Authors
Authors
The Government published the eagerly awaited draft legislation on its reform of Business Property Relief (BPR) and Agricultural Property Relief (APR) this week.
Overall, it is largely in line with what was announced in October and there were no big surprises. Critically, there is no delay to the commencement of the new rules, which remains 6 April 2026 despite significant lobbying.
Disappointingly, the £1 million allowance that qualifies for 100% relief is not transferable between spouses, as many had hoped it might be.
More positively, the £1 million allowance will be index-linked to the Consumer Price Index, but not until 2029/30 (it is frozen until then, like the Nil Rate Band).
The technical consultation on the draft legislation will run for eight weeks ending on 15 September.
Now is the time to review succession planning strategies and progress them to take advantage of the “window of opportunity” before April 2026 while the unlimited 100% relief still applies. The risk of further tax increases in the Autumn Budget cannot be ignored either.
Our Tax, Trusts & Succession team has significant experience in advising rural land-owning clients on their succession planning and efficient structuring. Please contact Iwan Williams, Elinor Crosbie Dawson or Charles Frost to discuss this further.