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HMRC consult on APR/BPR changes for trusts

HMRC have launched a technical consultation as promised at Autumn Budget 2024 on the proposed reforms to IHT agricultural property relief and business property relief from 6 April 2026 with transitional provisions for transfers made before this date. In essence the 100% relief from IHT on qualifying business property including company shares and agricultural property which has applied for more than 30 years will be capped and a new reduced rate of relief of 50% will apply above the limit.

The consultation gives further clarification on these reforms in relation to trusts which hold qualifying agricultural and business property and it invites replies to nine specific questions which are mainly about their impact on trusts. To summarise the effect of the changes as they apply to trusts:

  • The changes will apply equally to trustees as they do to individuals...

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