.UK, Tax relief for investors using venture capital schemes. https://www.gov.uk/guidance/venture-capital-schemes-tax-relief-for-investors ↩

  17. GOV.UK, Venture Capital Trusts, Enterprise Investment Scheme investment limit increase and restructure. https://www.gov.uk/government/publications/enterprise-investment-scheme-eis-and-venture-capital-trusts-vct-changes/venture-capital-trusts-enterprise-investment-scheme-investment-limit-increase-and-restructure ↩

  18. PKF Littlejohn, Business Property Relief Reform: an Inheritance Tax headache for AIM investors. https://www.pkf-l.com/insights/bpr-reforms-2026-aim-listed-investors/ ↩ ↩2

  19. GOV.UK, Enterprise Investment Scheme, Seed Enterprise Investment Scheme and Social Investment Tax Relief statistics: 2025 (May 2025). https://www.gov.uk/government/statistics/enterprise-investment-scheme-seed-enterprise-investment-scheme-and-social-investment-tax-relief-may-2025/enterprise-investment-scheme-seed-enterprise-investment-scheme-and-social-investment-tax-relief-statistics-2025 ↩ ↩2

  20. HMRC Shares and Assets Valuation Manual, SVM111050. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm111050 ↩

  21. Inheritance Tax Act 1984, section 104. https://www.legislation.gov.uk/ukpga/1984/51/section/104 ↩

  22. HMRC Inheritance Tax Manual, Section 11: Relief for business property. https://www.gov.uk/guidance/inheritance-tax-manual/section-11-relief-for-business-property; Farrer & Co, Commercial woodland can qualify for 100% BPR from IHT. https://www.farrer.co.uk/news-and-insights/woodland-tax/ ↩

  23. Forest Research, Woodland Carbon Code. https://www.forestresearch.gov.uk/climate-change/carbon/woodland-carbon-code/ ↩

  24. Defra, Spending Review 2025: a commitment to farming (June 2025). https://defrafarming.blog.gov.uk/2025/06/16/spending-review-2025-a-commitment-to-farming/ ↩

  25. GOV.UK, UK Government Green Financing Programme. https://www.gov.uk/government/collections/uk-government-green-financing-programme ↩ ↩2

  26. NS&I Annual Report and Accounts 2024-25. https://www.gov.uk/government/publications/national-savings-and-investments-annual-report-and-accounts-2024-to-2025/national-savings-and-investments-annual-report-and-accounts-and-product-accounts-2024-25-html; DMO, Green Gilts. https://www.dmo.gov.uk/responsibilities/green-gilts/ ↩

  27. GOV.UK, UK Government Green Financing Framework 2025. https://www.gov.uk/government/publications/uk-government-green-financing-framework-2025 ↩

  28. FCA, PS23/16: Sustainability Disclosure Requirements (SDR) (November 2023). https://www.fca.org.uk/publication/policy/ps23-16.pdf ↩

  29. GOV.UK, Inheritance Tax on unused pension funds and death benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩

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