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APR and BPR reform: time to make hay while the sun shines?

After a wait of four months for more detail on the changes, what does the consultation document now tell us? While there are some helpful clarifications, not all of the concerns are addressed, write Hayden Bailey and Emma Haley (Boodle Hatfield).

It’s been a winter of discontent for some farmers and business owners since the government announced their intention to restrict these inheritance tax reliefs at last year’s Autumn Budget. A consultation was promised on the application of the proposals to trusts and this was published by HMRC on 27 February 2025. After a wait of four months for more detail on the changes what does the consultation document now tell us?

To recap agricultural property relief (APR) and business property relief (BPR) operate by reducing the taxable value of qualifying property by either 100% or 50% depending on the type of property concerned. The...

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