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Farm inheritance tax: what changes from April 2026

From 6 April 2026, 100% Agricultural Property Relief and Business Property Relief will be capped at a combined £2.5 million per person (£5 million for couples). Above the threshold, an effective 20% inheritance tax rate applies. This guide explains who is affected, the key thresholds, and what farm owners should do before April.

Change event: Farm inheritance tax reform: APR and BPR caps from April 2026 Effective 6 April 2026

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Topics

Tax & Finance

What is changing

Currently, qualifying agricultural property and business assets can receive 100% relief from inheritance tax, regardless of value. From 6 April 2026, 100% relief will be capped at a combined threshold of £2.5 million per person.

Above this threshold, relief reduces to 50%. This means an effective inheritance tax rate of 20% on the excess value (half the standard 40% rate).

The threshold covers both Agricultural Property Relief (APR) and Business Property Relief (BPR) combined. You cannot claim £2.5 million for APR and a further £2.5 million for BPR — the total across both reliefs is £2.5 million per person.

Changes take effect
6 April 2026
100% relief cap (individual)
£2.5 million (APR and BPR combined)
100% relief cap (couples)
£5 million (transferable between spouses)
Effective IHT rate above cap
20% (50% relief, so half the standard 40% rate)
AIM-listed shares (from April 2026)
50% BPR only (reduced from 100%)
Ownership requirement
2 years before death
Instalment option
10 annual interest-free instalments (for qualifying property)

Who is affected

The changes primarily affect:

  • Farm owners with combined APR/BPR qualifying assets above £2.5 million (or £5 million for couples)
  • Family businesses with significant business property qualifying for BPR
  • AIM investors — shares in AIM-listed companies will only receive 50% BPR relief from April 2026

Farms under the threshold continue to receive 100% relief and pay no inheritance tax on qualifying assets. However, land values can rise significantly, so even farms currently below the threshold should plan ahead.

Action required before April 2026

If your farm or family business assets may exceed £2.5 million, you should act now. Get a professional valuation from a RICS or CAAV agricultural valuer to understand your exposure. Review your will to ensure it takes full advantage of both nil-rate bands and the APR/BPR threshold — particularly for married couples, where correct drafting is essential to use the combined £5 million threshold.

Planning options to consider

Several planning strategies may reduce your exposure:

  • Lifetime gifts: Gifts of agricultural or business property become exempt after 7 years (potentially exempt transfers), but you lose your CGT base cost and gifts with reservation of benefit do not work
  • Partnership restructuring: Each partner in a farming partnership has their own £2.5 million threshold — restructuring ownership may help
  • Insurance: A life insurance policy written in trust can provide funds to pay any IHT liability without forcing a farm sale
  • Instalment payments: IHT on qualifying property can be paid in 10 annual interest-free instalments, which may be manageable from farm income

Seek professional advice

This is a complex area with significant financial implications. We strongly recommend seeking advice from a solicitor or tax adviser experienced in agricultural estates before making any decisions. The earlier you plan, the more options are available to you.

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