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How Agricultural Property Relief (APR) and Business Property Relief (BPR) work for farms and agricultural estates. Understand the allowances, qualifying criteria, calculate your potential liability, and plan your succession effectively.
You must check your farm estate against the Agricultural Property Relief (APR) and Business Property Relief (BPR) rules. From 6 April 2026, you get full (100%) inheritance tax relief on the first £2.5 million of qualifying assets per person (or £5 million for a couple). Above that, relief drops to 50%, meaning you pay an effective tax rate of 20% on the excess value.
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Agricultural Property Relief (APR) and Business Property Relief (BPR) can significantly reduce or eliminate the inheritance tax due when a farm passes between generations. However, 100% relief is capped at a combined threshold per person, meaning larger estates may face a tax liability.
This guide helps you understand how APR and BPR work for farms, assess your exposure, and plan your next steps.
This is a complex area with significant financial implications. We strongly recommend seeking professional advice from a solicitor or tax adviser experienced in agricultural estates before making any decisions.
Qualifying agricultural property and business assets can receive 100% relief from inheritance tax up to a combined allowance of £2.5 million per person.
Above this allowance, relief reduces to 50%. This means an effective inheritance tax rate of 20% on the excess value (half the standard 40% rate).
These rules took effect on 6 April 2026 under the Finance Act 2026 (section 65 and Schedule 12). The allowance was raised from the originally announced £1 million to £2.5 million on 23 December 2025. It is frozen at that level initially, then indexed to CPI from 6 April 2031.
For farms, BPR covers business trading assets that do not qualify for APR. This typically includes machinery, livestock, harvested crops, and trading stock.
The £2.5 million allowance applies to APR and BPR combined. You cannot claim £2.5 million for APR and another £2.5 million for BPR. The total across both reliefs is £2.5 million per person.
The allowance is fully transferable between spouses and civil partners, in the same way as the nil-rate band. This means a couple can pass on up to £5 million in qualifying agricultural and business assets with 100% relief. Where the first death occurred before 6 April 2026, the full £2.5 million allowance is treated as available to transfer to the estate of the surviving spouse or civil partner.
These allowances are in addition to the standard nil-rate bands (£325,000 per person, plus the £175,000 residence nil-rate band if passing a home to direct descendants - although the residence nil-rate band is tapered by £1 for every £2 of estate value over £2 million, so it is rarely available to larger farming estates). A farming couple could therefore potentially pass on more than £5.6 million tax-free in total.
APR applies to the agricultural value of qualifying property. This is the value the property would have if it could only be used for agriculture. For land with development potential, the agricultural value may be significantly less than market value.
Qualifying agricultural property includes:
Farmhouses are a common area of dispute with HMRC. To qualify for APR, the farmhouse must be:
A farmhouse used as a retirement home after the farmer stops working, or one that has been substantially extended beyond agricultural needs, may not qualify for APR.
APR has been extended to land subject to certain environmental land management agreements (such as SFI and Countryside Stewardship). This means land taken out of agricultural production for environmental purposes may still qualify for APR, protecting farmers who participate in agri-environment schemes.
BPR covers business assets used in the farming trade that are not agricultural property. For farms, this typically includes:
Some assets do not qualify for BPR:
To qualify for BPR, the asset must have been owned by the deceased for at least 2 years before death. For APR, the property must have been occupied by the owner for agricultural purposes for 2 years, or owned for 7 years while occupied by someone else (such as a tenant) for agriculture throughout. For inherited property, the previous owner's period of ownership can count if they also qualified for the relief.
Shares listed on AIM (Alternative Investment Market) only receive 50% BPR relief. This affects farming companies whose shares are traded on AIM.
If your total APR and BPR qualifying assets are under £2.5 million per person (or £5 million for a couple, as the allowance is transferable), you will continue to receive 100% relief and pay no inheritance tax on those assets.
However, you should still:
To understand your exposure, estimate your total estate value and how it splits between APR-qualifying, BPR-qualifying, and non-qualifying assets.
Instruct a qualified agricultural valuer (RICS or CAAV member) to value:
| Asset category | Typical relief |
|---|---|
| Farmland, farm buildings | APR at 100% to threshold, 50% above |
| Farmhouse (if qualifying) | APR at 100% to threshold, 50% above |
| Machinery, livestock | BPR at 100% to threshold, 50% above |
| Let cottages, diversified property | Likely no relief - full 40% IHT |
| Personal assets, savings | No relief (use nil-rate band) |
Example: a farm worth £4 million owned by one person
The same farm owned by a married couple: with the fully transferable allowance, the couple has £5 million of combined 100% relief. The £3.5 million of qualifying assets are fully relieved, and the £500,000 of non-qualifying assets are covered by the two nil-rate bands (£650,000 combined). No inheritance tax is due.
Without APR/BPR relief: the same estate would face significantly higher inheritance tax (100% of value above nil-rate bands at 40%).
If your farm operates as a partnership, each partner's share of the partnership assets is valued separately for IHT purposes. This can be beneficial:
Review your partnership agreement to ensure succession provisions work with the IHT rules. Consider whether the current profit and capital sharing arrangements are optimal for your succession plans.
Shares in an unquoted trading company (including family farming companies) can qualify for BPR. However:
If your farm is already incorporated, or you are considering incorporation, take specialist advice on how the rules affect your position. Incorporation can have benefits for lifetime tax planning but may complicate IHT.
If inheritance tax is due on agricultural or business property, the estate can pay in instalments rather than finding the full amount immediately.
This payment option may make it possible to pay IHT from farm income without selling land. However, you need to model whether the farm can generate sufficient cash flow to meet the annual instalments.
Farmers should take a proactive approach to inheritance tax planning:
Instruct a RICS or CAAV agricultural valuer to value your farm, separating agricultural value from market value where relevant. This is essential to understand your exposure under the current rules.
Check your will takes full advantage of APR and BPR. The £2.5 million allowance is fully transferable between spouses and civil partners, but correct drafting is still essential. Consider whether assets should pass in a different order.
Gifts of agricultural property or business assets can become exempt after 7 years (potentially exempt transfers). Weigh this against losing your CGT base cost and the risk of dying within 7 years. Gifts with reservation of benefit do not work.
If farming as a sole trader, would a partnership with your successor give more flexibility? If already incorporated, is the shareholding structure optimal? Get professional advice on the best structure for your situation.
A life insurance policy written in trust can provide funds to pay IHT without forcing a farm sale. The premiums may be expensive for older farmers, but the certainty can be valuable.
Keep evidence of active farming. HMRC may challenge APR claims years after death. Document who lives in the farmhouse and their role in the farm business.
This guidance provides an overview, but inheritance tax planning for farms is complex. Seek professional advice if:
Look for professionals with specific agricultural experience. The sector has unique rules that generalists may not understand fully.