Changes to APR and BPR
Rachel Reeves announced in the Autumn budget changes to Agricultural Property Relief (APR) and Business Property Relief (BPR). These reliefs reduce the value of qualifying agricultural or business property subject to Inheritance Tax (IHT) and are either available at 50% or 100%.
Currently, there is no upper ceiling on relief of this type that qualifies for 100% BPR or APR; however, from 6 April 2026, relief at 100% will only be available for the first £1 million of combined agricultural and business assets. Anything over this amount will only attract relief at 50%. The £1 million allowance will be applied proportionately across the qualifying property.
Assets currently only qualifying for 50% APR or BPR will not use up the £1 million allowance. If any of the allowance is unused it will not be transferrable between spouses and civil partners.
The £1 million allowance will also apply to trusts when calculating 10-year anniversary charges and exit charges. For Trusts created by 30 October 2024, each Trust will have a £1 million allowance for 100% relief. However, where a settlor has created more than one trust on or after 30 October 2024 the government is proposing dividing the allowance between the trusts.
AIM shares
The government also announced changes to the availability of BPR for shares designated as “not listed” on the markets of a recognised stock exchanges, such as AIM.
Currently, these types of shares attract 100% BPR but from 6 April 2026 relief will only be available at 50% in all circumstances.
The changes above will apply for lifetime transfers on or after 30 October 2024 if the donor dies on or after 6 April 2026.
Trusts, IHT and estate planning 
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